Panelists:
Randall D. Huffman, Ph.D., American Meat Institute Foundation
Alice L. Johnson, DVM, National Food Processors Association
William Brown, Ph.D., ABC Research Corp.
Scot M. Russell, Ph.D., University of Georgia

Food Safety Magazine: In your area of expertise, what are the top issues with regard to the current food safety, scientific, international trade and/or regulatory challenges faced by the meat and poultry industry today, and why?

William Brown: Hazard Analysis & Critical Control Points (HACCP) implementation and pathogen control are the two areas that are most troublesome to the meat and poultry processors with whom we work on a daily basis. Regulatory HACCP is difficult for processors to fit into a process control program. Process control was established to have control points measured and actions taken on the processing line. Microbial monitoring is not appropriate to be used as a critical control point. An example of this is attempting to control Listeria monocytogenes on fully cooked meat and poultry products. Microbial counts are not available for one to five days; therefore, Listeria monocytogenes control cannot be monitored as the manufacturing process is taking place.

Scott Russell: In the poultry industry the main areas of concern right now are issues that occur in the field as the chickens are being hatched and raised, which have a direct impact on regulations in the plant. This includes fecal contamination in the processing plant and Salmonella, E. coli and ingesta contamination. The U.S. Department of Agriculture (USDA) has zero tolerance for feces on the carcass. If any fecally contaminated carcasses get to the chiller in the processing plant then significant measures have to happen. One of the main problems related to this is that regulations place 100% of the responsibility on the processing plant, but there are a number of things that occur in the field that affect the processing and regulatory compliance, including the four types of contamination that I’ve just mentioned. For example, cross-contamination in the hatchery during the hatching process can directly influence the number of Salmonella-contaminated birds coming through the processing plant. The fact is that only very small decreases in Salmonella can be made at the processing plant. If the birds are coming into the processing plant highly contaminated due to cross-contamination during hatching or the grow-out phase, there’s only so much that the plant can do about it and yet all of the current regulation places the onus on the plant to deal with the issue completely.

As far as ingesta and feces contamination, it is the same situation. If problems occur in the field, such as overuse of certain kinds of antibiotics or the birds become diseased, then their intestines are going to be weak and when they go through the processing plant they will be torn and you will have feces all over the carcass and ingesta, which ultimately results in failures. And the plant gets all the regulations and yet there is nothing they can do about it. Another problem that occurs prior to the processing plant is the issue of feed withdrawal. The contracted grower has to go out in the middle of the night and take the birds off feed. If the birds are not off feed for a sufficient period of time, their intestines will be full of feces and you will have problems in the plant. Seasonal changes are another such issue. We see an increased number of USDA failures due to fecal contamination in the winter time. We don’t know exactly why. But the regulations put all of the onus on the plant as if the plant has total control of these types of variables. When there is cyclical variation in fecal or bacterial contamination going on due to weather, or when there are things in the field that occur due to unforeseen circumstances that will cause more contamination, it is difficult to understand why all the regulations are on the plant, which cannot control the weather nor the grower The poultry processors are doing everything the same as they’ve been doing when there was only 2% Salmonella contamination and no fecal. And yet the regulations are more stringent and plants are being shut down.

The government has talked about implementing HACCP all the way back to the field, but thus far it hasn’t happened. Until some of the responsibility is placed on the growers, these issues will remain of significant concern to poultry processors. Since processors have contracts with growers, the companies really don’t have that much control over how the grower manages the birds, except seeing at the plant end that the birds grow well and look healthy. But without some regulatory responsibility, the grower is not going to be responsible for implementing bacterial intervention strategies to try to help out the processing plant.

Another major area of interest to the poultry industry is the HACCP Inspection Models Program (HIMP) which was introduced by the USDA Food Safety and Inspection Service (FSIS). This program allows some plants, on a temporary basis, to operate HACCP by themselves and not be inspected. It is a trial to see if FSIS can do less inspection. The participating plants seem to like it really well, but there appears to be some tension between the plants and the inspectors in terms of implementing this HIMP program.

Currently, there are both research efforts and extension activities underway here at the University of Georgia to try to assist poultry plants in dealing with these challenges. These include development of more effective intervention strategies, such as ways to increase gut integrity, ways to manage the flock to reduce fecal or bacterial problems before the birds reach the plant, and ways to decrease cross-contamination in the hatchery and grow-out house.\

Alice Johnson: In talking about the meat and poultry industry, there are many issues that are considered top priority with regards to food safety. The meat and poultry industries are sincere in trying to obtain the best methods for handling these issues with currently available science. Scientific data gathering will continue to expand and serve to provide direction for the various challenges faced by the industry. Recognizing that each one of these challenges is unique with regard to specific products produced, research is providing the information needed to understand and to develop methods for their control. However, the major challenge for the industry may not be individual issues, so much as an overriding concern encompassing them all: how to mix science with public perception. All the science in the world can be tossed aside with one “sound bite,” swaying public emotion and influencing regulators, national and international consumers and the food industry itself. Products are being blocked from international trade due to unfounded scientific concerns. Regulations are being developed based on public concern, in some instances, sacrificing scarce resources that could be better spent focusing on true public health concerns.

With regard to the efforts underway to address this challenge, there are several key tools being used by the meat and poultry industry. The first and perhaps the most important is better use of the media. The American public is being bombarded with all types of information from all different sources. The meat and poultry industry must take advantage of all sources of media. When a consumer wants to find out more about bovine spongiform encepalophy (BSE) on the Internet, what keywords do they look up? “Mad Cow,” of course! The meat and poultry industry is working to use these tools in a manner in which information is provided in an easy to understand format.

I think a good example of moving toward creative media to get information to the public is through the Fight Bac campaign. This is a joint industry-government partnership that incorporates cartoon characters to illustrate food safety handling information.

Randall D. Huffman: Microbiological hazards continue to be the single most significant challenge facing our industry. From a technical perspective, pathogen elimination is challenging, if not impossible. While we have made enormous strides in reducing pathogens, we cannot eliminate every pathogen in every case without a final kill step in the process, such as cooking. For the foreseeable future, consumers will want to purchase many meat products in the traditional, raw form.

Complicating our efforts is an erroneous assumption by some groups that the presence of pathogens on meat and poultry is somehow the result of poor slaughtering or processing practices. Policies that approach the challenge of eliminating pathogens based on that assumption can do more harm than good because they will divert resources from areas that can truly enhance food safety.

I’ve seen many excellent companies with comprehensive and sophisticated food safety programs produce products that—despite every effort—test positive for a microbial pathogen. In some cases, these companies were devastated by recalls and negative publicity—even in the absence of illnesses. As a meat scientist, I share the historical view of the National Academy of Sciences, which as early as 1987 stated that pathogen standards and “zero tolerance” policies in and of themselves do not make food safe.

If you want to talk about making real progress, I think in the next few years we will see significant strides in the ability of producers to reduce pathogens in live animals, in new intervention strategies that reduce pathogens on carcasses during processing and in new ingredients that retard the growth of pathogens in processed products. All of these developments will help enhance food safety dramatically. But I think it is critical as we move forward with both food safety technology and food safety policy that we ask what impact our actions have on the public health, because that is what really matters—not what a test result alone can show.

Interestingly, BSE has become a larger and larger issue for the meat industry. Technically speaking, our risk of BSE in the U.S. is lower than it ever has been since the disease was first identified. This is because the U.S. government and industry took numerous actions soon after the first identification of the disease in the U.K. and have sequentially strengthened our firewalls. Despite this fact, the animal disease has devastated the British beef industry and approximately 100 people have been diagnosed with vCJD, a human disease that has been linked to BSE. As a result, our government continually scrutinizes our animal disease prevention, livestock production and meat processing systems so that we can continue to prevent the disease in the U.S. cattle herd.

While I feel more confident in the safety of U.S. meat than I ever have, the ongoing effort to minimize risk in the U.S. will continue to present challenges to the meat industry as policymakers and other groups seek changes that we may deem unnecessary given our B SE-free status. The fact is, the U.S. is not Europe and there are significant differences that must be recognized. We render products, raise animals and process meat in far different ways than they do in Britain. Our livestock populations and densities also are very different. And we have always been in the fortuitous position of preventing a disease we don’t have rather than trying to contain one we do have. Our policies must reflect these differences.

FSM: Recent government-driven initiatives focus heavily on food safety efforts regarding microbial contamination. For example, USDA FSIS’s new five-year strategic plan includes goals such as reducing by 50% the incidence of positive tests for Listeria on ready-to- eat meat and poultry products by 2005 and reducing Salmonella by changing the allowable level of contamination on boiler thickens (to drop from 20% to 7.5%), market hogs (to drop from 8.7% to 4%) and ground beef (drop from 7.5% to 4%).

And, in February, the agency published a proposed rule entitled, “Performance Standards for the Production of Processed Meat and Poultry Products,” in which the agency outlines food safety measures applicable to all ready-to-eat and all partially heat-treated meat and poultry products, as well as environmental testing requirements intended to reduce the incidence of Listeria monocytogenes in processed meat and poultry products.

Would the panelists comment on the concerns of and challenges faced by the meat and poultry industry with regard to these initiatives?

Brown: There are several reasons why Listeria has garnered heightened attention by regulators and industry. First, the death rate of people with listeriosis is as high as 25%, although it is rare in terms of associated incidents of foodborne disease, the percentage of fatalities is very high. Many of the pathogen’s essential characteristics also serve to make its presence in or on product an important food safety concern. For instance, Listeria grows at refrigeration temperatures, down to 40°F, posing a real problem for ready-to-eat meat and poultry processors, as well as other refrigerated food categories. Listeria is also more heat-resistant Salmonella or E. coli, about two-and-a- quarter times more heat-resistant than Salmonella or E. coli O157:H7 which means that any product that is undercooked has a possibility of Listeria contamination.

Listeria is also an environmental contaminant. For example, it can be brought into the plant on the feet of plant workers who live on farms or even enter the facility via airborne contamination from nearby sewage treatment plants. Listeria’s ability to stay in the plant for an extended period of time also adds to the problem. We know, for example, due to genetic testing, that a strain of Listeria found in one plant in the mid-1980s showed up again recently in a product produced by that same plant. In total, Listeria is a very difficult-to-control organism.

In terms of the government initiatives to reduce Listeria, I would say that the USDA is concerned with microbial standards in a way that makes it extremely difficult for industry to operate. Listeria is currently at the forefront of discussion, and as I’ve stated, is an important issue to be addressed by all involved in food safety and processing. However, the first problem with some of the Listeria-related agency initiatives is that there is no such thing as a zero tolerance. As long as we produce meat, poultry, vegetables and seafood, we’ll have pathogens in the product. I am concerned that we will waste too much time and effort trying to eliminate all pathogens from raw product. It just isn’t feasible. We are not able to completely eliminate organisms in the final product and therefore, a zero tolerance standard and final product testing mandates are not appropriate. I say this because a HACCP program is a process control program, which by its very nature is a program that aims at uncovering problems with the product and correcting them prior to shipping to the consumer.

In Listeria testing, for example, the results will be available on negatives 24 to 48 hours later, long after the product has gone through the process. On the final product testing discussed in the Listeria initiatives, it may take as long as five to seven days to get a confirmed positive. This time lag and the way in which we are trying to do the testing creates a real problem for the processor.

Another problem with testing for Listeria in a meat or poultry plant is the fact that if you find it in a fully cooked product, you must go through a recall. This creates a concern about finding Listeria and tracking its source. We try to talk plants into using microbial genetics techniques to find out where the Listeria is coming from so we can eliminate it from the plant, but the processors are quick to point out that the USDA recall penalty for finding it precludes them from wanting to do any additional testing. So finding a Listeria source and eliminating it in today’s regulatory climate becomes a real problem.

For all of these reasons, I think that processors are going to have a lot more trouble meeting the agency’s new strategic goals to reduce by half the number of positives for Listeria. The difficulty is that it can come from the environment, the raw product or from plant contamination, and there are probably even carriers in the workplace as cited in a European study of butchers identified as Listeria carriers. Even if we reduce the level of Listeria on the products, there is no guarantee that we are going to reduce the number of food poisoning cases that occur in the restaurants and homes. Cornell University researcher Martin Weidmann has done some really excellent work showing that all strains of Listeria are not pathogenic. Under the current regulatory program, however, the presence of Listeria monocytogenes forces the recall regardless of whether it is a virulent strain or a nonvirulent strain.

If our goal is to reduce the incidence of food poisoning, we need to concentrate on another area of our food system; in particular, focus more on the restaurants than on the food processors. I say this because approximately 50% to 80% of all food poisoning cases are of unknown origin, and of the remaining cases, 50% are caused by viral agents.

If you look at the Centers for Disease Control and Prevention (CDC) record, you find that approximately 60% of the food poisoning cases occur from restaurant-prepared food, 30% to 32% occur from food prepared in the home, and less than 10% can be traced back to the processing plant.

I think if we want to make some real inroads in reducing foodborne illnesses, we need to look at the cause of the food poisoning and concentrate more on the food service area. Proper education and training of food service employees should be our number one goal.

Russell: The creation of new laws and requirements doesn’t somehow magically cause bacteria to die or fall off of chicken. Just because you lower the amount allowable doesn’t mean it is going to occur. All that this does is increase the number of plants that are out of compliance. The government has reported that by implementing HACCP the number of Salmonella-positive carcasses has been reduced by about half. In actuality, this reduction is probably more due to the way carcasses are sampled with more diluent, and so, in reality, the numbers have probably not changed very much. If you look back at the historical data, even in the 1950s, you’ll see that the amount of Salmonella on chicken has not changed appreciably in the last few decades. So, just by lowering the allowable level of Salmonella to 7.5% as a requirement is not going to help anything.

Of course, this is a touchy issue for the poultry industry. The government really believes that the institution of HACCP has reduced the number of contaminated carcasses. But it has been done at a very high cost, and the question is, is it worth what is happening to the environment, to the processing plants, to the price of chicken and the amount of effort and expense that the companies are having to put forth to get it down another couple of percent? For example, what is the difference between the 9-10% the regulators are reporting now and 7.5%? Or put another way, has foodborne illness as a result of Salmonella contamination from chicken decreased as a result of implementation of HACCP? If it hasn’t, then why are we spending hundreds of millions of dollars trying to make it happen? These are the tough questions that people need to ask.

The fact is that when a plant gets shut down due to fecal failures or Salmonella failures, it is a major issue. You’ve got to do something with the many, many live animals in process. I’ve watched 42,000 birds in trucks in 90°F heat, waiting and ready to be processed, be put on hold for a plant shutdown. What do you do? You’ve got to clean out two entire chicken houses, put new water, feed and litter in, and put those birds in the chicken houses until you can get the problem squared away. And then you’ve got six-and-a-half weeks worth of chickens backed up, all at various stages of growth and ready to be processed. Four hundred chicken houses feed one chicken plant, and each chicken house contains 25,000 birds. If the regulator finds one speck of feces on a bird and shuts the plant down, it not only costs the company probably $500,000 a day, but is a major animal welfare issue. So we’ve got to think carefully about what these reduction numbers really mean.

Also, the poultry industry has experienced a skyrocketing of Listeria failures. Again, this is due to regulation, not necessarily because Listeria has increased. What you risk when these tolerances are set is that the companies do not want to test, because the more they test, the more they find, and the more they find, the more trouble they get into.

Johnson: FSIS has announced in its new five-year strategic plan, the agency’s goal to reduce Salmonella in certain raw products. The reduction of pathogens in raw products is a desirable goal for both industry and the agency. FSIS data indicates that the Salmonella numbers have dropped over the past few years. Industry has worked through various interventions to accomplish this type of reduction. However, it is very important to keep in mind that animals carry pathogens and that raw products produced from these animals will not be consumed without a process that kills the pathogen. The industry will continue to work through appropriate process steps and interventions to further reduce pathogens on raw products, but at some point, there will be a point of diminished return.

While continuing to accomplish pathogen reduction on raw products, industry and agency focus must be on the relative risk certain foods have to public health. Raw products that will undergo a thermal process before consumption provide a much lower risk to public health than ready-to-eat products. This brings in the discussion on the FSIS proposed rule on Performance Standards for Production of Processed Meat and Poultry Products published February 27 2001. This proposed rule for processed meat and poultry products is massive in scope and will have a very significant impact on the production of ready-to-eat products. As with any proposed regulation, it must be reviewed to determine whether or not it will enhance food safety. The RTE proposal provides some provisions that appear to present a significant burden with little or no likelihood of positive impact on public health. Some of the provisions might even be considered to lessen the public health protection and misdirect agency resources. It appears that in developing this proposal, FSIS totally ignored the finding of the interagency Listeria monocytogenes risk assessment, in that products that don’t support the growth of pathogens, identified as low risk, are treated the same as those given a high risk ranking. FSIS resources are not allocated in the most efficient and effective manner with regards to public health concerns. In addition, Listeria testing requirements may have a negative impact on public health in that they serve as a disincentive to aggressive testing programs. In saying this, it is important to recognize that this is a proposed rule and credit is to be given to FSIS for the open manner in which the agency has solicited public comment. The technical meeting held in May was excellent! Comments on the proposal are due in September. I am sure the agency will receive many substantive comments that will allow for changes to be made if there is a need for further rulemaking.

Huffman: The meat and poultry industry benefits by selling food that is as safe as it possibly can be. We support the government’s efforts to reduce pathogens. The industry shares this goal and believes it is laudable. No one is more committed to reducing pathogens than the people who process and sell U.S. meat and poultry products; it’s just good business.

Our chief concern is that government and industry work together as a team achieve results that enhance public health. For too long, we’ve played a game of “gotcha” in which the government focuses on trying to find problems—like pathogens on products. But we need to research our way out of pathogen challenges—not write rules that are unachievable, like zero tolerance for E. coli O157:H7 in ground beef While we’ve learned in many ways to live with the E. coli rule, the fact is, it is comparable to the government issuing a new regulation prohibiting car tires from becoming flat. Writing a new rule will not achieve that goal. But investing in research, technology and education of the workforce can at least bring tire makers closer to perfection.

The same goes for the meat industry. We certainly support pathogen reduction efforts. But pathogen performance standards are not the cause of reduced pathogens on meat products. What reduces pathogen on products is the use of better technology and the effort and hard work of those employees in the industry charged with producing safe products, day in and day out. Regarding the proposed RTE rule, AMI will be providing extensive comments on the proposed rule in the hope that we can ensure that it is grounded in risk-based science, is achievable, and that it ultimately will benefit the public health.

FSM: In your opinion, what are some of the most significant analytical, testing, technological and/or intervention advances that have been made in the meat and poultry industry in terms of microbiological, chemical or physical hazards?

Brown: One such advance can be seen in the antimicrobials that are used in the slaughtering of cattle and in the processing of poultry. There are a couple of compounds in particular that have been used successfully. For example, sodium chlorite reduces incidence of pathogens on both beef cattle and poultry carcasses, and trisodium phosphate has been used to reduce pathogens on beef and poultry carcasses. Other intervention strategies that have been used successfully are steam pasteurization (hot water pasteurization) and a number of organic acids approved as carcass washes to reduce pathogens.

Even with the successful use of intervention and pathogen reduction strategies, I think the overall incidence of food poisoning is probably staying at approximately the same level. The 1999 CDC data shows E. coli O157:H7 with 73,000 cases, 61 deaths; Salmonella with 1,412,000 cases, 582 deaths; Campylobacter with 2,453,000 cases, 124 deaths; and Listeria monocytogenes had a much lower number of cases, 2,518, but a higher number of deaths, 504. It appears that we are doing a good job of reducing the pathogens on beef; pork and chicken, but it isn’t following through with a huge reduction in food poisoning cases. Perhaps one of the reasons for this is that the same microorganisms showing up in clinical isolates from hospitals.

Microbiology is an extremely complex issue, and the microbe will find a way to get around any intervention that we put in place. Microorganisms are adaptable and the mutation rate of pathogens is much higher than the mutation rate of most other microorganisms. This means that when we try to eliminate the pathogenic microorganisms by putting up hurdles, they find a way to go around the barrier. Having said this, our testing and analytical methods are improving all the time. Not too many years ago, for example, food service operators were willing to accept a 750,000 or one million total count per gram on ground beef as standard. Today, most beef processors are producing product with less than 10,000 total count per gram.

The development of rapid microbiological methods has enhanced detection and confirmation efforts in the meat and poultry industry. From our own laboratory work, we routinely run traditional organisms of concern: Salmonella, E. coli, and Campylobacter. The level of the latter is much higher than the other pathogens on meat and poultry, which jibes with the 1999 CDC data that reports that Campylobacter is associated with more food poisoning cases than Salmonella, E. coli and Listeria monocytogenes combined. The development of methods for Campylobacter, for example, provides a good example of the usefulness of these quicker tests. Twenty years ago, it probably would have required 20 to 30 days to get a positive result, because of the time- consuming methodology involved. Today, we have rapid methods using the enzyme-linked immunosorbent assay (ELISA technology) and are able to get negatives on most of the pathogens within one or two days, depending on the amount of time required for enrichment. Of course, we still have to use the methods provided in the FDA Bacteriological Analytical Manual (BAM) and USDA Microbiology Guidebook in order to confirm. Recently, there have been some developments in the confirmation process that promise to make the time-to- result much shorter, hut currently these are not approved by the regulatory agencies. However, some of these rapid confirmation methods have been tested in the commercial laboratories and found to be acceptable. I envision that in another year or two we will be able to get faster results.

We also need to concentrate our efforts on environmental monitoring. Many technological advances have helped industry to more effectively track such environmental contaminants as Listeria. Microbial genetics techniques by Dr. Samadapour at Washington State University, DL Benson at Nebraska and DL Weidmann at Cornell University have given use the tools to determine where the pathogen is coming from and also whether a particular organism is the cause of illness.

Again, intervention strategies will be more effective if we begin all the way back at the farm, including feeding probiotics to livestock to eliminate pathogens from the animal’s gut or utilize vaccines. The source of the problem is the farm, and I think that if you can better control or eliminate the organisms