AMI Addresses Flaws in FSIS Pre-Harvest Management Controls GuideThursday, July 15, 2010
(American Meat Institute)
AMI supports the use of appropriate pre-harvest programs to reduce shedding of E. coli O157:H7, but there remains a lack of scientific evidence to support the incorporation of such programs and this process would be impractical to implement. AMI made its comments in response to Docket No. FSIS-2009-0034: Pre-Harvest Management Controls and Intervention Options for Reducing Escherichia coli O157:H7 Shedding in Cattle-May 2010 (Guide).
AMI notes that since the packer/processor has no direct control over their supply base, the use of pre-harvest programs would be difficult to implement. “When supplier programs can be used to support the hazard analysis determination, then these producer driven pre-harvest programs could become part of the HACCP plan,” says AMI.
In addition, AMI says the Guide does not address the fact that a large amount of beef livestock are marketed through auctions. Customer specifications would not be feasible in this type of marketing scenario as pre-harvest on-farm information would not be known. Whereas, plants and processors that buy livestock directly from feedyards or dairies could be able to address a specification program.
“The impact of the Guide on these marketing scenarios needs to be reviewed before final issuance,” AMI states.
AMI is also concerned that current research does not conclusively demonstrate a reduction in shedding, yet the agency stills supports these principles for animal health and welfare, which is not supported or in the scope of purpose of this Guide.
In conclusion, AMI encouraged federal agencies to approve pre-harvest interventions that can truly impact shedding of E. coli O157:H7 in a timely fashion.
To view AMI’s comments go to http://www.meatinstitute.org/ht/a/GetDocumentAction/i/61005.share on facebook share on twitter