The meat and poultry industry believes that risk-based policymaking is key to enhancing public health. We support Food Safety and Inspection Service (FSIS) and Food and Drug Administration (FDA) risk assessments because they can guide the federal government in using resources appropriately where they achieve the greatest public health enhancements.
We believe it is appropriate that these federal agencies seek public comments on the risk assessments so that scientists will have the opportunity to make meaningful contributions to the progress of these risk assessments. Scientists from the meat and poultry industry have reviewed FSIS’s draft Listeria risk assessment and believe there are a number of changes that should be given serious consideration.
First, several existing data gaps must be filled. The draft risk assessment does not provide all references cited in the document, nor has all current, relevant scientific literature been integrated into the document. In addition, it is important not to rely on single sets of data from single situations in assessing the risks posed by a wide variety of meat and poultry products produced under varying circumstances with different pathogen intervention technologies. Many technologies and sanitation practices impact risk; these factors must be incorporated if the risk assessment is to be of scientific value.
Second, the draft risk assessment needs to describe in greater detail the limitations of microbiological sampling and testing programs given the low prevalence and random distribution of Listeria on food contact surfaces and in ready-to-eat meat and poultry products. When bacteria occur at extremely low levels or are not evenly distributed in the product or in the processing environment, as is the case with Listeria, testing programs must be very flexible and must be designed to be biased toward finding the organism. The draft risk assessment has not been developed to account for this level of detail or complexity.
Third, we urge FSIS to release the draft risk assessment for “use and experimentation” by interested stakeholders. We believe that this will provide an opportunity for hands-on analysis and scientific peer review so that meaningful comments can be developed that will ultimately enhance the tool.
It is important to keep in mind that FSIS’s draft risk assessment is designed to assist policymakers in developing an effective risk management plan. The FSIS risk assessment on deli meats must be viewed in the context of the risks posed by all foods. FDA is in the process of finalizing its risk assessment for a wide variety of food categories. The FSIS risk assessment relies on data that are being compiled through FDA’s risk assessment to assess the public health impacts. We urge FSIS to wait for FDA to complete its risk assessment before finalizing its own.