“The food industry is committed to doing everything within its powers to ensure that its products are the safest and most wholesome in the world,” said Gary Jay Kushner, a legal expert from Hogan & Hartson, L.L.P. “But USDA does not need additional enforcement authority; more punitive measures cannot make our food safer.”
The trade associations represented were the American Meat Institute, Grocery Manufacturers of America, National Broiler Council, National Food Processors Association and National Turkey Federation.
“USDA has more than enough authority to obtain prompt removal of unsafe products from the marketplace, and to make sure that companies who are uncooperative with the agency or who are found to be in violation of the law are sanctioned,” Kushner said. “Additional recall authority is not justified.”
Dr. Mike Doyle, director of the University of Georgia’s Center for Food Safety and Quality Enhancement, said “the emphasis of our discussions should be how to prevent the risks of foodborne illness in our food supply.” He cited E. coli O157:H7 as one of the more significant foodborne illness problems, and said that the pathogen’s low infectious dose and the severity of the disease it can cause mean that successful prevention strategies must focus on reducing or eliminating its presence.
In the area of prevention, the industry can report tremendous gains, said Greg Page, president of the Red Meat Group at Cargill Incorporated. As an example, he reported that new technology such as steam pasteurization and steam vacuums can, when used properly, reduce bacterial counts on beef carcasses by as much as 99.999 percent.
Despite these advances, Page said “we cannot guarantee raw food products are free from all risks.” Neither can government food inspection systems guarantee zero risk, he said. “Only the final food preparer can eliminate many of these risks, but consumer knowledge is needed to achieve that result.”
As a more practical approach to improving food safety, Page offered the following suggestions:
a comprehensive, coordinated and prioritized approach to food safety research.
Doyle noted that HACCP systems can reduce the risk of E. coli O157:H7 infections, “but they are not infallible. For example, the low incidence of this pathogen in foods makes direct microbiological testing for the pathogen as a means of verifying the effectiveness of a HACCP program of limited benefit.”
“What we need,” Doyle said, “is a process that includes a step that kills this pathogen.” He cited heat (cooking to 160 degrees for meat and poultry) and ionizing radiation (approved for some foods, pending for red meats) as two viable kill steps.
“I believe ionizing radiation is a promising technology because it can eliminate E. coli O157:H7 while maintaining the raw character of foods,” Doyle stated.
Doyle also noted that research on farms indicates that “we may find animal feed or health management practices that could reduce the incidence of some pathogens in otherwise healthy animals.” He also noted that, at the other end of the food continuum, there is a striking knowledge gap among consumers about proper food handling, preparation and storage. “More aggressive educational efforts could help convince consumers that they have the power to protect themselves, and teach them the basic principles to keep themselves and their families safe.”
Commenting on the proposed bill to enhance USDA authority and punitive powers, Kushner said, “The...proposal is not new. The same provisions, in one form or another, have appeared many times over the past two decades. Each time, Congress has recognized the breadth of the agency’s current enforcement arsenal; each time, Congress has questioned how effectively the department has used its existing authority; and each time, Congress has considered companies’ Constitutional due process rights. Every time USDA has sought this kind of legislative authority, Congress has said ‘no’. We urge this Committee to reject USDA’s latest proposal for the same reasons.”
BEN ZINGMAN, GMA, 202/337-9400
BILL ROENIGK, NBC, 202/296-2622
KELLY JOHNSTON, NFPA, 202/639-5900
JOEL BRANDENBERGER, NTF, 202/898-0100