HACCP proposal prompts hand wringing

by Bernard Shire
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Last year, President Obama and members of his White House Food Safety Working Group created some priorities they felt were needed to improve food safety in the United States. These changes were necessary because of what they considered to be avoidable food-safety hazards in the domestic food supply that can lead to foodborne illness. So, the U.S. Dept. of Agriculture has proposed several regulations to implement what the president and his food-safety group feel is important.

Unfortunately, these proposals, which are open for public comment by the industry and other interested parties, could result in ending voluntary product recalls by the meat, poultry and other food-processing industries in the U.S. These proposed plans, which are published in the Federal Register, would also require plants to document how they regularly reassess their HACCP plans, when the plant modifies its processes or the plans it operates.

USDA’s Food Safety and Inspection Service (FSIS) is proposing to turn several provisions of the 2008 Farm Bill into specific regulations. They would have poultry and meat establishments under federal inspection notify the FSIS District Office they operate under when an adulterated or misbranded meat or poultry product has entered public commerce. The proposed regulation would also require regulated establishments to prepare and maintain current procedures for recalling products produced and shipped by the company. The rule would also require all inspected establishments to document their HACCP plans every time it decides to reassess those plans.

Mandatory recalls?

The problem with the first part of USDA’s proposed regulation is plants already notify the secretary of agriculture, via FSIS, when they believe contaminated or misbranded poultry or meat products they’ve received or produced, have entered public commerce. Yet, this regulation would require plants to notify USDA of the type, amount, origin and destination of the adulterated product in commerce. When this happens, plants immediately begin to mount a recall of these products. By putting a regulation like this info effect, USDA will be forcing plants to carry out a recall, an action the plant already takes on its own.

No meat or poultry company has ever refused to cooperate with a mandatory recall. But under some plans floated in Congress requiring plants to conduct a recall, the time elapsed until such a recall begins could actually be longer than the current voluntary system, ranging from a number of hours to several days. USDA has warned of greater delays in recalls under a mandatory system.

Most plants already have recall procedures or plans. Trade associations also play a prominent role in assisting small and very small plants to create a plan they can use immediately to mount a product recall or to help a plant that would need to launch a recall. FSIS also provides help to a plant. But in most cases, the plant is ready or can get the help it needs. This is better than having a canned recall plan gathering dust in a drawer that no one in the plant knows anything about.

The proposed rule would also require meat and poultry plants to reassess their HACCP plans at least once a year or when any changes are made in the HACCP plan or in the plant-processing procedures affecting the company’s hazard analysis. FSIS officials say it occasionally notifies the public when changes take place affecting the hazard analysis or company HACCP plans for particular products. One example: FSIS publicized the fact about new scientific data showing E. coli O157:H7 was more prevalent than originally thought. The inspection agency also notified the public about outbreaks of E. coli in mechanically tenderized beef.

The agency says it will now require establishments to document changes in their HACCP plans by making the change or changes in writing, claiming in the past, such documentation wasn’t required. But when plants have reassessed their HACCP plans, the changes and the detail in the new plan or plans have always been in writing. Trade associations and consultants who help firms reassess or re-write their HACCP plans have always listed the changes; otherwise how would anyone, including the plant operator or inspector, know what they are?

So this section of the proposed rule is asking plants to do something they already do. FSIS’ claim they aren’t currently complying with regulations is ludicrous.

The new regulation is based on additions to the Federal Meat Inspection Act adopted as part of the 2008 Farm Bill. But since plants already are doing these things under the current HACCP regulations, this proposal seems like duplicative overkill. •

Bernard Shire is M&P’s Washington correspondent, a contributing editor and a feature writer based in Lancaster, Pa. Sire also works as a food safety consultant and writer for Shire & Associates LLC.
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