Sample-ready, or not?
by Bernard Shire
Beginning June 4, the US Dept. of Agriculture’s Food Safety and Inspection Service meat inspectors began collecting samples of beef trimmings and other raw ground-beef components in slaughter plants to test for six additional strains of E. coli declared as adulterants by the federal agency last fall. The sampling of the six strains is in addition to testing for E. coli O157:H7 that has been underway for years and continues. The new sampling will be limited at first to slaughter plants where beef manufacturing trimmings are manufactured for use in ground beef.
In order to prepare the beef industry for this new regulation, including USDA’s expansion of the number of adulterants in ground beef and the inspection agency’s new search for these adulterants, 14 meat industry trade associations conducted a webinar for their processor members last month. More than 300 trade-association members participated. Two FSIS officials conducted briefings for the meat industry and answered questions during the electronic meeting. Dr. Daniel Engeljohn, former policy administrator for FSIS and now head of the agency’s field inspection division, told processors what the agency expects from them under the new testing program. Dr. Emilio Esteban, a USDA Public Health and Science official from the agency’s laboratory in Athens, Ga., told processors how the agency plans to find and isolate the six pathogens that are now considered adulterants.
New adulterant policy final
Engeljohn noted the new policy naming the six additional E. coli strains as adulterants is final and will not be changed or reversed. “This new policy affects six, non-O157:H7 shiga toxin-producing E. coli strains,” he said. “These strains are now adulterants in certain raw, non-intact beef products [ground beef], along with E. coli O157:H7, which continues to be an adulterant, as it’s been for many years.”
While he pointed out to processors what the inspection agency expects industry to do, Scott Goltry, the American Meat Institute’s vice president for technical services, who hosted the webinar, provided industry members with scientific supporting documentation that showed current programs controlling E. coli O157:H7 are also effective against the six additional adulterant strains. Goltry has also furnished meat processors with information supporting the use of E. coli O157:H7 as an “indicator organism” for the six types. The information comes from the AMI Foundation, AMI’s research arm.
Goltry said the second study released by AMI found “indicator organisms” can play a major role in helping a process management system address pathogens of concern. “Given the history of outbreaks and the industry’s success in reducing O157 prevalence in beef products, O157 is likely the best microorganism to target in reducing the risk,” he said.
In the AMIF statement, Goltry noted FSIS published a review noting indicator organisms “are those organisms whose presence in numbers above certain limits indicate inadequate processing for insuring pathogens would not be present.”
Ann Wells, director of scientific and regulatory affairs for the North American Meat Processors Association, emphasized the new FSIS testing program is for manufacturing trimmings only, which are only produced at slaughter facilities, so FSIS will not be changing its testing program at grinding or fabricating facilities – yet. For that reason, bench trim, which is trim processed at grinding facilities into ground beef, as well as ground beef itself, will not be part of this new testing program in the beginning. She noted FSIS has not told its inspectors to write noncompliance reports (NRs) or conduct assessments of companies doing further processing of beef, such as grinding (beyond slaughter) regarding the six additional strains of E. coli. It would be helpful for processors to discuss the issue with their inspectors, Wells suggested.
But Engeljohn pointed out after the testing program is in operation for 90 days or so, possibly in September of this year, the agency will issue a Federal Register Notice indicating the testing program will be expanding from slaughter plants into further-processing plants. “There will be plenty of notice to the industry when that is going to happen,” he said. During the 90 days, plants should collect relevant data to support their controls for the six adulterants, particularly if they rely solely on E. coli O157:H7 testing results, he said.
“After the 90 days, FSIS will survey beef establishments to find out what changes there have been to controls for E. coli throughout the industry. We’ll also begin routine food safety assessment activities,” he said.
How to prepare
Engeljohn explained the new testing program will not be limited to domestic beef production, but will also apply to imported products. He was also asked during the meeting what steps slaughter plants should take during the 90-day period until September to make sure their products don’t contain any of the additional six strains of E. coli. “If plants are not doing testing of the manufacturing trim themselves, then it might be prudent for them to look at their slaughter-dressing programs to make sure they are preventing contamination. They also might want to reexamine their E. coli O157:H7 control program to make sure it’s working OK,” Engeljohn said. “If there is no O157:H7, but they find any of the six new adulterants, then their plant program is not controlling them, and they have to correct that.”
In the beginning, FSIS will not schedule “for-cause” food-safety assessments in plants if there is a positive sample found. Engeljohn said plants are not required or expected to reassess their HACCP plans immediately. But the agency will take action in the case of a positive, just as it would if it found a positive of E. coli O157:H7, including requiring follow-up sampling at the plant.
The FSIS official was also asked how meat plants, both slaughter and processing, can prepare for the new testing. “For slaughterers, during the 90-day period, they need to look at their non-O157:H7 data and slaughter dressing, and operations controls, including their hide removal, and make sure there is no contamination in the animals’ digestive tracts, and no other visible contamination,” he said. “They should look at their operations, their support documentation for E. coli O157:H7, and their testing results.
“For processors, since they’re buying trim to make ground beef, they can take the same steps the slaughter establishments are. Processors should look at their Letters of Guarantee and their Certificates of Analysis, making sure they reflect the new adulterants, as well as traditional O157:H7,” Engeljohn advised. He and Wells suggested processors communicate with their suppliers of raw materials for grinding, and eventually replace current letters and certificates with updated ones as they are made available by the suppliers.
Dr. Emilio Esteban described the testing procedure meat inspectors and agency laboratories will use for the six additional E. coli pathogens. He said sampling and analysis will be the same as for E. coli O157:H7. “Potential positives will be identified by the second day,” Esteban said, “and by the third day, the analysis will be complete; we’ll find either a presumptive positive or confirm there’s no pathogen present.” He said if the sample of trim contains a pathogen, any of the six adulterants or E. coli O157:H7, it will be confirmed by the fourth day.
Bernard Shire is a contributing editor based in Lancaster, Pa. With a background in editing and writing for daily news publications, he also works as a food safety consultant and writer for Shire & Associates LLC.