AMI conveys support for test-and-hold procedures
WASHINGTON – Once again, the American Meat Institute voiced its support for controlling sampled product in comments submitted in response to Food Safety and Inspection Service (FSIS) Docket No. 2005-0044: Not Applying the Mark of Inspection Pending Certain Test Results. This announced FSIS’ intention to withhold a determination as to whether meat and poultry products are eligible to enter commerce until all test results that bear on the determination have been received.
“AMI has long advocated as a ‘best practice’ that establishments retain control of sampled product to avoid a recall in the event the test result is positive for an adulterant,” the comments stated.
The association along with several other organizations – and with assistance of and encouragement from FSIS – mailed a best practices document in September 2005 encouraging them to adopt a policy to control tested product until the results are known to every small and very small federally inspected establishment. AMI also requested on two occasions the agency adopt a policy that is largely consistent with the concepts articulated in the published notice.
AMI stated it supports the concepts articulated in the notice, with the following clarifications:
- The policy should not require the use of company seals but should allow the use of other effective mechanisms in addition to seals.
- The agency’s policy should not provide for agency retention of any FSIS tested product, but rather the policy should allow a company to utilize its own, effective control measures to ensure the product is not used or distributed for sale to consumers before the test results are known.
- AMI disagrees with the agency statement that “if the establishment moves the product to other locations, it would not be able to transfer ownership of the product until negative test results become available.” Strict application of this approach would force an unnecessary change in business practices and could create chaos with a supply chain that relies on fast distribution times because of quality and shelf life issues. The critical issue is not one of ownership; rather it is one of product control.
- In addition, the pre-discussed concepts advanced by AMI in these comments regarding this policy should apply not only to domestically produced products but also to products exported to the US.