Since the packer/processor has no direct control over their supply base, A.M.I. argued that the use of pre-harvest programs would be difficult to implement. “When supplier programs can be used to support the hazard analysis determination, then these producer-driven pre-harvest programs could become part of the Hazard Analysis and Critical Control Point (H.A.C.C.P.) plan,” A.M.I. said.
According to A.M.I., the guide does not address that a large amount of beef livestock are marketed through auctions. Customer specifications would not be feasible in this type of marketing scenario as pre-harvest on-farm information would not be known. Whereas, plants and processors that buy livestock directly from feedyards or dairies could be able to address a specification program.
“The impact of the guide on these marketing scenarios needs to be reviewed before final issuance,” A.M.I. said.
The association is also concerned that current research does not conclusively demonstrate a reduction in shedding, yet the agency still supports these principles for animal health and welfare, which is not supported or in the scope of purpose of this guide.
A.M.I. encouraged federal agencies to approve pre-harvest interventions that can truly impact shedding of E. coli O157:H7 in a timely fashion.
To read A.M.I.’s comments, visit http://www.meatami.com/ht/a/GetDocumentAction/i/61005.