USDA’s ‘Hold and Test’ Policy: Limitations and Loopholes

This morning, USDA’s Food Safety and Inspection Service (FSIS) released the details of its new ‘hold and test’ policy for meat and poultry products. While the policy marks a step forward for food safety, the details reveal several limitations and loopholes that will limit its effectiveness at reducing the number and magnitude of recalls.

1. The policy will apply to “non-intact raw beef product or intact raw beef product intended for non-intact use” that is tested by FSIS for E. coli O157:H7 and six other shigatoxin-producing E. coli (STECs) that FSIS has designated as adulterants in these products. It does not apply to “…raw meat or poultry products tested for Salmonella or other pathogens that FSIS has not determined to be adulterants in those products.”

2. The policy will apply to any ready-to-eat products tested by FSIS for pathogens, and to ready-to-eat products that passed over food-contact surfaces that have been tested by FSIS for the presence of a pathogen.

3. The policy will apply to livestock carcasses tested by FSIS for the presence of veterinary drugs. It will not apply to poultry carcasses tested for those drugs.

For those who may have missed it, THIS POLICY ONLY APPLIES TO TESTS CARRIED OUT BY FSIS. FSIS tests only a small fraction of the meat and poultry products that are released into commerce every day. Most production line and finished product testing is carried out by food establishments; some using their own in-house labs, and others by sending samples to free-standing independent testing labs. FSIS encourages, but does not mandate, ‘hold and test’ under these circumstances.

In spite of these limitations, FSIS calculates that its new policy will yield an economic benefit of between $12.8 million and $37.8 million annually, comprising:

  • Reduced cost of recalls: $12 million to $37 million
  • Actual averted illnesses: $650,000
  • Estimated averted illnesses from E. coli O157:H7, Listeria monocytogenes and Salmonella: $106,724

This benefit will more than offset the estimated costs to industry of $923,000 to $1.4 million annually, according to FSIS calculations.

It is said that every journey begins with a single step. FSIS, to its credit, has made some strides in the right direction over the last few years – releasing retail distribution lists for recalled products, expanding the list of pathogens that it considers to be adulterants, and now mandating a limited ‘hold and test’ initiative.

What do you think should be FSIS’s next step? Please take this eFoodAlert survey.

3 thoughts on “USDA’s ‘Hold and Test’ Policy: Limitations and Loopholes

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