Month: December 2012

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.

USDA Embraces ‘Hold and Test’ For Meat and Poultry Products

Beginning 60 days from now, USDA’s Food Safety and Inspection Service (FSIS) will require producers and importers of raw beef – and of all ready-to-eat products containing meat or poultry – to hold these products until they pass FSIS tests for adulterants.

Products affected by this new policy will not be permitted to enter commerce until negative test results are received. FSIS estimates that, had this policy been in place between 2007 and 2010, 49 out of 251 recalls of meat, poultry and processed egg products could have been avoided. Based on the information contained in the FSIS Recall Archive and list of Current Recalls, the new ‘hold and test’ policy could have prevented the recall of more than 200 tons of meat, poultry and processed egg products in 2011, and more than 175 tons in 2012.

Although finished product testing is not, of itself, a guarantee of food safety, any reduction in the quantity of pathogen-contaminated or adulterated food in the marketplace also reduces the risk of food-borne illnesses. There are, in addition, economic benefits to a ‘hold and test’ policy, including a reduction in the expenses associated with recalls. Not the least of these expenses is the effect of a major recall on the image of the recalling company.

‘Hold and test’ is a sensible policy that should be part of every company’s food safety program. Are you listening, Unilever? Are you listening, Spence & Co.? Are you listening, Kenny’s Farmhouse Cheese? Are you listening, J.M. Smucker?

Are YOU listening, FDA?

Prompt Prose: Still Waters

Canadians are known to be quiet and reserved. Canadians who were born and raised in England make the rest of the population look like wild barbarians. And then there’s Auntie Minnie.

Auntie MinnieMinnie was the primmest of the prim – a true, proper, English lady, with manners fit for the Royal Court. Everything about her was diminutive: just five feet tall, always soft-spoken, always dignified. Never a hair out of place, her back was as straight as her perfectly vertical stocking seams. Yes, Auntie Minnie was the epitome of British-Canadian comportment – the Dowager Duchess of our family.

When her Grand-nephew, Gordon, decided to take a bride in Toronto, the entire family was invited to his wedding. Although my parents decided to travel by car, most of the Montreal contingent – including Auntie Minnie – chose to take the train. Rumor has it that the wedding party began on that train ride, in the train’s “refreshment” lounge. I don’t know how many bottles of gin, bourbon, vodka and Crown Royal were emptied during that six-hour revel.  What I do know – what the rest of us learned after the “gang” poured into the hotel where all of the wedding guests were staying – is that prim, proper, petite Auntie Minnie was the life of the party.

The story of Wild Auntie Minnie became a family legend, epitomized in the bit of doggerel that made the rounds all weekend, and that was sung loudly on multiple occasions during the wedding reception:

My Wild Auntie Minnie,
Remember when she was skinny.
Now look at her today,
All old and gray,
My Wild Auntie Minnie!

Some say that booze will shorten one’s lifespan. But I don’t know. Minnie was only 70 years old when she had her fling; she lived to celebrate her 90th birthday. Still prim, still proper, still petite. And, to us, always our Wild Auntie Minnie.