More Arguments For ‘Hold and Test’

On December 10th, I praised the introduction of the new ‘Hold and Test’ policy announced that day by USDA’s Food Safety and Inspection Service (FSIS) while, at the same time, lamenting its limitations. And I asked eFoodAlert readers to respond to a survey on what FSIS should do to improve food safety.

Here are the results of that survey:

  • Mandate ‘hold and test’ for all meat and poultry processors: 35%
  • Add Salmonella to the list of beef adulterants: 21%
  • Increase USDA’s sampling frequency at meat and poultry establishments: 19%
  • Test every shipment of meat or poultry imported into the USA: 22%

Three readers submitted their own suggestions, which were:

  • Publish in stores for customers to view
  • Fruits and veggies need HOLD too
  • Ensure meat and poultry used for pet food is completely safe as well.

I thank everyone who took the time to respond to the poll, especially, those who submitted their own suggestions. I have long thought that giving maximum publicity to recalls – including posting recall information in stores – would both improve the effectiveness of recalls and encourage food manufacturers to undertake preventative measures in order to avoid the adverse publicity that such recall notices would mean.

I also endorse completely the extension of ‘hold and test’ to all foods, including perishable produce. As I’ve stated in the past, current lab methods provide fast answers. And the tests continue to improve as kit manufacturers compete to develop and market the fastest possible lab tests. Finally, as the human companion of a ten-year-old Australian Labradoodle, I am always mindful of the importance of ensuring the safety of ingredients used in the manufacture of pet food.

Since my December 10th post, there have been at least two more recalls that illustrate the value of ‘hold and test’ as a fundamental food safety policy.

  • On December 14, 2012, Ocean Beauty Seafoods LLC recalled two brands of Nova Cold Smoked Salmon after “…internal testing by the company revealed the presence of Listeria monocytogenes in samples…” of the recalled products. The Nova Salmon was imported into the USA from Chile.
  • On December 28, 2012, the French cheesemaker Fromagerie de Jussac recalled nearly two months worth of cheese production after Listeria monocytogenes was found in “certain lots” of nearly twenty varieties of its cheeses. The cheeses were sold in France and were exported to a number of countries, including: Andorra, Austria, Belgium, Germany, Italy, Lebanon, Spain, United Arab Emirates, United Kingdom and Vietnam.

Although no illnesses were reported in connection with either of these recalls, there is no question whatsoever that releasing food into the retail market before test results are available places consumers at risk unnecessarily. If the food industry and its regulators make just one resolution for the New Year, it should be to ‘Hold and Test’ all batches of finished product.

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.