Monitoring critical control points key to safer meat products
by Bryan Salvage, editor
Each link of the American meat chain (producer, packer, processor, distributor, retailer and foodservice operator) must establish, utilize and enforce Hazard Analysis and Critical Control Point programs throughout their operations to ensure consumers get the safest meat possible, most industry officials agree.
"One of the most helpful steps in enhancing meat safety would be a mandatory requirement for HACCP in all meat and poultry plants," AMI president J. Patrick Boyle stresses. "While HACCP's detractors like to make the program seem risky, in reality, HACCP is a proven process control technology which is endorsed by the National Academy of Science and other independent scientists throughout the country."
During the late 1980s, then-FSIS Administrator Lester Crawford requested an ad hoc working group to draft a guide to set forth the principles of HACCP systems. The group defined HACCP as a systematic approach to be used in food production as a means to assure food safety.
Although seven basic principles (see chart on page 21)-which include an assessment of the inherent risks that may be present from harvest through consumption-underlie the concept, the group recommended that each company develop its own HACCP system, tailored specifically to its product, processing and distribution conditions.
"Our committee, which consisted of 25 of the nation's leading experts on microbiology in meat and poultry, concluded that HACCP was the state-of-the-art, best scientific way to control food-borne disease," says Crawford, who is now director of the American Association of Veterinary Medical Colleges in Washington. "The second thing we did [in addition to developing HACCP principles] was to design a program [that would] introduce HACCP [to the meat and poultry industries] by 1993. As you know, that deadline has slipped."
Last August, USDA Secretary Mike Espy directed FSIS to pursue regulations mandating implementation of HACCP programs for the meat and poultry industries, which was widely supported by industry.
But the following month, Espy opted against pursuing normal rule-making procedures and announced plans to hold a HACCP roundtable conference. The conference was scheduled to take place March 30-31.
"Industry seems to be ready, but USDA doesn't," says Crawford in reference to HACCP. "We don't need meetings to discuss this subject; we've already done that during my term as FSIS administrator [1986-1991]. We had meetings around the country. We had workshops to develop model HACCP programs.
"Piece-mealing [strategies]-like Track I and Track II, the Pathogen Reduction Program and all those other things-that's like a house of cards. Those things will never come to fruition at the same time, so you'll be talking about improving meat and poultry inspection years from now. If you put [HACCP] in now, it would be over and done with."
Some meat industry leaders are unhappy with what they call unnecessary foot-dragging by USDA in HACCP implementation.
"AMI will not be held back on HACCP," Boyle points out. "We are proceeding with an aggressive HACCP training program in 1994-with or without government support."
AMI's goal is to have at least one HACCP expert in each meat and poultry plant by 2000.
Boyle, testifying before a Senate agricultural subcommittee in February, described steps taken by the meat industry during the past year to prevent food-borne illness, promote food safety research and education, and to reform meat inspection. He also emphasized the need to implement HACCP. And AMI has formally petitioned USDA to initiate a mandatory HACCP rule similar to the seafood safety rule proposed by FDA.
In the future, all segments of the meat chain will incorporate HACCP, Boyle predicted. He said that livestock and poultry farms of the future will use HACCP principles to design, monitor and adjust their animal husbandry practices; keep records on both the source and destination of their animals to facilitate trace-back programs; and conduct research to identify types of animals or farming practices that increase or decrease human health risks.
Immunological testing will be used to screen animals for pathogens or disease so when animals arrive at the packing plants it will be known which ones might need special treatment to prevent food-borne hazards.
Packing plants would be required to keep detailed records on the critical control points monitored under HACCP, as well as on the origin and destination of their products. And more detailed livestock records would facilitate animal traceback, and better product distribution records would facilitate product tracing or recalls.
All meat and poultry processors would also be required to have a product recall plan to make it easier to control exposure to products which might, despite all the hurdles, carry a human health hazard.
Boyle added that plants would be required to use certain technologies known to prevent, reduce or destroy human health hazards, and that industry and government would work together to identify and encourage development of those technologies.
The government's modernized meat and poultry inspection program, Boyle said, must follow National Academy of Science recommendations and be driven by science, not politics; be grounded in human health protection, not animal disease detection; and be modeled after HACCP.
He pointed out that government is already moving toward a HACCP-based inspection system. For example, HACCP-based requirements for producing cooked roast beef in the 1970s led to a dramatic drop in salmonella. FDA's low-acid canned food regulations and USDA's residue monitoring program are both HACCP-based rules designed to control safe processes.
Boyle said AMI advocates that all foodservice and retail establishments use HACCP to control the way they handle, process and prepare meat and poultry to help prevent public health problems.
Since the consumer is the last line of defense in the battle against food-borne illness, AMI advocates safe handling labels on packages of raw meat and poultry-and consumer education about food safety through the food and retail industries, government, public health community and the media. Educational outreach efforts would focus on consumers most at risk of developing food-borne illness, including children, the elderly and immunocompromised.
Meat chain HACCP
Spokesmen from producer organizations, including the National Cattlemen's Association and the National Pork Producers Council, point out that their members are already embracing and using HACCP, and some of their association programs also incorporate HACCP. For example, NCA's Beef Quality Assurance Program has been in effect since 1987.
"If you do a side-by-side comparison of the outline our task force developed [for the Beef Quality program] and the seven principles of HACCP, they are almost identical," says Gary Wilson, NCA director of animal health and research. "And we didn't even know we were doing HACCP back in 1987."
The Pork Quality Assurance Program, introduced by NPPC in 1989, is based on 10 critical control points for quality assured pork production.
"The HACCP approach should be the centerpiece of any program we design to take the U.S. meat inspection system into the 21st Century," according to a NPPC statement made last year addressing the proposed FSIS strategic plan and Pathogen Reduction Program.
The retail grocery segment of the meat chain is also involved in HACCP.
John Farquhar, vice president of science and technology for Food Marketing Institute, says, "We're currently working on a generic HACCP model for ground beef. We're planning to release this to the retail industry around [FMI] convention time in May. It will encompass the farm, packing, retail and the consumer."
Bill Brown, president of Gainesville, Fla.-based ABC Research is the consultant putting this model together for FMI.
"We're concentrating on temperature control throughout the entire retail area and employee handling of the product," he points out. "For example, we're telling [employees] not to handle raw and cooked products in the same area; how often cleanup and sanitizing should be done; and about building shelf life into the product."
Farquhar explains FMI has done a lot of work in the past on seafood and deli-which both now have extensive HACCP models for retailers.
"In the meat area, other than the [work we've done on] basic sanitation and handling of the product, this is our first new project we've done on meat in years," he adds.
Many foodservice operations are practicing HACCP-although some may be unaware they are doing so.
"Last year we did a HACCP pilot program with FDA and the Department of Commerce on seafood," says Bob Harrington, director of technical services for the National Restaurant Association. "Many people came thinking [HACCP] would require extra work for them. Most people found out they were already doing what HACCP requires them to do."
Although there isn't a formal foodservice HACCP program specifically for meat, many operations are creating their own. And a final cook temperature standard for ground meat (155 F center temperature for 15 seconds) is now in place.
Harrington feels there can be a "generic, fill-in-the-blanks" HACCP program for meat since operators could "just trade in one arbitrary set of checklists for another equally arbitrary set." Harrington says that the essence of HACCP has to be a risk analysis for individual processes at individual sites.
In addition to safer product, foodservice operators may discover side benefits from a meat-oriented HACCP program.
"People will rediscover some shrink controls," Harrington says. "They'll discover with tighter attention paid to cooking times and temperatures, they may find some better yields."
AAVMC's Crawford discusses the importance of HACCP in meat inspection.
"It is time to get [HACCP] into place," says Crawford. "FDA is putting it in place, and the [European Union] and other member countries of the United Nations will have put in HACCP by the end of 1994. If we don't, there [could] be a trade war because we won't be inspecting meat using modern standards.
"If we don't implement HACCP in 1994, we will again be out of step with the rest of the world," he adds. " At the turn of the century, [the U.S.] didn't have mandatory inspection and everybody else did. We now have mandatory inspection, but it's not based on modern science-it's based on 1906 science."
The 7 HACCP
Principles
1. Assess hazards and risks associated with growing, harvesting, raw materials and ingredients, processing, manufacturing, distribution, marketing, preparation and consumption of food.
2. Determine critical control points required to control the identified hazards.
3. Establish the critical limits that must be met at each identified critical control point.
4. Establish procedures to monitor critical control points.
5. Establish corrective action to be taken when there is a deviation identified by monitoring a critical control point.
6. Establish effective record-keeping systems that document a HACCP plan.
7. Establish procedures for verification that the HACCP system is working correctly.
Janet Riley