A Consensus, if not Complete Agreement
While their agendas and opinions might be different, all sides concur that HACCP is vital to ensure meat safety
by Ken Krizner, senior editor
It was lunch time on the first day of a two-day USDA roundtable on implementing Hazard Analysis and Critical Control Point programs in the nation's meat and poultry plants. Representatives from various consumer groups huddled to discuss strategy on how to blunt any potential attacks directed at them from industry representatives.
About an hour later, in a different room, some meat and poultry processors were developing their plan of attack against possible consumer group charges that profits were at the root of any endorsed change in the inspection system.
It's a crapshoot as to what will happen when groups with different agendas and different opinions on the same issue come face to face. Will their disagreements disintegrate into arguments about each other leaving the issues of the day unresolved? When these groups address each other through the media, arguments seem to happen.
But as was proven during the roundtable in Washington, groups differing in opinions can talk to each other instead of at each other, and they may even find they have more in common than they are willing to admit.
USDA selected 33 participants to discuss the development and implementation of HACCP. The participants included meat and poultry processors, scientists, academians, public health groups, federal and state meat inspectors, farmers, and consumer groups.
The roundtable divided into three small groups to discuss six issues: plan approval, training, phase-in, effectiveness, compliance and enforcement, and current procedures. Each group then reported its findings to the entire group.
The objectives were to identify issues of concern, explore areas of agreement and disagreement, and identify measures that will help in the implementation of HACCP.
USDA Assistant Secretary Patricia Jensen said that results from the roundtable will be used in drafting a HACCP regulation.
Among the points of agreement:
-- USDA should have access to records of companies' critical control points. However, there was not a consensus on public access to records.
-- HACCP will give meat and poultry processors increased responsibilities.
-- HACCP will shift inspectors' responsibilities from direct oversight on process to observing critical control points.
-- USDA should have strong enforcement capabilities to penalize processors that seriously and willfully violate the regulation.
Both sides debated enforcement that would include civil and criminal penalties, and whether processors with model HACCP programs should be rewarded with less inspections. There was no consensus on these issues.
Of course, there was no consensus on the issue of whistle-blowers. Industry representatives argued that while it is important that employees report any "unusual activity," there should be no such provision in a HACCP regulation.
Consumer groups disagreed. "There is no incentive for employees to speak out if they are not protected," said Thomas Devine, legal director of the Government Accountability Project.
Participants debated and argued over questions including who should decide if a plant's HACCP plan was adequate, and the amount of training needed.
"The need for training and education is not only for plant employees, but for inspectors," pointed out James Marsden, AMI vice president of scientific and technical affairs. "It must be consistent and uniform."
Michael Robach, director of quality assurance for Duluth, Minn.-based Wayne Farms Inc., argued that consumers need to be made aware that HACCP will not completely eliminate pathogens. "That needs to be clearly understood," he pointed out, adding that consumers should not be given a false sense of security.
Devine agreed, but added, "We do expect that we are going to be the best we can be."
As for training personnel in HACCP, all agreed the expertise exists, but it is limited. There was also a consensus about the need to standardize training and certification.
The roundtable endorsed the idea of a trade-group consortium to develop a uniform initiative that would prevent inconsistencies. HACCP plants would be developed and approved by individuals who has successfully completed a standardized HACCP course.
"FSIS must have the final OK for any plan to train HACCP workers," stressed Pamela V. Fernandez of the American Public Health Association. "Otherwise, there will be no consumer confidence."
Among the agreements on training were that universities must have courses on food safety that include HACCP, at least one employee at each plant must have full training in HACCP principles and top management must be involved.
USDA's role
But there was not concurrence among the groups about what USDA's role will be in approving HACCP plans. But most agreed that inspectors in charge at the individual plants-not officials in Washington-should have the final OK.
With the exception of one consumer group representative, every member of the roundtable agreed that HACCP implementation was a three-to-five year project. The overriding argument: "The entire industry cannot be jump-started into HACCP at the same time."
"It's reality that you are going to need time to implement HACCP," pointed out Arthur Hughes of the National Joint Council of Food Inspection Locals.
The lone dissenter to the three-to-five year implementation period was Gerald F. Kuester of Safe Tables Our Priority, a national organization consisting of E. coli victims' parents, relatives and friends. The group, which has met with USDA Secretary Mike Espy, is actively lobbying for changes in meat inspection.
"It should be one year," Kuester said. "We cannot afford to wait any longer."
Most everyone agreed one year is unrealistic, and most everyone warned that creating unrealistic expectations about HACCP would do more harm than good.
"We can't oversell HACCP. If we do, we hurt ourselves," noted Richard H. Forsythe of the University of Arkansas.
Perhaps Dane Bernard of the National Food Processors Association spoke for the entire group when he said, "There is still a great deal to be learned by both industry and government."
For USDA, it is now time to write a proposed rule. Jensen said she wants the agency to move expeditiously but would not give a date for unveiling the proposed rule.
In an interview with Meat Marketing & Technology, acting FSIS Administrator Terry L. Medley gave a time frame that indicates a proposed rule could be ready for comment by December, although he admitted it could be written sooner.
A source in USDA said Espy wants a proposed rule by September.
As for implementation, Medley said the regulation-and the comments that follow it-will dictate a time frame. But he added that three to five years is normal for implementation of a substantial regulation.
"We have not identified a specific phase-in period," he stressed. "If we have a proposal that only needs slight modifications before being approved, then we can concentrate on a specific phase-in period.
"If we have to repropose the rule based on the comments we receive, then the implementation period is up in the air," he cautioned.
Medley noted that any discussion as to what a company's responsibilities and what FSIS' responsibilities will be because of HACCP would be speculative prior to rule-making.
But he dismissed the notion that HACCP means the industry will police itself.
"Clearly, there will be a major role for companies in implementing and running HACCP programs," he said. "But there will be a critical role for FSIS. We will monitor and evaluate those plants on a continuous basis. The regulation will determine the appropriate roles for the industry and FSIS."
And although HACCP will likely be "mandatory," Medley said the program will be flexible. "These regulations would set the standard that plants would have to meet," he pointed out. "But they would not prescribe how a plant develops those plans. That will be based on whether it is processing or slaughter, whether it is meat or poultry, or whether it is a large or small operation. We will set the minimum standards, and there will be flexibility to determine the best HACCP plan for each individual plant."