30TH ANNUAL NATIONAL DELI SEMINAR
NATIONAL MEAT ASSOCIATION
SATURDAY, SEPTEMBER 26, 1998
Itís a great pleasure to be here this morning in beautiful Palm Springs. I commend your site selection, most especially the Rancho Las Palmas, a truly lovely resort. I rather suspect that the golf course had something to do with it!
Last time I visited with the Council, I had taken Bud Moorman to task for some position with which we disagreed. Iím glad that the disagreement is behind us! Weíve become good corresponding friends ever since, and in fact weíve been able to collaborate on issues of common interest.
The issue in question, in 1993, just happened to be one about fundamental food safety and it was related to the "turning point" event in the State of Washington, when four children died, and hundreds of people became ill, all attributed to the consumption of undercooked hamburger at Jack-In-The-Box restaurants. By May of that year, when I came to speak with your organization, the meat industry was struggling to find solutions to the problem; weíre still looking, even today, and Iíd like to share with you some of the good opportunities that weíre uncovering.
Hamburgers are not particularly good deli items, but they are a very popular food with Americans. The problem with the deadly microorganism, E. coli O157:H7, is that it is a really good survivor because the deadly strain of this very common microorganism that lives in your gut and mine, and does useful work in breaking down our food into usable constituents for our body, has what microbiologists call an "adherence" factor, i.e. it sticks to surface tissues like glue. It doesnít dislodge with regular washing, which is what makes it so dangerous in fruits and vegetables because it wonít wash off with cold water. We know of only two ways to "kill" it: by heating to 160 degrees Fahrenheit, or by irradiation. For beef, irradiation is not yet approved by USDA, so destroying by heat is our only option. I donít know many people who like cooked lettuce, strawberries, and bean sprouts, so those industries have a different problem. This is a related problem for delis.
Despite what you may hear in the media, the beef industry has worked very hard to identify and implement intervention technologies to destroy the microorganism that we canít see on the surface of the meat after it has been slaughtered but which may have stuck to it. We had to overcome traditional objections of both government regulators and the meat inspectors who have traditionally stood on the line to make visual findings and who are not enthusiastic or trained to understand and accept scientific rationales. Several technologies have been implemented, the first being a steam vacuum, something like the hand-held vacuum youíd clean the car with but it pours out steam over the surface of the hanging carcass at the most vulnerable places where there might have been adherence. If the steam vacuum lingers a moment too long on the fat surface, you get a scorch mark just like you do on a white shirt! The downside of steam vacuums is that they could possibly act like a transfer agent, so their use has to be carefully monitored. The next intervention was the use of lactic or inorganic acids in water as a rinsing agent. They create an inhospitable environment for the survival of this microorganism. We then learned that if they are used after a very hot water wash, it increases the inhospitable environment exponentially! Thus, the use of combined hot water pasteurization or steam pasteurization followed by lactic acid in many of the larger plants which account for the largest percentage of commercially slaughtered beef is now quite widespread. We believe that the successful use of interventions has reduced the potential for survival of E. coli O157:H7 substantially. None of the systems is absolute. Cooking to 160 degrees Fahrenheit is the only sure kill step.
Researchers are looking at a variety of new possibilities, including what is called competitive exclusion -- that is finding something that overcomes the undesirable microorganism. This is what is used to assure that the deadly Staphyloccoccus aureus is destroyed in the production of dry fermented sausages. The competitor is lactic acid cultures that create such an inhospitable environment that the staph dies off. This is measured by controlling the fermentation process. Early sausagemakers did this by instinct; todayís commercial food manufacturers understand the science, and use it in making all kinds of fermented foods, including cheeses and other dairy products as well as fermented sausage. Once again, there is the challenge to make any such applications universal throughout the food system. The most recent suggestion is to change the environment in the animalís intestine before slaughter by changing its diet from corn to hay for a few days. This research is in the very early stages, but the principle is interesting.
The other major paradigm shift since 1983 has been the development of an inspection systems change, from the traditional hands-on inspection of every plant, every day, by USDA inspectors with supreme authority to mandate everything from what equipment is used, prior approval of labels and facilities, to hours of operation, and the organoleptic examination and re-examination of meat time and time again throughout the system, to HACCP. Mammoth regulations were proposed and debated in 1995, and resulted in final regulations in the summer of 1996. They implemented several requirements. Weíre lucky that we didnít get everything that our tax-supported government regulators had in mind for us!
The first requirement was Sanitation Standard Operating Procedures. In traditional inspection, the meat inspector, often on a random basis but at least a couple of times a week, would walk through the plant before start-up and before the equipment was assembled, to conduct pre-op sanitation. Sanitation SOPs require the company to take on the responsibility for the condition of the plant to manufacture food, and to have the records to demonstrate. Inspectors will still check on a random basis, but a finding by an inspector of something that the company has not identified or found is a more serious issue and can have much more serious consequences. All plants under federal inspection were required to implement Sanitation SOPs in January 1997.
In January 1998, the largest plants in the industry, about 300 meat and poultry firms with 500 or more employees at the location, were required to implement HACCP: Hazard Analysis Critical Control Points. HACCP is a food safety system based on prevention and was designed by The Pillsbury Company when it was asked by NASA to prepare food to accompany the first astronauts into space. It was really important that they not be sickened by the food they ate so many miles from home! A hazard analysis is made to determine what microbiological, chemical and physical hazards may exist in the production process, then criticial control points to measure that the system works. Documentation to support monitoring of the critical control points, and to show corrective action, is essential. For instance, a metal detection system to ensure that there are no metal constituents (buckshot, staples, etc.) in sausage would be a CCP. Cooking temperatures, sufficient to kill microorganisms in cooked meats, would be another CCP. If a system fails, then the corrective action must demonstrate sufficiency for the circumstances. And the final step is records review BEFORE the product leaves the control of the manufacturer, to make sure that all parameters are met. The medium-sized firms in the industry come under mandatory HACCP in January 1999, and the very small (less than 10 employees or no more than $2.5 million in annual sales) come under mandatory HACCP in January 2000.
Two other elements of the paradigm shift regulation are: Salmonella testing by the USDA on all species. In a series of tests, a very limited number of qualitative positives are permitted; and Generic E. coli testing by the industry, taking three sponge samples and compositing them for results. Again, there are qualititive findings that firms must meet.
I would strongly encourage you to become familiar with HACCP. The sooner that delis in stores learn and understand the seven principles, and begin to apply them, even in an adjusted form to fit the working constraints, the better. I have brought with me an introduction to the subject, which we published in our Heads Up For HACCP publication. It was prepared by Dr. Kerri Harris of the International HACCP Alliance. Your organization can become a member of the Alliance, and can benefit from its information. Major organizations, such as Food Marketing Institute and the National Restaurant Assn. Foundation are active and participating members.
Food safety is of paramount importance. Whether it is the consortium of organizations participating in the Fight Bac campaign to inform and educate consumers about how to make food safe, both away from home or at home, or the handling of deli items that are manufactured under hospital-like conditions in manufacturing facilities, itís the popular crusade for theYear 2000. Another story that we could talk about is the gross exaggeration by federal officials of the numbers of people that get sick, or even die, annually from foodborne problems. We at National Meat Association questioned the data that figuratively carried the new meat and poultry inspection revisions, but the power of the entrenched bureaucracy, supported by consumer activists, ignored the evidence. We understand that the authorities, with better data, are talking of revising the estimates that were so inflated. Itís hard to find the 9,000 corpses that die annually from foodborne illness! Weíre looking forward to the issuance of revisions!
There is one last microorganism that it is important for me to talk to you about. It is important to many in the food industry, and has been responsible for some of the largest recalls and some of the most deadly consequences. It is Listeria monocytogenes, which causes circling disease and spontaneous abortion in livestock, and was the cause of the Mexican soft cheese problem in Los Angeles in 1985 when there were a quite large number of illnesses of pregnant women who then lost the baby. Itís different from many of the other pathogens. Sometimes, it seems as though it can swim and fly! It lives cheerfully in drains and around dripping faucets. Be careful of overhead refrigeration units, hard to reach mechanisms in equipment where it can hide. It survives well in cold, moist environments like refrigerated cases. Deli counters sound to me like an ideal location. Environmental swab samples of likely locations would be a good idea. Positive findings of such sampling is a good warning sign for thorough clean-ups but does not incite regulatory action. And remember, after thorough washing, bactericidal rinses with food grade sanitizers are important. In meat plants, employees in RTE designated areas wear special gowns that do not leave the packing room. After they enter, walking through a foot bath with sanitizers, they put on the gowns and then wash hands before putting on clean plastic gloves. The handling of RTE at deli counters needs to simulate as much as possible the careful handling of products that can and will be eaten without any further cooking.
Earlier this week, I talked with one of the Directors of NMA in Los Angeles. He is a major manufacturer of cooked sausage products. He reminded me that the good old American Hot Dog was the first Fast Food! We talked about the diminishing size of the self-service wall delis, and the increasing size of the service delis. I would suggest to you that the service delis will continue to be popular and to grow because the displays are appetizing and inviting. Establishing and maintaining extraordinarily high standards for the product handling is essential; it all starts with good employee training; the way these employees handle product under the eyes of consumers is critical; the service deli counter is very vulnerable. It takes heroic efforts to pull out of bad experiences; it can be done, but itís tough! If I owned the real estate, I would have both the wall and the service deli -- a kind of insurance contract, if you will!
And those of you who are manufacturers of product need to remember that you are simply renting space in the counter of the store to merchandise your products, be they on the wall or in the counter. Thatís what slotting fees are -- simply renting space to show your products to the people that want to buy them. I will be watching a lawsuit filed by an energetic lawyer in Los Angeles on behalf of a consumer against Sara Leeís International Baking Company claiming that the consumer is denied the right of choice because small firms canít afford slotting fees. It sounds like a pre-cursor for a class action law suit, but it is a novel approach and one we should all watch. I have no love affair with slotting fees, or with reclamation centers for that matter, but I think theyíre here to stay for awhile, and Iím appreciative of the member who suggested to me that I think of them as renting space.
I hope that I have met the challenge of your theme here today: Learning from the past .... Preparing for the future. Iíd be glad to try to respond to any questions you may have, and I thank you for your attentiveness.