NATIONAL MEAT ASSOCIATION h 1970 Broadway, Suite 825, Oakland, CA 94612

(510) 763-1533 Fax (510) 763-6186 h Email Address: [email protected] h http://www.nmaonline.org

Edited by Jeremy Russell and Kiran Kernellu

July 22, 2002

TOTAL RECALL

On July 19, NMA Member ConAgra made the decision to greatly expand a June 30 recall of 354,200 pounds of beef trimmings produced by its Greeley, Colorado plant. The recall, based on tests linking a strain of E. coli O157:H7 from an outbreak which sickened 18 people in Colorado to E. coli O157:H7 found in ConAgra ground beef, is being extended to encompass untested ground beef and trim produced on any day when ConAgra had a positive test for O157 between the dates of April 12 and July 11, 2002. With such a swath, USDA estimates that ConAgra is voluntarily recalling 18.6 million pounds of ground beef. This is the second largest recall in history, the first being Hudson Foods’ recall of 35 million pounds of ground beef in 1997. Like ConAgra, Hudson voluntarily recalled its products due to illness.

What is unusual about the ConAgra recall is not only its size, but way in which that size of recall was derived. Hudson was forced to expand its recall due to the practice of ‘reworking’ excess product into the next day’s production. Reworking made it difficult to prove that potential contamination had not been shared from day to day. The recall ended the practice as effectively as it ended the company’s existence.

ConAgra was testing product for E. coli O157:H7 at the request of customers. Lots that sampled positive were diverted. In going back and recalling all of the untested lots from a day on which a positive was found, USDA is changing what the tests represent. According to the revision, a positive test represents not only the lot from which it came but the entire day on which it was produced. It remains to be seen whether USDA will apply this new standard in future recalls.

In the film Total Recall, Arnold Schwarzenegger’s character discovers that he has been implanted with false memories. Is he who he thinks he is or is he someone else? How would he know? In this massive product recall microbial tests seem to be undergoing a similar crisis of identity. We already know that tests are merely representative of a larger body of product – the way one respondent represents thousands in a poll. If in retrospect tests can be made to represent something different than they were meant to represent, then it throws the entire scheme into chaos. Already aware that it is an inexact science at best, those doing the testing may wonder, am I who I think I am? How do I know?

ANOTHER RECALL

Last week, in another recall, NMA protested to USDA that it was misleading and frightening consumers by requiring the recall of 7,500 pounds of product from the market when the company already had recovered or had under its control about 7,300 pounds of the product in question. In our view, a recall of about 200 pounds might have been warranted, although the reason the company had not got the full amount back was because it had been consumed in the foodservice industry.

We were told that this was a valid question to bring to a public meeting to be held later this year, and that the agency could not change its long-standing policies in the middle of a recall.

CA RANCHER RECEIVES TOP AWARD

Third-generation California rancher and conservation leader Al Poncia received USDA’s first national Excellence in Conservation Award. Poncia was presented the award by the Natural Resources Conservation Service (NRCS) for his efforts “to maintain and improve the natural resources on America’s private rangelands,” according to Meatingplace.com. His century-old, 700-acre ranch of sheep, cows and calves in Marin County features an integrated pastureland system to protect streams and riparian areas with culvert crossings and moveable electric fences. Meatingplace.com further reported that Poncia has planted indigenous plant species on his stream banks, carefully monitoring grazing to safeguard against overuse and protect the productivity of these areas. Poncia extends his conservation efforts by conducting workshops on his ranch in partnership with the University of California Extension Service and the Marin County Resource Conservation District. Veneman called Poncia “an outstanding example of an agricultural producer who is committed to preserving the resources on his land and sharing his passion with other ranchers.”

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TRANS FATTY ACIDS BETTER IN BEEF!

The bad news is there are trans fatty acids in beef. The good news is that the trans fatty acids in beef have “positive effects on blood lipids and anti-cancer properties.” According to NCBA Executive Director of Nutrition Mary K. Young, “the trans fatty acids in beef are primarily conjugated linoleic acids (CLA) – which act differently than man-made [fatty acids].” A recent National Academy of Sciences (NAS), Institute of Medicine (IOM) report entitled Letter Report on Dietary Reference Intakes for Trans Fatty Acids, stated that “small amounts of trans fatty acids and CLA are present in all diets. They can serve as a source of fuel energy for the body. However, there are no known requirements for trans fatty acids and CLA for specific body functions.” The report concluded that there is no safe level of trans fat for consumption. In fact, the Institute urged people to reduce trans fat in their diet as much as possible.

As reported in last week’s edition of Herd on the Hill, trans fat is directly associated with poor LDL cholesterol and heart disease, which may explain why the Institute has not stated an upper limit for trans fat in the diet. According to The New York Times, the upper limit is what FDA uses to establish the daily value for any part of the diet. Thus, FDA has no recommended daily value for trans fat to put on product labels. Yet the Institute recognized that since trans fat occurs in meat, dairy products and pastries, in addition to many other foods, eliminating it altogether would mean such extraordinary changes in diet that many might not get enough proteins or nutrients.

The NAS/IOM report relayed that dairy fat and meats contain trans fatty acids. It also stated that “foods containing hydrogenated oils tend to have a higher trans fatty acid content than those that do not contain hydrogenated oils.” According to Young, “many people [don’t] realize that trans fatty acids are best known for being in hydrogenated fat, which is artificially created and used in fried and baked foods like crackers, cookies and potato chips.” Beef, however, contains primarily CLA trans fatty acids, which differ from trans fatty acids in hydrogenated fats and oils. The NAS/IOM report cited limited evidence suggesting that CLA “is active in inhibiting carcinogenesis. Similarly, there are limited to data to show that [CLA] inhibit atherogenesis,” the process causing the degeneration of arterial walls. These fatty acid features are important in weighing the helpful character of beef in healthy diets.

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NEW FOOD SAFETY SYSTEMS

According to a report last week in FSNet, Texas A&M’s Rosenthal Meat Science and Technology Center is testing a new food processing safety system it began developing four years ago called SENTRY9000, which both the Texas Agricultural Experiment Station and FoodHorizon have agreed to experiment. The system monitors various food safety programs for food processing plants using hardware and software applications. In addition to providing production data, which can support critical decisions based on real-time production line events, the system relates how much product is in inventory, undergoing packaging, being transported, and stored in coolers, ovens and preparation rooms. The system can also increase quality control. If incoming data violate critical limits, system warnings such as on-screen alerts, telephone messages, paging systems, or any combination of these will notify personnel, even if they are remotely located, using Internet or intra-net-based technologies to allow offsite inspections. Production data can then be viewed as it’s collected on any production line, allowing for an unprecedented benefit to consumers for food safety. Jose Quintana, chief technology officer for FoodHorizon, said, “[the] system monitors, 24 hours a day, the critical processes in a factory such as temperature control. The plant can take immediate action if there is a problem.” SENTRY9000 has the potential to aid all food processing plants in automating food monitoring and increasing quality control. “The benefit to consumers is unprecedented,” Quintana stated. “SENTRY9000 reduces the risk of food safety problems. There is an overall increase in the quality of security.”

Increasing food safety may also be improved by a new system Farmland National Beef recently introduced. Farmland’s BioLogic system, developed two years ago in conjunction with Kansas State University and Food Labs Inc., consists of two interlocking components – the Zone System and the Test, Track, Treat System. According to Meatingplace.com, the Zone System divides production plants into five functional zones identified and divided by their potential for microbial contamination during processing procedures. The Test, Track, Treat System follows each of the five zones, a continuously repeating process essential to the ongoing safety of each zone and product. The new food safety system, proprietary to Farmland, is currently being used in its facilities to prevent microbial contamination across all processing operations. Farmland president Tim Klein said that “[it has] invested a significant amount of money and resources in developing this system, and … plan[s] to continue this commitment to maintain [its] position as a leader in food safety innovations.” Farmland currently has no plans to market its system, which is still undergoing continuous testing and evaluation, though it could be used in nearly all processing plants. Brenden McCullough, director of technical services for Farmland, said that “[they] are never content with where [they] are today because [they] know there are even better systems and new innovations that can be developed tomorrow to further protect consumers.”

HACCP A HIT…

According to a recent New York Times letter to the editor written by USDA Under Secretary for Food Safety Elsa Murano, the Centers for Disease Control and Prevention credits HACCP with a 23% reduction in instances of food-borne illness in the United States.

Murano wrote, “we [the USDA] can and will do better.” FSIS’ highest priority is protecting public health through a rigorous system of meat and poultry inspection. USDA inspectors are present in every plant, every day. She also stated that in her time in office she has instituted a number of food safety improvements including better training for plant inspectors, scientifically trained inspectors known as consumer safety officers, and computer systems to ensure accountability.

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NATIONAL MEAT ASSOCIATION

NMA - East: 1400 - 16th St. N.W., Suite 400, Washington D.C. 20036 Ph. (202) 667-2108

NMA - West: 1970 Broadway, Suite 825, Oakland, CA 94612 Ph. (510) 763-1533 Fax (510) 763-6186

THE POLICY FALL OUT FROM THE CONAGRA RECALL

Last week, USDA used its powerful persuasion to get ConAgra to expand its voluntary recall from one day’s production (May 31) to product produced and not tested on days between April 12 and July 11 when the company had found a positive on combos of trimmings that it had tested but had diverted from fresh distribution channels. This took the quantity of the recall to nearly 20 million pounds, and merited a press conference by the Secretary of Agriculture on Friday morning.

From a microbiological testing perspective, a single 375-gram sample of 4,540,000 grams (10,000 pounds ) of product has no statistical validity. The fact that 75 grams is taken from each of five combos to make a composite 375-gram sample does not make it statistically sound. The real fact is that because of the nature of trimmings, it would take several hundred samples from any one 2000# combo to achieve a statistical confidence level.

Certainly, once ConAgra had agreed to expand the recall, that information was released promptly. With full cooperation by the company, a very complex series of events was set in motion. That included a press release by USDA detailing the many products. This is covered in a news item on page one of this week’s Lean Trimmings.

This recall has raised policy questions that need to be addressed. They include:

· The 1994 recognition of E. coli O157:H7 as an adulterant applied to ground beef since there was a likelihood that consumers might prepare it without the thorough cooking that destroys the microorganism. Is the finding of it in trimmings an expansion of the adulteration finding?

· Is a recall of beef trimmings that have not been tested warranted? The quantity of this untested product is huge, and has trickled through the industry levels in many different distribution channels. No illnesses have been reported on product coming from other than the May 31 production which was the date implicated in the first recall.

· Is USDA, which has never recognized other than official government laboratory testing to determine E. coli O157:H7 an adulterant within the meaning of the FMIA, now accepting third party laboratory testing?

· Fresh chilled beef has a finite shelf life. Is it realistic to recall product that is long past its fresh shelf life?

· Finally, the biggest question of all is the intent of regulatory authority, where there is no absolute kill step as in refrigerated or frozen uncooked meat, and the final elimination step of the HACCP system occurs in food preparation outside an official establishment.

Many NMA members and indeed industry members are confused as to their responsibilities at this time. NMA is working diligently to resolve the outstanding questions. Stay tuned.

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NTF SEEK PRESIDENT

National Turkey Federation President Stuart E. Proctor, Jr. announced his departure effective September 1. Proctor will go on to the CEO position at U.S.A. Rice Federation after a nearly 14-year stint at NTF during which he became “a national leader in developing and influencing legislative and regulatory policy and helping the NTF members play a powerful role in shaping policy for turkey industry.” NTF further commended Stuart, as Chairman Ron Prestage stated “[his] leadership transformed NTF into the successful organization it is today.” NTF has formed a search committee to discover a “talented and versatile” CEO “who can continue to position the turkey industry in government affairs and [develop] marketing programs to increase turkey consumption.”

USDA OFFERS VOLUNTARY EQUIPMENT INSPECTION AND CERTIFICATION

AMS is offering a new voluntary program to inspect and certify the sanitary design of equipment and utensils used to process red meat and poultry products. The Dairy Grading branch in Washington, D.C. proffers the user-funded program to provide a third-party assurance that equipment and utensils meet minimum requirements for cleanability, suitability of materials used in construction, durability and inspectability. AMS’ equipment review specialists inspect and certify equipment and utensils to adhere to a new American National Standard, a consensus paradigm promoting sanitary design and ease of disassembly for cleaning and inspection, differentiated from the sanitation performance standards in 9 CFR 416.3 that USDA will continue to require the industry to meet. The service, international in scope, can be performed in the machine fabricator’s facility as well as in Washington, D.C. For more information visit http://wwwfsis.usda.gov/OPPDE/rdad/FSISNotices/25-02.htm.

FSIS DETAILS EMERGENCY RESPONSE TEAM

FSIS employees have been notified about the Agency’s Emergency Response Team (ERT), which will respond to emergency health threats involving biological, chemical, radiological or physical agents from a deliberate act that adulterates an FSIS-regulated food product or a foodborne outbreak. Physical agents are identified as any material causing adverse effects if eaten and result in a human health hazard, including but not limited to glass fragments, metal filings, bone slivers, radioactive isotopes, chemical warfare agent, toxic chemical, bacteria, toxin, virus, parasite, or other infectious agent. ERT will assess the nature, extent and severity of the deliberate health threat and react accordingly. For more information visit http://wwwfsis.usda.gov/OPPDE/rdad/FSISNotices/27-02.htm.

MICROBIAL PATHOGEN COMPUTER MODELING IN HACCP PLANS DRAFT

The notice describes the Microbial Pathogen computer Modeling (MPCM) programs and appropriate verification activities when an establishment uses the programs in validating and maintaining its HACCP plans. The MPCM program is software that estimates the growth or decline of foodborne microbes in food samples in production based upon the factors of growth, lethality and survival in culture broth and food products. While MPCM isn’t a panacea, it can be a valuable tool to support hazard analyses, develop critical limits, evaluate the relative severity of problems caused by process deviations and help predict the expected effectiveness of corrective actions. Written comments are currently being accepted. For more information on this notice visit http://www/fsis.usda.gov/OPPDE/rdad/DraftIssuances/PathModel.pdf.

FOREIGN AG SERVICE APPOINTEES

USDA Secretary Ann Veneman has appointed Kenneth J. Roberts as associate administrator and W. Kirk Miller as general sales manager of the USDA’s Foreign Agricultural Service. Roberts is a career FAS foreign service officer, currently serving as minister-counselor for agricultural affairs at the U.S. Mission to the World Trade Organization. Miller was director of international programs and regulatory affairs at the North American Export Grain Association. Veneman intimated her pleasure to add “these very qualified individuals to [the] FAS management team,” and added that “[FAS] will rely on their expertise as [they] pursue ongoing trade negotiations and implement a new farm bill.