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 Kiran Kernellu

September 3, 2002

WHAT ODDS!

What are the odds of dying from food? The National Safety Council (NSC) did some research on the odds of dying. The most recent data, compiled from statistics from the National Center for Health Statistics and the U.S. Census Bureau, is from 1998. It gives us some perspective.

NSC reports 3 deaths from “foodstuffs and poisonous plants” in its 1998 report. Thus, NSC calculates odds of dying from consuming food and poisonous plants to be 1 in 90,082,667. Lifetime odds are 1 in 1,174,481. In most states, you have a better chance of winning the lottery than of dying from bad food. That’s a timely perspective in light of recent events.

According to the NSC’s website (http://www.nsc.org/), the information was “prepared in response to frequent inquiries, especially from the media, asking ‘What are the odds of being killed by lightning?’ or ‘What are the odds of dying in a plane crash?’” Answering those two questions, NSC provides specific data on 40 injuries all of which are greater than the risk of dying from foodstuffs and poisonous plants. NSC data is actual incidents compared to CDC’s estimates of food-borne illnesses and deaths.

The media was frenzied in its haste to crucify the meat industry during the recent ConAgra recall. The media left the public with the impression that E. coli is a rampant threat stemming from the meat industry. Few stories even mentioned that ConAgra recalled meat that had not tested positive for the pathogen. This is hardly the action of a company from an industry that shortcuts food safety.

ConAgra is a large company that produces millions of pounds of meat per day in an $80 billion industry. It makes for a perfect target for those that have a beef with meat. Odd that there wasn’t much ado a few days later when E. coli was found on lettuce. The media was still consumed with the meat industry that has scientists working continuously on improvements to food safety. Food safety is seldom covered in depth, except to discuss the meat industry and the USDA falling short.

The media fell short of being the true watchdog of the public in this instance. You can count on one hand the number of popular press stories that let consumers know that cooking meat to an internal temperature of 160° Fahrenheit kills any E. coli that might be in it. Those odds are 100% in your favor. A new report from the USDA’s Economic Research Service states that 80% of people said they cook their burgers to well done, up only 4% since 1991. The industry and the USDA have instituted numerous safety advances since then, but consumers’ personal responsibility hasn’t grown proportionately. It’s time for a new perspective in which consumers see themselves as working with the meat industry to further food safety.

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NMA WELCOMES NEW REGULATORY ANALYST

Roberto Escalante Jr. joined the NMA staff two months ago. He comes to NMA from the Clorox Service Company. He attended Cal Poly San Luis Obispo and received a B.A. in Plant Science. Most of his career has been in the fields of biology and chemistry, working with agriculture chemicals and consumer products. For the last four years he has worked in the regulatory field dealing with the EPA on product registration and other issues. Contact him at [email protected] with your technical questions!

OPINIONS WANTED!

The August 19, 2002 Lean Trimmings contained a short article about an agriculture questionnaire that Chairman Larry Combest of the House Agriculture Committee released with the hope that organizations and companies would respond to questions of packer ownership.  This questionnaire has been provided to NMA leaders and slaughter members but we hope other members will respond with their points of view in mind. Contact Government Relations Liaison Shawna Thomas by phone at (202) 518-6383 or e-mail at [email protected] to request a copy of the Chairman's letter and questionnaire.  The questionnaire can also be found on the web at http://agriculture.house.gov/press/pr020812.html.  As an industry, our responses are due to the House Agriculture Committee by September 20, but we hope to have developed a cohesive response that we can share with our members by September 15.  Please do not hesitate to call, fax, or e-mail any questions or comments to Shawna Thomas. 

UNUSUAL ALLIANCES

NCBA reported that Beefeater Gin helped sponsor a recent PETA kickoff party for a new vegetarian campaign targeting young men.  In an excerpt in PR Week Magazine, Beefeater VP of corporate communications Jack Shea said, “Frankly, the irony of a gin called Beefeater tying in with a vegetarian group was too good to pass up.”  Shea told the magazine that PETA’s demographics and image fit well with Beefeater, which is trying to reposition itself to a premium drink for the nightclub crowd.

NCBA is contacting Mr. Shea to express its disappointment in the company’s decision to support an animal rights activist group that helps sponsor animal rights terrorism activities.  Contact Beefeater for more information about their sponsorship of PETA’s campaign at [email protected]. 

PROFESSOR ROBERT VANCE (CORRECTION)

Dr. Vance began his career at California Polytechnic State University, San Luis Obispo on January 1, 1972, not 1979 as reported last week. Thanks to Bob Karmann who e-mailed us and said he took a class with Professor Vance in 1974.

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CORPORATE CAMPAIGNS

Among the more common acronyms like HACCP, SSOP, and IDV heard at this year's NMA Summer Board Meeting and Conference in Sedona, AZ, were a few others sprinkled in for flavor. Terms such as PAC's, NGO's and SDS filled Dr. Jarol Manheim's speech about "corporate campaigns" on Friday, August 16.

PAC’s, and NGO’s are often the source of corporate campaigns. A PAC is a political action committee. NGO's are non-governmental organizations. SDS stands for Students for a Democratic Society. Dr. Manheim, a professor of Political Communication and author of Death of a Thousand Cuts: Corporate Campaigns and the Attack on the Corporation, defines a corporate campaign as a coordinated, long term, wide-ranging attack on the reputation of a business or industry initiated by a union, organized labor, advocacy group and/or competitors, caused by a bad feeling over a certain issue. The corporate campaign dates back to the organization Students for a Democratic Society that became a spearhead of the 1960's anti-war movement. These anti-war tactics paired with labor union strategies from the 1970's morphed into what can now be called the corporate campaign. It is not just a public relations war, but also a political, psychological, economic and moral war that undermines company or industry ability. Dr. Manheim’s book specifically recounts the origins of the corporate campaign and details it with references. What he wants to make clear to those in the meat industry is that the actions of groups like People for the Ethical Treatment of Animals (PETA), the Sierra Club, and others, which discount and demonize the industry, are not coincidences. They are calculated plans to distract management and disrupt stakeholder relationships so that the target suffers.

For example, PETA's website takes the moral high ground when talking about animal cruelty by quoting a credible source saying, "House of Representatives Agriculture Committee member George E. Brown has written that to keep production lines moving, slaughterhouse employees often find themselves resorting to unbelievable brutality ... Slaughter workers admit to routinely strangling, beating, scalding, skinning and dismembering fully conscious animals." PETA’s moral high ground also allows them to sponsor events like a vegetarian hotdog cookout featuring the July 2002 Playboy Playmate. They were given political and media time when they held the event on the lawn of the Capitol on July 18.

But what does the meat industry, which is fraught with ugly pictures and a bad reputation, do about a corporate campaign? Dr. Manheim postulates that winning a corporate campaign war is improbable once a methodical campaign has begun against a particular industry, but it is possible to defend and survive. Survival takes research. The meat industry must take more than a cursory look at itself and find the vulnerabilities that a corporate campaign can seize upon. Meat packers and producers know that meat production is not a tasteful process. They also know that the words Salmonella and E. coli are always problematic to the public. The industry needs to find its own weak spots, as well as take a careful look at the wagers of the campaign. What are the corporate campaigners’ vulnerabilities? What do they really want out of their campaign? Who are the corporate campaigners’ allies? Who are their unlikely allies? How can the meat industry take their version of the world and make it understandable and favorable to the public? Who are the meat industry's allies? Dr. Manheim left those in the session with these questions that need answering if this industry is going to survive intact. Thanks to Shawna Thomas, NMA’s Washington-based Government Relations Liaison, and former student of Dr. Manheim, for her contribution to this story.

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PUBLIC MEETING: CONTROLLING Foreign MaterialS IN A HACCP ENVIRONMENT

The U.S. Department of Agriculture’s Food Safety and Inspection Service today announced that it will hold a one-and-a-half-day technical conference on September 24 and 25 in Omaha, NE to address and seek public comment on the control of foreign material contaminants in a HACCP environment.

FSIS will present its current thinking on controlling how it expects establishments to address foreign material contaminants in its hazard analysis. The Agency seeks information from academia, industry sources, and consumers on the best ways to identify such potential hazards and to provide a forum to address how best to control them.

The agenda will include discussions of the different types of foreign material contamination in a HACCP environment, the health and safety risks associated with foreign material and the current state of detection and removal of foreign material. Discussion panels of food safety experts will review the current state of foreign material contaminant detection, removal, and verification.

To submit comments or to receive copies of documents on the agenda, contact the FSIS Docket Room, Docket #02-033N, U.S. Department of Agriculture, Food Safety and Inspection Service, Room 102, Cotton Annex, 300 12^th Street, SW, Washington, D.C., 20250-3700.

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

Edited by Kiran Kernellu

September 3, 2002

COOL UPDATE

AMS hasn’t yet put forth draft voluntary guidelines for the country-of-origin labeling law in the 2002 Farm Bill. It has posted over 170 comment letters that can be accessed at http://www.ams.usda.gov/cool/comments.htm. NASDA News reported Agriculture Secretary Ann Veneman stated that the administration expressed “concerns about the potential costs and implementation difficulties of country-of-origin labeling, nonetheless, the provision was included in the final farm bill and it is now USDA’s job to administer the law.”

MEET DR. GARRY McKEE

Dr. Garry McKee takes up his responsibilities today as the Administrator of the Food Safety & Inspection Service in Washington, DC.  He follows a long line of individuals in this position that is of the greatest importance to the meat and poultry industry, and takes up his new responsibilities at a time of critical importance to all meat and poultry producers, packers, processors and consumers! 

Dr. McKee was Director of the Wyoming Department of Health and Cabinet Secretary, appointed by Wyoming Governor Jim Geringer, in February 1999. He previously served as Administrator of Wyoming's Public Health Laboratory.

Dr. McKee began his professional career in Oklahoma as a Medical Technologist and followed as a Public Health Laboratory Supervisor. In 1980, he was named Chief of the Public Health Laboratory in Oklahoma, and served for 18 years. 

He received his B.S. in Biology from Southwestern Oklahoma State University, his Master of Environmental Science, Master of Public Health and a Ph.D. in Microbiology from the University of Oklahoma at Norman, OK.

NMA looks forward to meeting with Dr. McKee at the earliest opportunity, and working with him proactively to work out the optimal ways in which its members can bring to market the safest possible meat and poultry products for American consumers. 

NMA COMMENTS

The following NMA comments on FSIS Draft Notice “FSIS Actions Concerning Suppliers that may be Associated with Escherichia coli (E. coli) O157:H7 Positive Raw Ground Beef Product” were sent to the Office Of Policy, Program Development And Evaluation in Washington, D.C.:

“As you may be aware, in 1998 NMA members recognized that raw ground beef and other raw ground products are not sterile due to the nature of the product and the lack of a “kill” step for biological hazards in the process. NMA members therefore conceived, participated in and developed GMPs and SOPs to improve process control for the manufacture of raw ground beef products in order to help grinders continue to produce the safest products possible by increasing total process control. These are posted on our website and were acknowledged by FSIS.

Currently NMA members in conjunction with the farm to table food safety continuum are in the process of developing guidelines for GMPs and SOPs for the Sanitary Dressing of Beef Carcasses. Therefore we applaud your effort to provide notification to raw ground beef manufacturers and suppliers of agency sampling collection activities and sample results in order to facilitate product trace back.

However, in accordance with the farm to table food safety approach, we respectfully submit that FSIS conduct testing earlier in the system in order to identify the source of pathogens. Moreover, the test result should be quantitative in order to address the strategic assignment of intervention strategies in the production process.

In addition we wish to recommend that communications between inspection personnel and the District Office addressing laboratory results be conducted not only with e-mails but augmented through verbal communication via the telephone. Furthermore we request that Part I. Section B. number 3. provide further clarification as to how the agency will identify the suppliers of raw materials and how the agency will define a “lot”.”

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RECENT FSIS NOTICES: Summaries by Olsson, Frank & Weeda

Final Notice on HACCP Verification Procedures and the 30-day Reassessment Letter: FSIS adopted its HACCP verification procedures virtually unchanged from those in the Draft Notice. In determining if a noncompliance record (NR) should be issued for a deviation of a critical limit or a HACCP noncompliance, inspection program personnel will ask four questions:

a) Has the establishment already identified the failure?

b) Has the establishment, when applicable, ensured product safety?

c) Has the establishment complied with 9 C.F.R. § 417.3 in the case of a deviation, or taken immediate and further planned actions in connection with a noncompliance?

d) Is the establishment having similar, repetitive problems, which demonstrate a trend?

If the answer is “no” to questions a, b, or c, or “yes” to question d, then a noncompliance exists and a NR should be written. If the answer is “yes” to questions a-c, and “no” to question d, then there is no noncompliance and an NR should not be written. Implicit in the Notice is that if an establishment documents that its preventive measure has been implemented and monitored, a trend should not exist.

Draft Notice on Actions Concerning Suppliers That May Be Associated with Escherichia coli O157:H7 Positive Raw Ground Beef Product: The Draft Notice describes the actions that FSIS will take when there is either a presumptive or confirmed E. coli O157:H7 positive on raw ground beef product sampled at a federally inspected establishment, retail facility, or import establishment.

The Draft Notice reconfirms that FSIS will continue to notify federally inspected establishments, retail facilities, and import establishments prior to collecting samples for E. coli O157:H7 testing. With respect to grinders and import establishments, program personnel would inform establishment management of the reason for taking the sample and provide the establishment enough time to hold the entire sampled lot. With respect to retail facilities, a Compliance Officer would notify management just prior to collecting the sample. In addition, the Compliance Officer would ask for the names and establishment numbers of the plants supplying the source materials for the lot of ground beef being sampled. The Compliance Officer would also record the supplier lot number, production date, and other identifying information.

Although the Draft Notice does not direct program personnel to ask grinders for supplier information at the time of sampling, the IIC would ask for such information if, after using LEARN to check for sample results, there is a presumptive positive. At that point, the IIC would to obtain the name, point of contact, and phone number for the establishment supplying the source materials for the lot of ground beef being sampled. In addition, the IIC would record the supplier lot number, production date, or other identifying information that would be useful to the supplier if it is later notified of an E. coli O157:H7 positive test result. This information would be kept on file in the inspection office with the other documentation relating to the sample.

If results from a grinder or retail facility later confirm positive, the District Office would then notify all of the supplying establishments in his/her own district, his/her counterparts in the appropriate Districts, and the Technical Service Center (TSC) contact person when necessary. Date and time of the verbal notification will be documented and sent along with supplier information to the Director of Recall Management, who in turn, will issue a written notification to each supplier.

At supplier establishments, the District Officer would also inform the Circuit Supervisor and the IIC of each establishment about the positive test result. This notification would include identifying information about the production lot that the establishment supplied. The Draft Notice clarifies that this notification would be to ensure that the establishment knows that it could be the source of the E. coli O157:H7—it is not a definitive determination that the supplier establishment is the actual source of the pathogen. The IICs at the supplying establishments would ensure that inspection program personnel perform a HACCP 02 procedure verifying that the supplying establishment met all regulatory requirements at all critical control points in the HACCP plan for the production lots involved.

With respect to import establishments, if there is a confirmed positive and the product is on hold (whether voluntary hold or FSIS hold), the IIC would refuse entry of the lot. If the lot has moved into commerce from the import establishment, the IIC would notify the designated District Office contact person about the country of origin, foreign country establishment number, health certificate number, shipping mark, and name and address of the consignee from the health certificate. The District Office contact person would then notify the Consignee or Importer of Record in his or her own District of the positive finding. If the Consignee or Importer of Record is located in other Districts, the District Office contact person would provide the information to his or her counterpart in the appropriate Districts. The time and date of the verbal notification should be documented and sent along with the supplier information to the Director of the Recall Management Division. The Recall Management Division would issue written notification to the Consignee or Importer of Record. The TSC would fax the information to the International Coordination Staff and Program Development who would in turn notify the foreign country of the positive sample and request that appropriate action be taken.