HOW THE Salmonella STANDARD HURT HACCP
OAKLAND, CA – NMA participated in litigation against FSIS's Salmonella Standard as an amicus curiae* because the flawed enforcement standard had undercut HACCP-based inspection and compromised food safety.
The Texas litigation involves USDA’s failure to follow basic HACCP** principles in its food safety program for meat and poultry. Implicit in the term HACCP is the concept that food hazards *** will be minimized or eliminated at Critical Control Points. In applying Salmonella performance standards in ground beef processing plants, USDA has concentrated its compliance at points where, by the department’s own admission, "Establishments producing raw ground product from raw meat or poultry supplied by other establishments cannot use technologies for reducing pathogens that are designed for use on the surface of whole carcasses at the time of slaughter" (Pathogen Reduction; Hazard Analysis and Critical Control Point (HACCP) Systems; Final Rule, Federal Register, July 26, 1996 P.39946). Thus, USDA’s Salmonella performance standards have been attempting to measure performance in reducing Salmonella where there are no known mechanisms to reduce it. This is unfair to the processor and a disservice to consumers. Food safety will be better served by enforcing Salmonella performance standards at a point where there are mechanisms to control it so that real reduction can be measured.
USDA’s enforcement of its Salmonella performance standards at beef grinding plants is further complicated because of the way in which meat moves through the distribution system. In enforcing Salmonella performance standards, USDA should focus its testing at the point, after meat carcasses have been dressed and cleaned, to reconfirm that the treatment systems**** in place in slaughter plants are effectively reducing surface levels of Salmonella.
National Meat Association is a non-profit trade association representing meat packers and processors, as well as equipment manufacturers and suppliers who provide services to the meat industry. The association, with over 600 members throughout the United States, includes membership in Canada, Australia and Mexico.
* American Association of Meat Processors; North American Meat Processors; Southeastern Meat Association; Southwest Meat Association.
** The acronym HACCP stands for Hazard Analysis Critical Control Point.
*** Hazards of biological, chemical and sources reasonably likely to occur.
**** Pre-evisceration washing, finishing hot water and steam pasteurization, steam vacuum and acid washes.