AMI Outlines Actions USDA Should Take to Address STECS in Beef

Thursday, August 19, 2010

(American Meat Institute)

Substantial progress has been made in improving the safety of the nation’s meat and poultry supply, but designating non-O157:H7 shiga-toxin producing Escherichia coli (STEC) as adulterants will result in a regulatory program that will do more harm than good, AMI said in a letter today to USDA Secretary Tom Vilsack.  AMI said that non-O157:H7 STECs in beef products may be a reason for potential public health concern, but it is not a public health emergency.  AMI recommended eight specific and comprehensive actions USDA should take to combat STECs in the beef supply. 

1.  Focus on Prevention:  Any new regulatory programs that USDA contemplates should be addressed within the framework of the existing Hazard Analysis Critical Control Point regulation.  USDA should commission a group of qualified experts to review the current science related to the development of a comprehensive farm-to-table preventative strategy for non-O157:H7 STECs in beef products and report their finding to USDA and other stakeholders.

2.  Conduct a Comprehensive Public Health Risk Assessment: Conducting a public risk assessment that is subjected to public review before regulators embark on any regulatory program to control non-O157:H7 STECs in raw beef products will provide a better understanding of the public health issues association with non-O157:H7 STECs.  For example, why have no confirmed outbreaks associated with beef products occurred in the U.S.?  Why have non-O157:H7 STEC outbreaks occurred in other foods, but not in beef products?  Why have non-O157:H7 STEC outbreaks associated with beef products occurred in other countries, but not in the U.S.? 

3.  Validate Analytical Laboratory Test Methods:  USDA should openly share with the meat and poultry industry, testing laboratories and test kit manufacturers the sampling and analytical methods that the agency will use to implement any regulatory program and ensure that the analytical methods are peer-reviewed before any regulatory program is initiated.  An accurate, validated rapid analytical test must be available to the industry to effectively implement any regulatory program that would make it illegal to enter product containing non-O157:H7 STECs into commerce.

4.  Conduct a Baseline Survey of Non-O157:H7 STECs on Beef Products:  It is imperative that FSIS conduct a baseline survey of beef products to include beef carcasses, ground beef and the raw materials used to manufacture ground beef in order to assess the impact of any new regulatory program that the agency may be contemplating.  The baseline survey design and sampling and analytical methods should be published for public comment to solicit the advice and counsel of scientific and technical experts before proceeding with any such survey.   A very limited amount of research has been conducted to assess the prevalence of non-O157:H7 STECs on beef products.

5.  Measure Progress Based on the Public Health Outcome:  If FSIS decides to further regulate non-O157:H7 STECs, it is prudent to evaluate the success or failure of any such initiative by actual illness reductions.  In the case of beef, however, this is nearly impossible given that no non-O157:H7 STECs illness outbreaks have been confirmed in the U.S.  This lack of documented outbreaks associated with beef products is remarkable given that approximately 95 percent of the public health laboratories reported in a recent survey that they are screening for non-O157:H7 STECs.  If regulatory efforts to reduce non-O157:H7 STECs in beef products cannot generate measurable, positive public health outcomes, the underlying point of the exercise must be drawn into serious question.

 

6.  Expedite Approval of New Microbial Interventions: USDA should convene a joint task force of all federal agencies that are involved in the approval of new microbial intervention technologies and the affected meat and poultry industry to identify approval roadblocks and to develop a better, expedited approval process that can rapidly move new technology to commercialization.  New preventive technologies that are effective against all STECs are needed to control these pathogens before USDA considers making non-O157:H7 an adulterant on beef products.

7.  Determine Impact on International Trade:  USDA, the U.S. Trade Representative, and the Department of State should commission a study to determine the impact on international beef trade that would result from declaring non-O157:H7 STECs an adulterant on beef products.  Such a policy shift will be viewed by our trading partners as erecting a non-tariff trade barrier to prevent entry of beef products into the U.S.

8.  Provide an Open and Transparent Public Policy Process:  If FSIS decides to further regulate non-O157:H7 STECs in beef products, it should only be done through notice and comment rulemaking.  The questions surrounding non-O157:H7 STECs demand a disciplined, open, and transparent regulatory process.  Any new regulatory program to control non-O157:H7 STECs will likely impose significant financial and regulatory burdens on the meat industry and these costs must be weighed against any public health benefit.

To see a copy of the letter in its entirety, click here:  http://www.meatami.com/ht/a/GetDocumentAction/i/62169

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