Review of the Methodology Proposed by the Food Safety and Inspection Service for Followup Surveillance of In-Commerce Businesses A Letter Report (2009) / Chapter Skim
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APPENDIX C Presentations by Donald Anderson and Matthew Gonzales of FSIS
APPENDIX C Presentations by Donald Anderson and Matthew Gonzales of FSIS
Pages 18-29
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APPENDIX C Presentations by Donald Anderson and Matthew Gonzales of FSIS Public Health Risk-Based In-Commerce "Initial" and Follow-up Surveillance Presented to the National Academy of Sciences July 6, 2009 Today's Topics • Review the "initial surveillance" methodology we are implementing based -- in-part -- on the prior committee's recommendations • Ask NAS to comment on preliminary ideas for prioritizing follow-up surveillance activities 2 18
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Important Priority Risk Considerations - Inherent Risk -Consumer Susceptibility -Volume -Food Defense Vulnerability Reports -Jurisdiction Business Types Transporters, Distributors, 8,262 16,754 Other, 4,275 Warehouses, 23,625 Institutions, 54,621 Retailers, 120,249 Restaurants, 500,000 4
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y od ge s rs ks s ts rs ns m rs D tr se or 4 an to te re le an va Fo tio ul ut ou or ai us de ur Po B al itu ib et al sp eh C ta en lS od tr m R st pt es an ar is R ai ni Fo In em D W R et Tr A R Ex 6
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LETTER REPORT 21 Previous NAS Review • November 2008 public meeting • March 23 NAS report 7 Risk Considerations • Volume of meat, poultry and egg products handled • Susceptibility to Foodborne Illness of the populations served • Inherent hazards of the products handled and processes engaged in • Food Defense Vulnerability of the operations & • Extent of Surveillance by other Federal, State, or Local authorities 8
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22 REVIEW OF IN-COMMERCE SURVEILLANCE Key NAS Recommendations • Consider a "stepwise" decision process that, in effect, allocates surveillance resources across two tiers instead of three • FSIS should consider absence of surveillance by other jurisdictions to be more important in setting priorities for surveillance than the other risk considerations • Two Flowcharts.ppt 9
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In-Commerce Surveillance Activities: Initial and In Follow-up Surveillance Follow Methodology outlined in FSIS Directive 8010.1 • Applicable to both initial surveillance and follow-up follow Initial Surveillance subject of March 2009 NAS report Businesses chosen for initial surveillance using revised Tier structure TIER 1 TIER 2 "FOR CAUSE" Transporters Food Banks Institutions Distributors 4-D Retailers Warehouses Retail Salvage Restaurants Renderers Custom Exempt Exempt Poultry Animal Food July 6, 2009 Food Safety and Inpsection Service 2
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24 REVIEW OF IN-COMMERCE SURVEILLANCE In-Commerce Surveillance Methodology In Includes activities such as: • Food Safety • Food Defense • Non-Food Safety Consumer Protection Non • Order Verification • Imported Products Results entered into the In-Commerce System (ICS) In July 6, 2009 Food Safety and Inpsection Service 3 Data is Entered into ICS July 6, 2009 Food Safety and Inpsection Service 4
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LETTER REPORT 25 Possible Actions Taken in Response to Findings Tier 1 and Tier 2 Follow-up Surveillance Follow Focus of Next Task Product Control Action Initiate Investigation • Criminal Prosecution • Civil Action • Administrative Action • Recall • Letter of Information • Letter of Warning July 6, 2009 Food Safety and Inpsection Service 5 Possible Actions Taken in Response to Findings "For Cause" Businesses Cause" Initiate Investigation Follow-up outlined in appropriate surveillance program Follow • Melamine Testing Significant Incident Response • E coli O157:H7 Testing Formation of Recall Committee Share information with Federal, State and Local public health officials July 6, 2009 Food Safety and Inpsection Service 6
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Authorities Other Reg. Authorities Product Volume Inherent Hazard Consumer Susceptibility Food Defense Vulnerability Tier 2 For Cause Tier 1 Surveillance July 6, 2009 Food Safety and Inpsection Service 7 Prioritization of Follow-up Surveillance Follow at In-Commerce Businesses In Tier 1 Tier 2 For Cause Surveillance Food Safety Food Safety Finding Finding Product Product Control Action Follow-up as Control Action outlined in Non-Food Safety Consumer Non-Food Safety Protection Finding appropriate Consumer Protection surveillance Food Defense Finding program Finding No Findings Food Defense Finding No Findings High Medium Medium Low Low July 6, 2009 Food Safety and Inpsection Service 8
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July 6, 2009 Food Safety and Inpsection Service 10
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28 REVIEW OF IN-COMMERCE SURVEILLANCE Non-Food Safety Consumer Protection Non Tier Tier 1 Tier 2 Non-Food Safety Non- Medium Low Priority Consumer Protection Priority To verify products are not misbranded, economically adulterated or otherwise unacceptable Not related to food safety Certain misbranding can be a food safety concern and would be elevated to a food safety finding Others could trigger an investigation July 6, 2009 Food Safety and Inpsection Service 11 Food Safety Tier Tier 1 Tier 2 Food Safety Finding High Priority Medium Priority Includes • Adulteration • Inedible product being diverted to human food • Insanitary conditions • Inadequate hazard controls • Inadequate Recordkeeping Certain findings would trigger an investigation and/or a recall July 6, 2009 Food Safety and Inpsection Service 12
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LETTER REPORT 29 Product Control Action Tier Tier 1 Tier 2 Product Control Action High Priority Medium Priority Process outlined in FSIS Directive 8410.1, "Detention and Seizure" Seizure" Most product control actions result in voluntary action by the product owner or custodian, such as voluntary disposal of the product If detained product cannot be disposed of within 20 days, then FSIS may request an order to seize July 6, 2009 Food Safety and Inpsection Service 13
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