An Evaluation of the Food Safety Requirements of the Federal Purchase Ground Beef Program (2010) / Chapter Skim
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BACKGROUND
BACKGROUND
Pages 7-26
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From page 7... ...
AMS buys ground beef from more than 15 suppliers that are required to comply with federal regulations and guidelines and to adhere to strict nutritional, food safety, and food quality requirements. Specifications for the Federal Purchase Ground Beef Program exceed those mandated by the USDA Food Safety and Inspection Service (FSIS)
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From page 8... ...
On the basis of the statement of task, the committee considered the following as its charge: to evaluate the scientific basis of the AMS technical documents that describe food safety requirements for suppliers to the Federal Purchase Ground Beef Program and procedures for testing laboratories, to examine how the AMS standards, methods, and requirements compare with those used in large purchasing programs of industry leaders that supply ground beef products directly to consumers through retail sales or food service operations, and to provide recommendations to AMS for conducting periodic evaluations of the Federal Purchase Ground Beef Program. The committee examined the scientific basis of the AMS July 2010 TRS-GB (USDA-AMS, 2010a)
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From page 9... ...
Recognized principles for establishment of microbiological criteria. Indicator microorganisms as potential predictors of food safety.
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From page 10... ...
Because the Federal Purchase Ground Beef Program supports food assistance programs, such as the NSLP, the committee thought it unlikely that the 2000 SUNY outbreak and the 2003 restaurant–schools outbreak involved AMS-purchased ground beef and therefore did not consider them relevant to the discussion of the safety of ground beef in the Federal Purchase Ground Beef Program. Thus, from 1998 to 2007 there were two primary school lunch outbreaks associated with ground beef contaminated by E
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From page 11... ...
Some portions of Principles for the Establishment and Application of Microbiological Criteria for Foods that are useful for AMS to consider are discussed below with examples of how they may apply to the Federal Purchase Ground Beef Program. Application of Appropriate Tests CAC/GL 21-1997 Section 2.3: When applying a microbiological criterion for assessing products, it is essential, in order to make the best use of money and manpower, that only appropriate tests be applied to those foods and at those points in the food chain that offer maximum benefit in providing the consumer with a food that is safe and suitable for consumption.
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From page 12... ...
Recommendation A1: The committee recommends that the criterion for S aureus be removed from the Federal Purchase Ground Beef Program and that similar analyses be conducted and documented for other criteria to provide transparency and a scientific basis for the criteria specified.
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From page 13... ...
However, during a public meeting with AMS on July 15, 2010, the committee learned that for some products, such as coarse ground beef, further processing in USDA-inspected facilities is expected. Recommendation A2: The committee recommends that AMS consider conducting a more thorough review of criteria for different product types through a national advisory committee designated to provide impartial scientific advice on microbiological criteria to federal food safety agencies, such as the National Advisory Committee on Microbiological Criteria for Food (NACMCF)
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From page 14... ...
Therefore, the AMS standard for ground beef free of Salmonella is inconsistent with recognized principles for establishment of specifications. Finding A4: The application of more stringent microbiological criteria by AMS for the 2010 Federal Purchase Ground Beef Program is inconsistent with CAC/GL 21-1997 principle 4 in that previous requirements appeared adequate to protect public health.
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From page 15... ...
Agricultural Marketing Service Microbiological Requirements As a technical requirement document for AMS purchase of ground beef items, the committee found the July 2010 TRS-GB (USDA-AMS, 2010a) to have little information on the scientific basis of the selection and adoption of the safety requirements for boneless beef and ground beef.
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From page 16... ...
Finding A7: The scientific basis of the AMS technical requirements for the purchase of ground beef is questionable and might not reflect the best evidence available (see the section "Weight of Evidence and Role of Expert Opinion in Developing Science-Based Food Safety Requirements")
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From page 17... ...
However, increased testing might not increase the safety of the product. Process control is a well-established method for improving food safety and is the basis of HACCP.
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From page 18... ...
Moreover, different users may consider some measures as food safety specifications, as quality indicators, as tools for assessing process control, or as evidence of supply chain management. As a measure to protect public health, therefore, the comparison is of little value, or even of little purpose, because the scientific underpinnings of the specifications, excluding E
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From page 19... ...
(CFU/g) A 100,000 1,000 240 N/A N/A N/A B <50,000 <500 <10 <100 Min Min Neg C 750,000 1,100 240 <1,500 Min N/A D 250,000 N/A 110 Min Min E 1,000,000 5,000 -- 240 Min Min F -- -- -- -- Min Min G 500,000 1,000 250 250 Min Min H 500,000 1,000 100 500 N/A N/A I 500,000 500 240 100 Min Min J <100,000 <500 <110 250 Min N/A K -- -- -- -- -- -- L 500,000 1,000 250 500 Min -- M 500,000 1,100 100 -- Min Min N -- -- -- -- -- -- O -- -- -- N/A -- -- P 250,000 240 100 <500 Q <500,000 <1,100 N/A Neg R <1,000,000 <10 <3 110 Neg Min S 100,000 500 150 -- Min Min T -- -- -- 250 -- -- U 750,000 5,000 -- <110 Min Min V <100,000 <500 <150 -- -- W 500,000 500 Neg X <100,000 <110 Neg AMS upper specification 50,000 100 100 500 limitc AMS 100,000 1,000 500 Neg Neg critical d limit a APC = aerobic plate count; dash = company's default specification, not shown, used as company's specification; empty cell = company does not include as a requirement in its specification; N/A = company does not require testing for organism as part of its specification; Min = minimizes occurrence of positives through Good Manufacturing Practices; Neg = negative.
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From page 20... ...
. RECOMMENDATIONS ON HOW TO PERFORM FUTURE EVALUATIONS RELATIVE TO RECOGNIZED BEST PRACTICES Heuristic vs Science-Based Approach to Developing Specifications and a Food Safety Assurance System Specification writers may use a heuristic approach to develop specifications, which focuses on using experience to develop specification and is based on the following assumptions: The food safety assurance system has worked in the past.
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From page 21... ...
HACCP has achieved its success by designing food safety into the manufacturing process. Thus, the only rational means of achieving continual reduction in pathogens is to control the process of manufacture of ground beef from harvesting to packaging of the frozen patty and use statistical process control tools to monitor the process, and use continual improvement techniques to improve process and process performance.
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From page 22... ...
. Once the "context" is understood, a food safety assurance system can be developed to ensure the shipment of product that meets defined food safety requirements Weight of Evidence and Role of Expert Opinion in Developing Science-Based Food Safety Requirements The committee spent considerable time in discussing what science-based means for food safety requirements in the Federal Purchase Ground Beef Program.
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From page 23... ...
Peer-reviewed reports and risk assessments Formal expert consultation (for example, with NACMCF) Increasing Internal reports based on relevant AMS data Weight of Reports based on confidential data that are not peer-reviewed Evidence Industry standards/best practices Informal ad hoc expert opinion Figure 2 Hierarchy of science-based food safety evidence.
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From page 24... ...
Other Considerations As a large purchaser of ground beef for distribution to the school lunch program, emergency feeding programs, food banks, protective shelters, disaster-relief programs, reservations, and other eligible programs that serve the food-insecure, AMS serves members of society who may be most vulnerable to foodborne illness and its consequences, including children, the elderly, and the immunocompromised. It is essential that the specifications set by the USDA Federal Purchase Ground Beef Program are based on the best available science and have as goals protecting public health and ensuring that the ground beef products purchased in the program are safe, nutritious, wholesome, and of high quality.
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From page 25... ...
may also add cost to the system without public health benefit. Overall Findings and Recommendations on How to Perform Future Periodic Evaluation of the Federal Purchase Ground Beef Program Finding C2: In developing its current purchase specifications for ground beef, AMS did not follow a procedure based on the scientific principles described by the National Research Council, the International Commission on Microbiological Specifications for Foods (ICMSF)
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From page 26... ...
Recommendation C4: AMS's goal should be to protect public health by removing potentially unsafe product from the food supply through safe disposition, when advisable, such as directing it to safe further processing, rather than removing it completely from the Federal Purchase Ground Beef Program. In addition to providing guidance as to how such product is diverted, AMS could provide a mechanism for verifying its appropriate diversion.
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