The Impact of Pathogen Reduction/HACCP on Food Animal Production Systems

1. The Impact of Pathogen Reduction/HACCP on Food Animal Production Systems Food Safety and Inspection Service U. S. Department of Agriculture

2. Overview of Presentation • New USDA Pathogen Reduction and HACCP Systems Rule for Plants • In-Plant Residue Control Options • Impact of Rule on Food AnimalProduction Systems • Importance of HACCP-Compatible Production Practices

3. Why Has FSIS Changed Its Inspection Rules? Focus on Foodborne Illnesses • Salmonella • E. coli O157:H7 • Campylobacter • Listeria

4. Why Has FSIS ChangedIts Regulations • First major change in almost 100 years • Need to reduce risks of foodborneillnesses from meat, poultry andegg products • HACCP accepted as science-basedpreventive risk reduction system

5. Pathogen Reduction:Hazard Analysis and Critical Control Point (HACCP) Systems Final Rule Published July 25, 1996

6. Pathogen Reduction/HACCPFinal Rule • Meat and poultry slaughter andprocessing establishments must: • Implement Standard OperatingProcedures for Sanitation • Test certain products for generic E. coli • Implement HACCP systems • Meet USDA-FSIS Salmonellaperformance standards

7. Pathogen Reduction/HACCP Final Rule Slaughter and processing plants must assume more practical responsibility for food safety

8. Pathogen Reduction/HACCP Final Rule “Those in control of each segment must bear the responsibility for identifying and preventing or reducing food safety hazards.” 1996 Rule, Background

9. Farm to Table Food Safety • Animal Production (farm to slaughter) • Slaughter and Processing Plants • Post-Processing Transportation • Wholesale and Retail Stores • Food Service • Consumer Education

10. Pathogen Reduction/HACCP Final Rule • Foreign Systems must be “equivalent to” • State Systems must be “equal to”

11. Pre-HACCP ImplementationIn Plants • On January 27, 1997 plants: • implemented Standard Operating Procedures for Sanitation • began generic E. coli testing for fecal contamination; and • began devising pathogen reduction and HACCP plans

12. Pathogen Reduction/HACCP Final Rule Implementation • January 26, 1998 • Large establishments • January 25, 1999 • Small establishments • January 25, 2000 • Very small establishments

13. Pathogen Reduction/HACCP Rule and Animal Production • January 26, 1998 • 75-80% of food animals marketed • January 25, 1999 • 90-95% of food animals marketed • January 25, 2000 • 100% of food animals marketed

14. Pathogen Reduction/HACCP Rule and Animal Production • There is no regulatory requirement to test live animals for hazards • Rule describes non-regulatory approach for animal production food safety • Part 417.2 requires plans to evaluate hazards in animals

15. Pathogen Reduction/HACCP Rule Part 417.2(a) Plants must conduct a hazard analysis “to determine the food safety hazards reasonably likely to occur before, during and after entry into the establishment”

16. Pathogen Reduction/HACCP Final Rule Part 417.2 Hazards • Physical hazards (foreign objects) • Natural toxins (aflatoxins, etc.) • Zoonotic diseases (bacterial, parasitic) • Other microbial contaminants • Chemical contaminants (pesticides and drug residues) • Food additives and decomposition

17. Slaughter Plant ResidueControl Process • Evaluate significant residue hazardsof incoming animals purchased • Develop HACCP plan forresidue control • Determine information neededfrom animal suppliers

18. Slaughter Plant Residue Control Options for Incoming Animals • Reject animals with a high risk of violative residues • Clearly define purchase criteria • Buy only from suppliers quality assurance certified

19. Slaughter Plant Residue Control Options for Incoming Animals • Refuse to purchase from supplierswith past residue violations • Require written assurances or lettersof guarantee of no adulteration • Have drug or pesticide userecords available

20. Slaughter Plant Residue Control Options for Incoming Animals • Periodically test animals or carcasses for residues • Obtain verification of proper drug or pesticide use

21. Higher Risk Classes for Violative (Illegal) Drug Residues • Bob veal (3 weeks, 150 lbs.) • Culled cows and bulls • Culled boars and sows • Roaster pigs • Hospital pen clean-outs

22. Impact of PR/HACCP Rule on Animal Production Systems Packers may need more information on incoming animals for their HACCP plan.

23. Impact of PR/HACCP Rule on Animal Production Systems • HACCP-compatible practices provide food safety and market assurances • Quality Assurance Program(QAP) Certification • Animal/premise identification

24. Impact of PR/HACCP Rule on Animal Production Systems • HACCP-compatible practices (con’d) • Record keeping • Third party verified(audited) processes

25. Importance of QualityAssurance Certification • Promotes animal health and welfare • Ensures proper drug and antibiotic use • Provides records to assure purchasers of good production practices

26. Importance of QualityAssurance Certification • Proven to reduce residue violations • Potentially reduces pathogens through good hygiene and animal health • Improves production efficiency andquality of animals

27. Importance of Verified Quality Assurance Programs • Provides added assurancesto purchasers • Provides documentation tosupport branded productsand international markets

28. Milk and Dairy Beef Quality Assurance Program • Food Safety Control Points • Valid veterinary/client/patientrelationship for drug useand health • Storing and administering drugs • Milk drug screening tests

29. Milk and Dairy Beef Quality Assurance Program • Certification by veterinarians is an educational process

30. Pork Quality Assurance Certification Program • Level I • Food safety and HACCP awareness • FDA animal drug use compliance policy guide explained • Current regulatory systemsincluded • Level II: Educational self test

31. Pork Quality Assurance Certification Program • Level III: Veterinarian Assisted • 10 Good Production Practices Defined • 1 to 6: Residue avoidance practices • 7 to 9: Animal health, care and feeding • 10: Complete checklist annually • Recertify every two years

32. Beef Quality Assurance Certification Program • Guidelines for proper animalhealth product use • Awareness of feed ingredientsand potential residues • Total Quality Manage-ment education • Tailored State by State

33. Animal Production andPathogen Reduction • Research needed to determine food safety control points from farm to slaughter • What practices will reduce pathogens in live animals and result in reducing contamination on carcasses?

34. Animal Production andPathogen Reduction • Research needed for food safety control points from farm to slaughter (con’d) • Can animals be sorted pre-slaughter to reduce contamination on carcasses?

35. Salmonella in National Culled Dairy Cattle Survey 1996-1997 • FSIS/University collaborative project • 5,000 cecal-colon samples at slaughter • Winter and summer seasons • Good and poor conditioned cowshad no significant differencein Salmonella shedding

36. Summary of Presentation • New USDA Pathogen Reduction and HACCP Systems for Plants • In-Plant Residue Control Options • Impact of Role on Food Animal Production Systems • Importance of HACCP-Compatible Production Practices

37. Summary • New Pathogen Reduction/HACCP Systems Rule implemented in plants requires physical, chemical and microbial hazard controls • Food animal producers are being affected

38. Summary • Packers may need more information on animals supplied • Quality Assurance Program Certification • Animal/premise supplier identification • Treatment and disease records

39. Food Safety Productivity (Value) Animal Health Good Management Quality Assurance Program Animal Identification Production Treatment Records Proper Drug Use Feed Quality & Safety Culling Practices General Sanitation Waste Management

40. Summary Food animal producers who followgood production practices and are Quality Assurance Program Certifiedwill be able to meet food safetydemands in the HACCP era.