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Marler Blog Providing Commentary on Food Poisoning Outbreaks & Litigation

If there was an Undersecretary of Agriculture for Food Safety Inspection Services, what should he or she do first?

Or, what I would do if I changed jobs?

The position, although still unfilled, of Undersecretary for Food Safety plainly exists for a reason. Its sole mission should be food safety and public safety. The Undersecretary for food safety should, and needs to, be the responsible person within the FSIS on this important issue, advocating and making decisions solely on behalf of public health.

If, or when, the President appoints an Undersecretary here are some of the things they should do:

1. Have the FSIS update and finalize the E. coli O157:H7 Risk Assessment that it started about ten years ago, including especially an in depth look at cross-contamination (thus changing the agency’s operating assumption that somehow cooking alone solves all problems).

2. Develop uniform cooking and handling instructions that actually provide helpful guidance (in contrast, for example, of the suggestions to “cook thoroughly”), while also requiring that alternate or additional handling and cooking instructions on packages must be supported by tests and other evidence before being approved for use on the package.

2. Enforce a real zero-tolerance policy for E. coli O157:H7 and non-O157 EHEC.

3. Do meaningful sampling and surveillance of meat to determine real prevalence of all pathogens.

4. All Non-compliance Report (NR’s) and other enforcement documents at slaughter plants and grinding operations would go online in real-time (like restaurant health inspections are).

5. You should be able to go online, enter a USDA establishment number, and see not only all NR’s but testing results too.

6. Create new quality certifications to aid consumers in making choices, and allow companies to capture price premiums for higher quality.

7. Support small and medium sized agriculture by growing local and regional markets for produce and meat.

8. Improve surveillance of bacterial and viral diseases. First responders – ER physicians and local doctors – need to be encouraged to test for pathogens and report findings directly to local and state health departments and the CDC promptly.

9. Increase food inspections. While domestic production has continued to be a problem, imports pose an increasing risk, especially if terrorists were to get into the act. Points of export and entry are a logical place to step up monitoring. We need more inspectors – domestically and abroad.

10. We need to use our technology to make food more traceable so that when an outbreak occurs authorities can quickly identify the source and limit the spread of the contamination and stop the disruption to the economy.

Sure, there are more things (advice and comments requested), but this would give us a hell of a start.

  • Art Davis

    Below is part of a note I wrote two or three years ago for The Garrett and Associates Newsletter. I’m not sure if a Government official can mandate specific employee qualifications, operational practices, and managment involvement but to the extent possible I think it might help.
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    In my opinion the current need is not for new standards, programs or procedures. It is rather development within the industry, from the rarified atmosphere around the pinnacles of management to the daily haze and hustle of field and production facility, of a belief in and commitment to food safety as the fundamental foundation for all operational decisions. I think there are a number of ways to demonstrate that this commitment exists. While these will not provide the excitement of new committees, new rules, or new enforcement I do believe that in the long run they are a superior approach to the assurance of food safety for the produce industry.
    1. Every field operation and production facility will have a qualified individual responsible for application and documentation of food safety standards. This individual will report directly to the President / CEO and will have supported authority to suspend or modify all operations as required to meet established food safety standards.
    Qualifications for this position will include a four year degree in a relevant, science based, field of study. This person must be familiar with, at a minimum, basic microbiology, basic chemistry, basic statistics, and principles of food safety systems.
    2. The President / CEO / COO of each production entity will participate on at least a monthly basis in a review of food safety operations. This review will involve, at a minimum, a half day and include at least two hours in the field or production facility as appropriate. The President / CEO / COO will prepare a written review of each visit and present these to the board of directors or other group as appropriate.
    The basic idea behind this requirement is to ensure that a large percentage of a company’s employees see the top manager regularly involved in food safety issues. The power of leadership by example is well known and effective. In times of crisis it is also useful for the top leadership to have a standing relationship with daily operations and be somewhat familiar to employees at all levels.
    3. Third party audits will be unannounced and done by audit groups that meet some basic requirements as noted.
    Third party audit groups will have:
    A. All auditors will be direct, full time, employees of the parent audit group.
    B. Specific initial qualifications for auditors to include a four year degree in a relevant science based field of study.
    C. Standardized initial training of all auditors by the audit group on a face to face basis.
    D. At least annual retraining and standardization of all auditors done on a face to face basis
    E. Documented system of regular management review of audits
    The point here is to make sure that third party audits see operations as they exist on a day to day basis, not as they exist after a massive three day clean up and document update. It is also to insure that third party audits are conducted by qualified individuals committed to auditing who have appropriate background knowledge and work under a standardized system of training and review.
    4. Each operating entity will promote a policy of encouragement to employees to report any observed breaches in food safety standards. These reports will be reviewed and commented on as part of the President / CEO review noted in #2 above.
    Properly promoted this sort of program is very effective at spotting potential problems. Employees must feel a personal commitment to food safety and have no concerns with regard to reporting potential issues.
    None of these ideas are new. They do however reflect on the more critical deficiencies I have personally observed over the last several years. I think we need to put a great deal of effort into convincing the produce industry, from the top down, that food safety isn’t a marketing tool, it isn’t an annual cleanup for an audit, it isn’t just a good idea when convenient, IT’S THE WAY WE DO BUSINESS.