In recent years, we’ve seen a growing number of illnesses due to salmonella in ground beef that has been raised and processed at industrial-size farms and processing facilities.

The Food Safety Inspection Service (FSIS) of USDA is proposing changes in response to these outbreaks.  But while there is a need for reform, the proposed changes are unlikely to solve the problem.  Instead, the changes will cause problems for small-scale processors who are not the source of the outbreaks.

FSIS already tests ground beef for salmonella periodically, but because salmonella is not an “adulterant” under the Federal Meat Inspection Act, these tests aren’t designed to identify meat that would make people sick from salmonella.  Instead, the tests seek to identify any presence of salmonella, even if it is too low or of the wrong type to cause any human illness.  If salmonella is detected, then FSIS treats it as proof that the processing facility’s “process controls” are inadequate.

What happens then?  FSIS inspectors come in and demand that the facility change its Hazard Analysis and Critical Control Point (HACCP) plan to address the perceived flaw. 

Large scale-facilities have entire departments of lawyers and consultants to deal with the agency demands.  They may make some changes to their process, but they can stonewall any attempt to make the significant changes necessary to truly improve food safety.

What happens to a small plant?  They don’t have lawyers and experts on retainer, and they quickly find themselves buried in paperwork and impossible agency demands – even if the salmonella detected was at such a low level or a type that posed no real health risk. In the end, many small processors will be driven out of business, “HACCP’d to death.”

This is already happening to small-scale poultry processors, and FSIS’s proposed changes are likely to lead to the same pattern for beef processors. It’s difficult enough for small-scale poultry and livestock producers to find suitable processors, so putting more processors out of business could be catastrophic for independent farmers.

Specifically, FSIS is proposing to increase sampling frequency to once per week regardless of the size of the beef production (currently, smaller facilities are sampled a maximum of twice a month).  The proposed rule also tightens the criteria by which FSIS decides whether an establishment is “meeting” or “not meeting” the pathogen reduction performance standards for Salmonella – but, again, the “not meeting” threshold is not based on whether the detection is likely to cause human illness.

Under the new proposal, FSIS would thus be taking the same number of samples from a facility that processes 50,000 pounds/day as from a facility that processes a million or more pounds of product per day.  Facilities under 50,000 lbs./day will continue under the current rules.

While 50,000 lbs. of product sounds like a lot. that’s 50 cows.  Many small establishments process that volume of product in a day (although not necessarily every day).  The processes implemented by small establishments are different than those used by the largest establishments but are just as good if not better.  

TAKE ACTION:

The agency is accepting public comments until January 27, 2010. (The agency has extended the deadline from its original date of December 27, 2019.) FARFA filed its comments on December 30; you can read them HERE.

Read the rule and file comments online at:

https://www.federalregister.gov/documents/2019/10/28/2019-23473/changes-to-the-salmonella-verification-testing-program-proposed-performance-standards-for-salmonella

If you are a meat processor or livestock producer who has experienced problems with the current system with FSIS, please share your comments with us!  We’ll use your experiences both to craft our comments to the agency on this specific proposal and as we work on strategy for broader reforms.

TALKING POINTS:

• Sampling frequency should be based on the different types of processors and how much meat they process.  The processors should be separated into categories based on the processing methods, and FSIS should test every X pounds of product within the process categories.
• Testing should differentiate between the mere presence of Salmonella or other bacteria, and their presence at levels sufficient to cause human illness.
• The proposed change ignores important differences between the smallest and largest spectrum of the industry. The proposed changes are burdensome for small processors that already have high levels of food safety measures and much greater traceability than the large ones.