STATEMENT OF JOHN BAILAR FOOD AND NUTRITION BOARD NATIONAL RESEARCH COUNCIL FOR THE SUBCOMMITTEE ON OVERSIGHT OF GOVERNMENT MANAGEMENT MAY 15, 1987 The National Research Mr. Chairman and members of the subcommittee: I am Dr. John Bailar. I am a physician and statistician who specializes in public health aspects of risk assessment and risk management. I am on the faculty of the School of Public Health, Harvard University. Council's (NRC) Commission on Life Sciences has asked me to summarize the findings of the Food and Nutrition Board's Committee on the Scientific Basis of the Nation's Meat and Poultry Inspection Program. That committee's report, entitled Meat and Poultry Inspection: The Scientific Basis of the Nation's Program was published in 1985. I was a member of that committee, I also served as Vice-chair of the NRC's Committee on Public Health Risk Assessment of Poultry Inspection Programs, which has recently completed a study in follow-up to the one that produced the 1985 report. My statement is based on the 1985 report. The ideas, conclusions, and recommendations that I convey in this formal statement are those of the committee although I may not always identify them as such. My answers to your questions will for the most part reflect the conclusions and recommendations of the committee but will be undoubtedly flavored by my own viewpoints in some cases. -2 The 1985 report on Meat and Poultry Inspection was developed at the request of the Administrator of the Food Safety and Inspection Service of the Department of Agriculture. Hereafter I will refer to the Service as FSIS and its parent agency as USDA. The Administrator of FSIS asked the National Research Council to appoint a committee to provide a scientific appraisal of the ability of the current inspection system, including some recently introduced changes intended to improve public health protection, and to propose ways to improve the program. The committee recognized that the inspection process as a whole has important objectives other than health, including accurate labeling, protection of the aesthetic qualities of fresh and processed meat and poultry, and humane slaughter. The committee's charge, however, was to examine the "scientific basis of the nation's program," and we interpreted that charge to limit our direct concerns to health. In practice, that means biological and chemical hazards. The committee found that American consumers have broad access to meat and poultry that is wholesome and safe, but that inspection could be improved by new techniques for detecting microbial and chemical contaminants and by revised inspection practices that incorporate the principles of risk assessment and risk management. Traditional inspection procedures date to the turn of the century, when there was reason for genuine concern about the health of animals used for food products and the conditions under which they were -3 slaughtered. Federal meat inspection activities were organized to remove obviously diseased animals from the food supply and to assure that only healthy animals, slaughtered under sanitary conditions, reach the market place. The general responsibilities of FSIS include responsibility for inspecting slaughtered animals, ensuring the cleanliness of meat and poultry plants, monitoring contaminants in meat and poultry products, and ensuring the accuracy of labeling. Inspectors examine animals before, during, and after slaughter for physical injury or signs of disease. In the critical phase of postmortem inspection, inspectors rely primarily on organoleptic techniques; that is, observation by sight, smell, and touch, to examine some 127 million head of cattle, sheep, and hogs, plus more than four and a half billion chickens and turkeys each year. These procedures have served the purpose for which they were originally intended: to detect grossly diseased animals and damaged products and tag them for removal from the food supply. However, they can have little role in the detection and control of the most important health risks of the present, microbial and chemical contaminants. In part because of the success of that original program and the general good health of food animals, the conditions under which they are slaughtered and processed are no longer the major public problems they were some decades ago. I would now like to focus on the major conclusions and recommendations of the committee. The committee found that the meat and poultry inspection program of FSIS has in general been effective in ensuring that apparently healthy -4 However, animals are slaughtered in clean and sanitary environments and that defective animals and parts detected at slaughter are removed from the food supply. FSIS has clearly reduced risks to public health from conditions that can be observed during antemortem and postmortem inspection and that can be evaluated during processing. substantial challenges continue to confront the agency. Some aspects of the inspection system are poorly defined in terms of objectives relevant to public health. A risk-based allocation of resources, supported by modern technology and a systematic evaluation of the program, would be valuable. It is well established that species of Salmonella and Campylobacter cause diseases that are transmissible to humans through the consumption of meat and poultry products. Current postmortem inspection methods are not designed to detect diffuse contamination with these or other organisms, and the committee recommended that FSIS intensify its current efforts to control and eliminate contamination with microorganisms that cause disease in humans. Such efforts should include evaluation of rapid diagnositic procedures for detecting microorganisms, especially species of Salmonella and Campylobacter, and education of the general public, health care personnel, educators, and extension service workers in the safe handling of meat and poultry. The committee commended recent progress by FSIS in protecting the public against exposure to hazardous chemicals in meat and poultry, but found that FSIS's residue monitoring program needs to be further expanded and improved to ensure maximum protection of the public health. In particular, the committee questioned the adequacy of the total sample size used for routine monitoring, the procedures for sampling animals and -5 tissues, the basis for and utility of current tolerance levels for chemicals, and the basis for setting priorities for testing chemicals. In particular, we recommended that FSIS work to prevent the introduction of chemical hazards and potential hazards to human health. Although FSIS has adopted new technologies, the committee found that the efficiency of the current inspection and processing operations and the ability of those procedures to protect public health are impeded by the limited application of rapid, specific, and sensitive techniques to detect pathogenic microorganisms and deleterious chemicals in meat and poultry and by inadequate information acquisition and retrieval facilities. For example, the failure to apply sufficiently modern techniques to detect abnormalities in organs and tissues necessitates more extensive, yet less efficient, human resources during inspection. The current FSIS computer capabilities for the acquisition, analysis, and transmission of data are relatively slow and are inadequate to meet the growing demands of the agency for rapid interpretation of, for example, data on the prevalence and public health implications of high levels of chemical and microbial residues in meat and poultry. Computer-assisted information systems with better capabilities are commercially available. The Recent advances in science and technology have made possible rapid, sensitive, and inexpensive techniques based on immunological and recombinant DNA principles (biotechnology), some of which can be applied at the farm level for screening microbial and chemical contaminants. Swab Test on Premises (STOP) and the Calf Antibiotic Sulfonamide Test (CAST) are two such techniques used by FSIS for antimicrobial residues. STOP is a new fast screening test for antibiotics that is used at |