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slaughter. CAST is a similar technique for antibiotics and sulfonamide residues. The results of these tests can be obtained within 24 hours, compared with 1 to 2 weeks using conventional methods.

Several changes would help to strengthen the National Residue Program (NRP) of FSIS and to increase the impact of NRP test results. The present NRP program was designed to detect (with 95% certainty) certain chemical hazards that affect at least 1% of slaughtered animals across the nation as a whole; thus, problems that are temporary or affect only a few sources may have little chance of being detected. The NRP sampling plan for chemical residues should be expanded and revised to increase the probability of detecting hazards that are linked in time or location. Another useful step would be a system to identify animals individually, with means to trace specific health risks back to the farm of origin. Further, the committee suggested that FSIS reexamine the priorities and the methods used by other regulatory agencies for establishing tolerance levels of chemicals to ensure that they appropriately reflect the size of risks to public health. Formal risk assessment and more frequent communication with other regulatory agencies and with scientific peer-review groups would be beneficial.

This issue is

The committee noted that effective monitoring of feed and water ingested by food animals requires access to farms and feedlots, where infectious microorganisms and chemicals are introduced. complicated by the fact that FSIS does not have the authority to become directly involved in monitoring and management of feed and water and because other government bodies--namely, the Food and Drug Administration and the Environmental Protection Agency--also have responsibility for various aspects of the surveillence and control of additives and

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pesticides. The committee recommended that means be found for FSIS to coordinte monitoring and control of hazardous agents where they enter the meat and poultry food chain. The committee found it to be logical that FSIS have this responsibility, because FSIS alone is charged with ensuring the safety and wholesomeness of meat and poultry products in a general sense and because FSIS already does the sampling and testing for chemical hazards.

FSIS continually modifies its traditional inspection methods and introduces new techniques to detect health hazards and to increase the efficiency of inspection. The committee noted that the changes introduced are not likely to diminish protection of the public health. However, the committee was hampered in developing a more precise assessment of the effects of the changes because it could find no comprehensive statement of criteria used to justify the use of new procedures, no systematic accumulation of data that could be used for evaluations, and no complete technical analysis of the benefits of the procedures.

The committee commented that a voluntary program introduced in 1980 called Total Quality Control (TQC), in which selected meat processors share responsibility for ensuring product safety with FSIS, seem to be working well. However, it recommended that the program incorporate newer technologies and that both FSIS and industrial personnel receive

additional training to improve efficiency.

The committee favored an approach that would link the inspection program more directly to criteria relevant to public health. In this context the committee endorsed a hazard analysis-critical control point (HACCP) approach, which focuses monitoring efforts on specific points in

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the system. Ideally, this approach should be applied to each phase of food production and processing from farm to table. The committee recommended that FSIS implement a HACCP approach more rapidly and comprehensively within the scope of its authorities.

The committee concluded that "The establishment of reasonable, measurable objectives for the nation's meat and poultry inspection program is imperative." It urged FSIS to adopt the principles of risk assessment as a tool to guide its program analyses and decisions about inspection procedures. Risk Assessment includes:

identification of

hazards; measurement of dose-response relationships; estimation of exposure likely to be experienced by the population as a whole and by sensitive groups such as young children and the elderly; and an evaluation of the overall consequences of exposure. Using this approach FSIS could assess each step of the inspection process to determine whether it is useful in protecting human health and in the attainment of other inspection objectives.

The committee described an optimal meat and poultry inspection program and listed 17 of its components, many of which FSIS has already put in place. As envisioned by the committee, an optimal program would utilize the skills of teams of broadly knowledgeable inspectors and would seek advice from panels of outside persons who are experts in specific disciplines. Some other critical elements of an optimal program are a traceback and recall system, an adequate sampling plan, an inspection system with different levels of intensity, and adequate resources to conduct or sponsor research into new inspection technologies.

To summarize, the committee concluded that what FSIS does, it does well, but some changes are needed. The primary risks to public health

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associated with meat and poultry products are from microbiological and

chemical contaminants.

These health risks are not in general detectable

by current inspection methods, but recent technological advances could be used by FSIS to help attain its goal of protecting the public health. FSIS must determine where such techniques might be used most effectively, it should provide for ongoing evaluation of these and other changes, and it should attempt to prevent the introduction of human health hazards into food production systems using well established risk assessment and risk management techniques. This latter objective is complicated by the overlapping authorities of several government agencies.

Record Statement of:

Joshua E. Neiman

Legislative Representative

Food and Allied Service Trades, AFL-CIO

To:

Subcommittee on Oversight of Government Management
Committee on Government Affairs

On:

U.S. Department of Agriculture Poultry Inspection System

MR. CHAIRMAN AND MEMBERS OF THIS DISTINGUISHED SUBCOMMITTEE, LET ME CONGRATULATE YOU FOR HOLDING HEARINGS ON SUCH AN IMPORTANT ISSUE. MY NAME IS JOSH NEIMAN AND I AM A LEGISLATIVE

REPRESENTATIVE WITH THE FOOD AND ALLIED SERVICE TRADES DEPARTMENT OF THE AFL-CIO. FAST REPRESENTS 16 UNIONS AND APPROXIMATELY 3.5 MILLION WORKERS IN THE RAPIDLY GROWING SERVICE ECONOMY.

THE ISSUE OF POULTRY INSPECTION IS NOT NEW TO FAST OR ANY OF ITS AFFILIATES. THE LABOR MOVEMENT HAS LONG PROMOTED LEGISLATION THAT PROTECTS WORKERS AND CONSUMERS FROM CONTAMINATED MEAT. NOW THERE IS GOOD REASON FOR REVIVED CONCERN.

SOME OF THE PEOPLE WHO HAVE TESTIFIED BEFORE THIS COMMITTEE WOULD LIKE YOU TO BELIEVE THAT VISUAL INSPECTION IS USELESS: BIRDS DON'T SUFFER FROM VISUALLY-DETECTABLE DISEASES, AND ALL DISEASES THAT BIRDS NOW SUFFER FROM CAN BE DETECTED WITH MICROBIOLOGICAL TESTS. IT'S TRUE THAT THE VISUAL INSPECTION SYSTEM WE NOW HAVE CAN'T DETECT SALMONELLA, BUT CAN THE PROPOSED MICROBIOLOGICAL TESTS DETECT A CANCEROUS TUMOR?

WE NEED TO USE OUR HUMAN RESOURCES IN THE MOST EFFICIENT WAY TO DETECT DISEASE IN FOOD. HOWEVER THERE IS NO EVIDENCE THAT MICROBIOLOGICAL TESTS ALONE ARE AN EFFICIENT WAY TO DETECT THE MOST COMMON DISEASES IN POULTRY. SOME DISEASES ARE MOST EFFICIENTLY DETECTED VISUALLY, AND SOME DISEASES ARE MOST EFFICIENTLY DETECTED MICROBIOLOGICALLY. BUT BEYOND THIS, THOSE MICROBIOLOGICAL TESTS SIMPLY HAVEN'T BEEN DEVELOPED YET.