Most hazardous, however, is the potential for a major regional outbreak resulting from unsanitary conditions in the processing plant. A contaminated slicer blade, for example, could contaminate every piece of meat it touches and lead to a large outbreak of foodborne illness. Shipping and Refrigeration Additional risks to public health can exist after meat and poultry products are shipped from processing plants. The bacteria already present on meat and poultry can grow if proper temperature levels are not maintained during transport. In New York State, trucks transporting perishable goods to retail food stores and foodservice establishments are not required to have refrigeration per se, although temperature maintenance is mandatory. The temperature for fresh foods must be maintained at or below 45 degrees Fahrenheit. The State Department of Agriculture and Markets is responsible for the conditions and temperature of inspecting trucks carrying perishable goods. Retail Sale The cycle of contamination can continue when meat and poultry products finally reach retail stores or foodservice outlets, such as restaurants, hopsital kitchens and cafeterias. As in the slaugherhouses and processing plants, dirty grinders, contaminated surfaces, temperature abuse, and unsanitary work habits can cause the spread of bacterial contamination. Cross-contamination can occur among raw items and between raw and cooked foods if rotisseries or deli operations are nearby (NRC, 1985a). The State Department of Agriculture and Markets inspects the conditions and temperature at which meat is sold in supermarkets, butchers, and grocery stores. The City Department of Health is responsible for the conditions and temperature of meats sold at take-out delis in New York City. Chapter Four WHERE DOES RESPONSIBILITY LIE? Summary Improving the conditions that cause foodborne illness will require a comprehensive effort on the part of industry and government. Every step of the cycle from feed to refrigeration needs to be addressed. - The USDA receives its mandate from the federal Meat and Poultry Inspection Acts of 1967 and 1968, which prohibit the sale of unwholesome meat and poultry. While it appears as if the presence of pathogens violates this law, the USDA argues that pathogens are ubiquitous, both on animal farms and in slaughterhouses. This argument is also used to circumvent a major flaw with current meat and poultry inspection program; inspectors base condemnation on sight, smell, and touch, the same system used since the program's inception in 1906. Critics claim that a change is long overdue. Furthermore, budget cuts in recent years have led to the "streamliing" of inspection procedures, which translates to fewer inspectors and faster line speeds. Instead of designing programs to prevent bacterial contamination, the USDA has endorsed less expensive methods of dealing with contamination. Chlorination, for example, is permitted to be used even though scientists are still exploring its potential adverse affects on human health. Last, it is important to keep in mind that although contamination originates in meat and poultry during the production and handling processes, food handlers, whether they be in a restaurant, store, or consumer's kitchen, are responsible for safeguarding against the growth and spread of pathogenic organisms. The USDA's Statutory Mandate The United States Department of Agriculture's statutory mandate to ensure the wholesomeness of the meat and poultry produced in this country is set forth in the Federal Meat Inspection Act of 1967 and the Poultry Products Inspection Act of 1968. These acts updated the Federal Meat Inspection Act of 1906. The statutes require the USDA to prevent the sale of food that is unwholesome, spoiled or deleterious to health. The USDA's operations, which reflect its current interpretation of its statutory mandate, fail to meet the challenge. Both acts require that meat and poultry should be considered adulterated "if it bears or contains any poisonous or deleterious substance which may render it injurious to health." Furthermore, they state that a product is adulterated "if it consists in whole or in part of any filthy, putrid, or decomposed substance or is for any reason unsound, unhealthful, unwholesome, or otherwise unfit for human food." A product containing pathogens which cause food poisoning fits the description of a poisonous or deleterious substance which is unsound, unhealthful, and unfit. Nevertheless, the USDA does not automatically condemn such products. According to the law, meat and poultry products are also considered adulterated if they have "been prepared, packed or held under unsanitary conditions whereby it may have become contaminated with filth, or whereby it may have been rendered injurious to health." The Department of Agriculture's Food Safety Inspection Service (FSIS) is responsible for preventing the interstate shipment of unwholesome meat and poultry. Since microbiological standards are not placed on meat and poultry, it is unlikely that pathogen-contaminated products would be pro-actively condemned by the USDA. Currently, the USDA has no plans of introducing microbiological standards for raw meat and poultry products. The Department relies upon an informal policy regarding microbiological testing. A meat packer or processor may voluntarily request that the government condemn their meat for microbiological contamination. Meanwhile, the Food and Drug Administration prohibits the sale of Salmonella-contaminated turtles, frogs legs, and Siamese shrimp in interstate commerce. This federal policy conflict in which the sale of Salmonella-contaminated animal and fish products is prohibited by the FDA, while contaminated raw meat and poultry products destined for human consumption are allowed by the USDA to be transported and offered for sale, is irrational. USDA Responsibility Justifications of the Current Inspection System Industry representatives argue that the level of microbiological contamination in raw meat and poultry products is so pervasive that any broad-scale attempt at curbing food poisoning organisms could not be cost-effective. It is further posited that the cost of microbiological standards would be unreasonable to industry. Further, industry asserts that pathogens, especially Salmonella, are ubiquitous in breeding and slaughter environments: Any effort to control levels of bacteria would not meet the goal of "zero-tolerance" and is therefore futile. A representative from the Meatpackers Council in Canada defends industry's position: "It is not yet commercially possible to market some food in a condition that approaches the absence of pathogens. For example, most meats contain Salmonella at relatively high frequency and no immediate solution is in sight...[Microbiologists] have stated: ...Absolute absence (zero-tolerance) is a condition which can neither be attained by, nor verified by any practical means. It is a figment of the bacteriolgist's imagination...making increasingly difficult demands upon the manufacturer" (Holland, 1978). Not all of industry agrees. A representative of Swift & Company, a major meat processor and packer, believes that the zero-tolerance argument is poor. "The bacterium gains entrance to the food plant environment by some means, establishes itself, and multiplies as part of the normal flora. Once these sites are detected and corrections are made, it is possible to eliminate the organism. In some instances this might be more correctly stated as bringing the population of salmonellae under control to the point where it is not detectable. Salmonellae need not be ubiquitous in a food processing environment. There is a reason for the presence of salmonellae and the bacteria can usually be brought under control" (Tompkin, 1976). Many microbiologists also disagree. Using contaminated feed as an example, one prominent Canadian microbiologist notes, "I think one of the greatest injustices that has been done towards improving foods or feeds with respect to Salmonella is in the use of the words, 'zero tolerance' or 'freedom from.' When I made suggestions on the condemnation of some manufacturers because of contaminated feed, I specifically said, 'Contamination at a given probability level'...Without a given target, or probability level to aim at, some manufacturers will say we can't achieve zero tolerance. They use the zero tolerance issue to evade their responsibilities. "I think we should be a little stronger," he adds, "and we should say that because many manufacturers are able to produce competitively-priced feed concentrates free from Salmonella at a given level of probability, we should condemn those manufacturers of protein concentrates who aren't reducing Salmonella in feed to acceptable levels" (AAAP, 1983). Similar arguments for timely control and acceptable levels hold true not only for Salmonella, but for other pathogens as well. The Arguments for Change in the Inspection System Several studies have examined the lax inspection procedures, the reduction in the number of inspectors in meat and poultry plants, and the changes in rules which have further weakened the protection afforded by the USDA. However, since the inspection system is not designed to detect human pathogens unless they produce an observable lesion, the value of the entire inspection system is questionable. Pathogenic microorganisms often reside in the gastrointestinal tract and on external surfaces of animals. The bacteria causing food poisoning cannot be detected by usual organoleptic procedures (i.e., sight, smell, and touch) used during inspection. As a result, pathogens are not reasons for condemning meat and poultry. A National Academy of Science report notes, "The methods used in inspection are primarily those developed in Europe during the last part of the nineteenth century. They are highly focused on observation of gross lesions or abnormalities that would be direct indicators or markers of disease...Salmonella and Campylobacter are major causative agents of diseases transmissible through the consumption of meat and poultry products, but the report concludes that it is virtually impossible to detect these organisms with current inspection methods" (NRC, 1985a). A former Assistant Secretary of Agriculture believes, "If it has a horrible tumor on it, they will condemn it since they can see those things. But they are looking for the wrong things because virtually none of those diseases or tumors or lesions are transmittable to human beings. They make the chickens sick, but they won't make you sick. Salmonella will make you sick. The $350 million meat and poultry inspection program could be more useful if it looked for the bacteria retailers and consumers cannot see. "They [the industry] could improve the way they take feathers off the bird," she continues. "They could have a system that does not beat feces into the bird. The way the Department runs the program right now favors the [processor] who does not spend money or effort to produce clean chickens...The law is dumb. The law was written for a time which has passed" (WABC, 1986). Attempts to Make the Inspection Process More Cost-effective In recent years increased consumer demand for poultry, coupled with a reduction in funding, has caused the Department of Agriculture to adopt procedures that include fewer inspectors. The most recent change regarding inspection procedures was implemented in January of 1986; it reduced the number of inspectors from three to two on poultry slaughter lines while requiring the same production and output level of chickens. The very way chickens are inspected had already been changed for some plants in recent years from what was known as "Modified Traditional Inspection" (MTI) to "New Line Speed" (NELS). Plants with "good track records" are now inspected by NELS with the remainder still under the MTI system. Under the NELS |