Chapter Five THE VALUE OF STANDARDS AND A JUSTIFICATION FOR CHANGE Summary One better way of fulfilling government and industry responsibility would be through the introduction of microbiological standards -- statutory limits on the amount of pathogenic bacteria allowable by law on meat and poultry. In 1973, Oregon introduced microbiological standards for raw meat and poultry products. However, these legislatively imposed standards faced judicial challenge by the retail industry, and were thrown out by the court. Although the Oregon experiment did not succeed, it made clear that standards could be designed to successfully reduce the incidence of foodborne illness from meat and poultry contamination. This chapter also examines the progress made in Scandinavian countries toward eliminating foodborne illness by using microbiological criteria. These programs significantly reduced levels of bacteria in meat and poultry products. Finally, microbiological criteria for milk and whole eggs which the USDA has instituted with marked success, is reviewed. To date, however, the USDA remains steadfast against introducing microbiological standards for raw meat and poultry. Case History of Microbiological Standards for Meat and Poultry Oregon was the first and remains the only state to have statutorily addressed the correlation between raw meat and poultry products and foodborne illness. In 1973, legislation that introduced microbiological criteria was passed. Standards limiting the total number of bacteria per gram and E.coli levels of meat and poultry were introduced. Retail stores were subject to fines if the levels were exceeded. Within the first year, the retail industry challenged the Oregon standards in court, arguing that the burden of an industrywide problem was unfairly placed on stores. The retail industry argued that raw meat and poultry may be contaminated at slaughter and processing levels, before temperature and handling abuses can occur at the retail stage. The court repealed the legislation, and ruled that "bacterial standards on raw meats, as applied in Oregon were considered unjustifiable because they: a) could not accomplish what they purported to do, i.e, reduce public health hazards, b) were not technically feasible, i.e., were unattainable under the conditions of current good manufacturing practice in the industry, and c) were not administratively feasible" (Winslow, 1979). Although the intentions were good, there were several problems with the Oregon law: - In testing bacteria levels, the Aerobic Plate Count (APC) test was used. This test indicates total bacterial counts and does not distinguish between those which cause food poisoning, and those which do not, therefore limiting its effectiveness. - The E.coli level test, also part of the program, indicates overall sanitation levels rather than whether food poisoning will occur. - E.coli and other bacteria can be introduced to meat and poultry long before it reaches the retail stage. Laboratory tests for E.coli take approximately six days, by which time the food would likely be too old to sell. In short, using microbiological criteria after the raw meat and poultry products have been shipped to a retail store may, in light of current technology, have limited value. For such testing to be useful, more expedient laboratory procedures which could determine the levels and toxicity of pathogens in a shorter period of time must be developed. In determining the appropriateness of imposing microbial standards for pathogens on meat and poultry, an National Academy of Science (NAS) subcommittee developed a list of factors that should be considered. The factors include: 1. Evidence of a hazard to health based on epidemiologial data or hazard analysis. 2. The nature of the natural and commonly acquired microflora of the food and the ability of the food to support microbial growth. 3. The effect of processing on the microflora of the food. 4. The potential for microbial contamination and/or growth during processing, handling, storage, and distribution. 5. The category of consumers at risk. 6. The state in which food is distributed, e.g., frozen, refrigerated, heat processed, etc. 7. The potential for abuse at the consumer level. 8. The potential for spoilage. 9. The manner in which the food is prepared for ultimate consumption, i.e., heated or not. 10. The reliability of methods available to detect and/or quantify the microorganism and toxins of concern. 11. The costs/benefits associated with the application of criterion. (NRC, 1985b) Raw meat and poultry fit all of these conditions. The major hindrance in the imposition of microbiological standards on meat and poultry is that expedient and inexpensive testing procedures have yet to be developed. Currently, microbiological testing can take up to a week before final results are available. USDA Pathogen Control Programs for Milk and Eggs The USDA is responsible for the wholesomeness of fresh milk and eggs produced in the United States; two products which used to be important vehicles of foodborne pathogens. However, in the cases of milk and eggs, the USDA has successfully introduced programs incorporating microbiological standards in order to reduce the incidence of bacterial poisoning associated with these products. "Around the turn of the century, " notes a NAS Subcommittee report entitled An Evaluation of the Role of Microbiological Criteria for Foods and Food Ingredients, "The United States suffered devastating outbreaks of milkborne disease. Thousands of people contracted typhoid fever, brucellosis, tuberculosis, scarlet fever, diarrheal disease, and diptheria from commercial dairy products. Even as late as the mid-1920's, fifty to sixty people died every year in the United States from milk borne disease. Public health authorities and the dairy industry then imposed controls on milk production, developed safe and effective pasteurization procedure, and set sensible microbiological limits that ensured these measures. These policies changed milk from one of the most dangerous foods in the United States to one of the safest. How much of this can be attributed to microbiological criteria is not clear, but surely they helped." The reports adds, "The consumption of eggs and egg products have been an important cause of human salmonellosis. The percentage of outbreaks caused by eggs decreased dramatically after 1966...of great importance was enforcement of the Egg Products Inspection Act, as of July 1972, which eliminated human consumption of high-risk shell eggs... Furthermore, the Egg Products Inspection Act required that all egg products be pasteurized to render them free of Salmonella [emphasis added]" (NRC, 1985b). In the mid-1920's, the annual death rate from milkborne illness totalled about sixty lives and the federal government saw fit to address the problem by introducing microbiological criteria. Today an estimated 4,500 people die each year from food poisoning by contaminated meat and poultry. The USDA, however, has consistently opposed the introduction of microbiological standards for raw meat and poultry. Pathogen Control Programs in Europe Several European countries have set up successful pathogen control programs to address foodborne illness at its source. The programs are particularly notable, in that they focused on the wholesomeness of the animal feed, which, as has been noted, is a fundamental root of the problem. In Sweden, pathogen control measures were taken that required all imported rendered feed ingredients and domestically rendered products to be free of Salmonella. All breeders, hatchery supply flocks, and broiler production operations were affected. Similar programs were set up in Denmark and Finland. Unlike the Oregon initiative, "In none of these countries is laboratory control exercised at the process or retail level. Various surveys have indicated that the incidence of Samonella in poultry from these three countries is lower than in other parts of the world; less than 1% in Sweden, about 5% in Denmark and about 7% in Finland" (Siliker, 1982). As noted earlier, the USDA estimates that 37% of the chicken sold in the U.S. are contaminated with Salmonella. Scandinavian countries also made efforts to control Salmonella in other livestock. In Denmark, the incidence of Salmonella in pigs became much lower than in the United States or Canada. Regulations required that garbage and swill be rendered before it is fed to hogs. On the occasions when Salmonella was detected on live cattle, the animals were quarantined and treated until Salmonella-free (Siliker, 1982). Economic Justification for Change Increasingly, public funds are allocated on the basis of cost-benefit analyses. Because national surveillance regarding food poisoning is incomplete and the number of reported outbreaks are not accurate, an exact cost-benefit analysis is difficult to measure. However, based on available statistics, which are commonly acknowledged to be conservative, such analysis confirms that it would pay to take measures to prevent foodborne illness. Each year, over six million Americans suffer from foodborne illness and it is estimated that 9,000 people die annually. Foodborne illness costs consumers between one and ten billion dollars a year in lost wages and medical expenses. At least half of these cases and expenses relate to meat and poultry contamination. The millions of dollars spent on hospitalization, medicine, and lost productivity justify more than the $2.4 million the Department of Agriculture will spend on pathogen control research this year. Steps to reduce the extent of meat and poultry contamination are cost-effective in light of the expense of foodborne illness to consumers and the nation. Moreover, the experience with successful European programs indicate that stringent control measures are not economically prohibitive. The Swedish control programs for Salmonella in poultry cost no more than fifty cents per person annually in the 1970's (Todd, 1980). |