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R-CALF on HACCP

Sandhusker

Well-known member
Billings, Mont. – In a formal letter to Agriculture Secretary Tom Vilsack, R-CALF USA has recommended the U.S. Department of Agriculture’s (USDA’s) Food Safety and Inspection Service (FSIS) consider a fundamental revamp, or a complete abandonment, of its style of Hazard Analysis and Critical Control Points (HACCP) for an alternative meat inspection protocol.

Because of the almost constant increase of beef recalls due to E. coli, USDA has recently mandated increased microbial testing, but primarily at small downstream meat processors rather than primarily at large slaughter plants where contamination of meat by intestinal-borne pathogens (enteric pathogens) like E. coli actually occurs.

“…We are pleased the FSIS is admitting that substantial amounts of hazardous meat currently is shipped into commerce, in spite of the fact that the largest slaughter plants have now operated under HACCP for 12 years,” the letter states, in part. “We are dismayed, however, that the agency’s increased validation demands are being focused primarily against the processing plants further downstream, the vast majority of which totally depend on meat purchased from upstream, source-slaughter providers.

“…FSIS-style HACCP has resulted in ongoing outbreaks and recurring recalls, which the agency uses as justification for increased microbial testing because HACCP plants ship such a high volume of hazardous raw meat and poultry into commerce bearing the official USDA Mark of Inspection,” the letter also states.

Central to R-CALF USA’s food safety beliefs is that corrective actions must be implemented at the source-slaughtering plant (origin) of contaminated meat, rather than at destination plants, which essentially are powerless over the sanitation conditions at their source-slaughter providers. We are greatly concerned the agency’s increased focus will not only create budgetary concerns that will remove the majority of small plants from federal and state inspection, but also will simultaneously insulate the true source of contaminated meat from adequate agency oversight, virtually guaranteeing ongoing shipment of hazardous meat into commerce.

“The fact that FSIS strongly recommends the testing of incoming product constitutes an agency admission that the large source-slaughter plants continue to ship large amounts of contaminated/adulterated meat into commerce, (and) R-CALF USA believes the solution to this problem is to detect such meat at the slaughter plant of origin and require corrective actions at the source, not at the destination,” the letter states.

Current FSIS guidance will necessitate that plants essentially validate, via testing, not only its HACCP Plan, and all Pre-Requisite Plans, but also the multitude of specialty products, which are the unique niche products that attract consumers to products emanating from small facilities. In stark contrast, large slaughter plants primarily produce carcasses, trimmings, and boxed beef, necessitating only three areas to validate, at most. Small plants, with substantially less sales revenues and that are dependant on the manufacture and distribution of specialty items, will be burdened with enormous increases in microbial testing expenditures, which their revenues cannot sustain. The American Association of Meat Processors estimates the initial cost for the increased testing of ready-to-eat products by smaller plants at $12,000 per product line, and subsequently $3,600 per product line in future years.

R-CALF USA is concerned that small, inspected plants, which are vital to livestock producers across America, will quickly disappear, eliminating essential services needed by small, local producers. At the same time that President Obama and the U.S. Department of Agriculture (USDA) are advocating the “Know your Farmer, Know your Products” program, this agency mandate to increase microbial sampling will further separate consumers from producers because it will result in a lack of processing facilities required to process locally grown livestock. This policy will effectively undercut the stated goals of USDA and will result in an increased dependence on imported meat.

“R-CALF USA is concerned that while the agency’s mandate for increased microbial testing is focused as close to the consumer as possible (at the downstream plants), such testing is also focused as far away as possible from the source-slaughter plants, which are the origins of enteric bacteria,” said R-CALF USA HACCP Committee Chair John Munsell. “By FSIS admission, the largest plants constitute only 7 percent of all federally inspected plants, but produce 90 percent of our meat. We suggest that 90 percent or more of agency mandated microbial testing must be focused at the source, not the destination of meat products.”

R-CALF USA would be more willing to endorse this agency mandate for increased microbial testing if such testing would result in safer food. However, since the true origin of contamination with enteric pathogens continues to remain off the agency’s enforcement radar, increased testing costs would produce no benefits for public health, while effectively eviscerating America of its small plants.

“Lastly, R-CALF USA is greatly concerned that FSIS firmly believes our current HACCP system is so ineffective that the agency perceives that greatly increased microbial testing must be implemented for validation purposes, and agency demands for increased testing are symptomatic of an underlying danger, namely the ineffectiveness of FSIS-style HACCP,” the letter states. “R-CALF USA respectfully recommends a thorough overhaul of the agency’s current HACCP methodology.”
 

RobertMac

Well-known member
Finally, someone in a cattleman's organization sees the true cause of lack of profitability for cattlemen. The more avenues to access the consumer, the more profitable ALL producers will be.
Thank you John Munsell!!!!!!


Prediction: NBCA will be against increased testing/corrective actions on large packers because they will pass the cost back to producers!
 

flounder

Well-known member
Sandhusker said:
Billings, Mont. – In a formal letter to Agriculture Secretary Tom Vilsack, R-CALF USA has recommended the U.S. Department of Agriculture’s (USDA’s) Food Safety and Inspection Service (FSIS) consider a fundamental revamp, or a complete abandonment, of its style of Hazard Analysis and Critical Control Points (HACCP) for an alternative meat inspection protocol.

Because of the almost constant increase of beef recalls due to E. coli, USDA has recently mandated increased microbial testing, but primarily at small downstream meat processors rather than primarily at large slaughter plants where contamination of meat by intestinal-borne pathogens (enteric pathogens) like E. coli actually occurs.

“…We are pleased the FSIS is admitting that substantial amounts of hazardous meat currently is shipped into commerce, in spite of the fact that the largest slaughter plants have now operated under HACCP for 12 years,” the letter states, in part. “We are dismayed, however, that the agency’s increased validation demands are being focused primarily against the processing plants further downstream, the vast majority of which totally depend on meat purchased from upstream, source-slaughter providers.

“…FSIS-style HACCP has resulted in ongoing outbreaks and recurring recalls, which the agency uses as justification for increased microbial testing because HACCP plants ship such a high volume of hazardous raw meat and poultry into commerce bearing the official USDA Mark of Inspection,” the letter also states.

Central to R-CALF USA’s food safety beliefs is that corrective actions must be implemented at the source-slaughtering plant (origin) of contaminated meat, rather than at destination plants, which essentially are powerless over the sanitation conditions at their source-slaughter providers. We are greatly concerned the agency’s increased focus will not only create budgetary concerns that will remove the majority of small plants from federal and state inspection, but also will simultaneously insulate the true source of contaminated meat from adequate agency oversight, virtually guaranteeing ongoing shipment of hazardous meat into commerce.

“The fact that FSIS strongly recommends the testing of incoming product constitutes an agency admission that the large source-slaughter plants continue to ship large amounts of contaminated/adulterated meat into commerce, (and) R-CALF USA believes the solution to this problem is to detect such meat at the slaughter plant of origin and require corrective actions at the source, not at the destination,” the letter states.

Current FSIS guidance will necessitate that plants essentially validate, via testing, not only its HACCP Plan, and all Pre-Requisite Plans, but also the multitude of specialty products, which are the unique niche products that attract consumers to products emanating from small facilities. In stark contrast, large slaughter plants primarily produce carcasses, trimmings, and boxed beef, necessitating only three areas to validate, at most. Small plants, with substantially less sales revenues and that are dependant on the manufacture and distribution of specialty items, will be burdened with enormous increases in microbial testing expenditures, which their revenues cannot sustain. The American Association of Meat Processors estimates the initial cost for the increased testing of ready-to-eat products by smaller plants at $12,000 per product line, and subsequently $3,600 per product line in future years.

R-CALF USA is concerned that small, inspected plants, which are vital to livestock producers across America, will quickly disappear, eliminating essential services needed by small, local producers. At the same time that President Obama and the U.S. Department of Agriculture (USDA) are advocating the “Know your Farmer, Know your Products” program, this agency mandate to increase microbial sampling will further separate consumers from producers because it will result in a lack of processing facilities required to process locally grown livestock. This policy will effectively undercut the stated goals of USDA and will result in an increased dependence on imported meat.

“R-CALF USA is concerned that while the agency’s mandate for increased microbial testing is focused as close to the consumer as possible (at the downstream plants), such testing is also focused as far away as possible from the source-slaughter plants, which are the origins of enteric bacteria,” said R-CALF USA HACCP Committee Chair John Munsell. “By FSIS admission, the largest plants constitute only 7 percent of all federally inspected plants, but produce 90 percent of our meat. We suggest that 90 percent or more of agency mandated microbial testing must be focused at the source, not the destination of meat products.”

R-CALF USA would be more willing to endorse this agency mandate for increased microbial testing if such testing would result in safer food. However, since the true origin of contamination with enteric pathogens continues to remain off the agency’s enforcement radar, increased testing costs would produce no benefits for public health, while effectively eviscerating America of its small plants.

“Lastly, R-CALF USA is greatly concerned that FSIS firmly believes our current HACCP system is so ineffective that the agency perceives that greatly increased microbial testing must be implemented for validation purposes, and agency demands for increased testing are symptomatic of an underlying danger, namely the ineffectiveness of FSIS-style HACCP,” the letter states. “R-CALF USA respectfully recommends a thorough overhaul of the agency’s current HACCP methodology.”


amen there sandhusker, could not agree more...terry



From: Terry S. Singeltary Sr. [[email protected]]
Sent: Tuesday, July 29, 2003 1:03 PM
To: [email protected]
Cc: [email protected]; [email protected]; BSE-L

Subject: Docket No. 2003N-0312 Animal Feed Safety System [TSS SUBMISSION TO DOCKET 2003N-0312]

Greetings FDA,

my name is Terry S. Singeltary Sr., i lost my mother to hvCJD (Heidenhain Variant Creutzfeldt Jakob Disease).

i would kindly like to comment on the proposed HACCP method of detecting and or preventing TSEs in the human/animal feed supply.

it seems to me by implementing something that was designed for Astronauts instead of cattle, something that the GAO has already stated is terribly flawed (HACCP), i find it very disturbing to continue to insist on refusing to use rapid TSE TESTING in sufficient numbers to find TSEs, as with other Countries that they too once thought they were BSE free. for example, it took Italy 1 MILLION rapid TSE tests since 2001 to find 102 cases of BSE. THE USA has only tested 48,000 cattle in the 14 years of surveillance. there is documented proof that indeed the USA cattle have been infected with a TSE for decades, but the FDA/USDA and other USA Gov. agencies continue to conveniently ignore these findings. YOU must not ignore what Richard Marsh found. Plus, you must not ignore Asante/Collinge new findings that BSE transmission to the 129-methionine genotype can lead to an alternate phenotype that is indistinguishable from type 2 PrPSc, the commonest _sporadic_ CJD. The USA has been feeding ruminant by-products back to cattle, deer, elk and sheep for decades, and TSEs in these species have been recycled for feed for decades in the USA. The rendering process here in the USA will not kill this agent. to implement any HACCP over massive rapid TSE testing is only prolonging the inevitable, and will only allow the agent to spread further. it is simply a band-aid approach to something that needs a tourniquet...

3. Meat and Poultry: Better USDA Oversight and Enforcement of Safety

Rules Needed to Reduce Risk of Foodborne Illnesses. GAO-02-902, August 30.

FSIS Is Not Ensuring that Plants' HACCP Plans Meet Regulatory Requirements

snip...

According to FSIS's food safety systems correlation reviews, inspectors are not consistently identifying and documenting failures of plants' HACCP plans to meet regulatory requirements. Furthermore, FSIS does not expect its inspectors to determine whether HACCP plans are based on sound science--the cornerstone of an effective plan. While in-depth verification reviews examine the scientific aspects of HACCP plans, they have been conducted in very few plants, and consumer safety officers hired to review the scientific soundness of HACCP plans may take several years to assess the plans at all plants. Moreover, inspectors in 55 percent of the 5,000 plants nationwide did not document any HACCP violations during fiscal year 2001. When we brought this information to the attention of FSIS officials, they were surprised that so many plants had no HACCP violations for an entire year.

snip...

2. USDA believes that the title of the report is misleading. We disagree. We believe the title accurately reflects the concerns detailed throughout the body of the report.

snip...

http://www.gao.gov/cgi-bin/getrpt?GAO-02-902

http://www.gao.gov/new.items/rc00255.pdf

FDA acknowledges that it has not yet identified and inspected all firms subject to the ban” pg. 3 ;

http://www.gao.gov/new.items/d02183.pdf

The report concludes that “federal actions do not sufficiently ensure that all BSE-infected animals or products are kept out or that if BSE were found it would be detected promptly and not spread to other cattle through animal feed or enter the human food chain” italics added pg. 3 ;

http://www.gao.gov/new.items/d02183.pdf


snip...


http://www.fda.gov/ohrms/dockets/dockets/03n0312/03N-0312_emc-000001.txt


Wednesday, February 24, 2010
School Food Safety Program Based on Hazard Analysis and Critical Control Point Principles (HACCP); Approval of Information Collection Request
Sent: Wednesday, February 24, 2010 11:32 AM
Subject: School Food Safety Program Based on Hazard Analysis and Critical Control Point Principles (HACCP); Approval of Information Collection Request


http://downercattle.blogspot.com/2010/02/school-food-safety-program-based-on.html


Monday, April 5, 2010

Update on Feed Enforcement Activities to Limit the Spread of BSE April 5, 2010

http://madcowfeed.blogspot.com/2010/04/update-on-feed-enforcement-activities.html



Wednesday, March 31, 2010

Atypical BSE in Cattle / position: Post Doctoral Fellow

http://bse-atypical.blogspot.com/2010/03/atypical-bse-in-cattle-position-post.html



CJD TEXAS 38 YEAR OLD FEMALE WORKED SLAUGHTERING CATTLE EXPOSED TO BRAIN AND SPINAL CORD MATTER


http://cjdtexas.blogspot.com/2010/03/cjd-texas-38-year-old-female-worked.html


http://transmissiblespongiformencephalopathy.blogspot.com/



2009 UPDATE ON ALABAMA AND TEXAS MAD COWS 2005 and 2006

http://bse-atypical.blogspot.com/2006/08/bse-atypical-texas-and-alabama-update.html


Monday, April 12, 2010

Senator Kay Bailey Hutchison says NO to safer food and S. 510 FDA Food Safety Modernization Act of 2009


http://fdafailedus.blogspot.com/2010/04/senator-kay-bailey-hutchison-says-no-to.html




Terry S. Singeltary Sr. P.O. Box 42 Bacliff, Texas USA 77518
 

PORKER

Well-known member
FSIS strongly recommends the testing of incoming product constitutes an agency admission that the large source-slaughter plants continue to ship large amounts of contaminated/adulterated meat into commerce

Should have been doing this a long time ago!
 

RobertMac

Well-known member
PORKER said:
FSIS strongly recommends the testing of incoming product constitutes an agency admission that the large source-slaughter plants continue to ship large amounts of contaminated/adulterated meat into commerce

Should have been doing this a long time ago!
The problem...
Small plants (that have become dependent on cheap ground and boxed beef, pork and poultry from the large processors...by design) start testing AND finding tainted product from their supplier...they lose their supplier and get "blackballed" from the other few big suppliers. I think that is what is known as a "catch 22"!
FSIS need to do a better job at the big plants...where the problem is!!!!
 

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