Foreign Spokesman Says Beef
Safety Efforts Miss Point

By David Bowser

HOUSTON — The meat safety system in the U.S. is in shambles, claims a New Zealand veterinarian, and because the U.S. sets the agenda, so are meat safety standards around the world.

In the simplest terms, he cautions, elaborate new safety efforts are being devised without a clear goal in mind. It's as if oldtime drovers threw a herd on the trail without deciding whether they wanted to end up in Denver, Dodge City or Independence.

"It is not overstating the case to say that we are in the midst of a global revolution in the field of food safety standards for beef," says Dr. Andrew McKenzie of the MAF Regulatory Authority, New Zealand Ministry of Agriculture and Fisheries. "Traditional approaches to meat hygiene as applied to all slaughter species are under attack, and the safety of beef production has been a major catalyst for both domestic and international debate."

Changes are due to the global focus on E. coli 0157:H7 contamination of ground beef, and the domestic and international trade implications of the United States' FSIS Pathogen Reduction HACCP Rule, McKenzie says.

Application of risk analysis will be the most dominant factor in future changes of global standards for beef safety, he says. It was the World Trade Organization Sanitary and Phytosanitary Agreement that provided sufficient impetus for all to recognize the importance of a risk-based approach.

Industry, regulators and consumers have different interests in different countries, and risk analysis is the single tool that can provide a transparent, objective platform for all groups to understand the basis for global meat hygiene standards, McKenzie explains.

The Codex Alimentarius Commission, the international agency responsible for food standards in international trade, has developed three components of food safety risk analysis: risk assessment, risk management, and risk communication.

Risk analysis includes scientific evaluation of the level of consumer protection afforded, enhancement of food safety, consideration of the cost-effectiveness of individual standards, farm-to-plate food safety strategy, effective risk communication, and an understanding of international obligations.

This can be expressed in quantitative or qualitative terms, and it is here that global harmonization is a critical issue.

Beef safety measures in a risk-based environment will often be different in different countries, he admits, but countries should strive for agreement on food safety outcomes. Most of the controversy surrounding beef safety standards comes from defining food safety outcomes.

"In the ideal situation, outcomes will be quantified in terms of risks to human health, and risk management decisions on an appropriate level of protection will dictate the nature and intensity of the hygiene measures to be applied," McKenzie says. "Unfortunately, quantitative risk estimates for different levels of hazards in most meat products are simply not available."

Risk management decisions will then involve subjective assessment of the differences in hazard levels of different hygiene measures.

"HACCP is now widely accepted as the food safety system of choice and has strong linkages to risk analysis," McKenzie notes.

Verification of the effectiveness of a HACCP plan should include a validation step that demonstrates that the hygiene measures chosen will achieve agreed food safety outcomes, he contends.

"Validation in these terms is not often included in the HACCP plans published to date," he warns.

Failure to state an intended food safety outcome and scientifically validate the overall effectiveness of the HACCP plan is a major shortcoming.

"A true food safety objective is not available, and international controversy has arisen over the strength of the linkages between achievement of the microbiological limits set for fresh beef carcasses in the United States, the actual level of control of pathogens at the time of consumption, and the resultant risks to human health," McKenzie says.

An FSO is a statement based on a risk analysis process which includes an expression of the level of a hazard in food that is tolerable in relation to an appropriate level of consumer protection.

In the fresh beef situation, FSOs can be developed from surveys, research data or ongoing monitoring programs. FSOs cannot be established from baseline surveys alone, and regulatory imposition of microbiological limits in the absence of a FSO is an inevitable lightning rod for debate.

"It is often the case that food control systems operating in an exporting country differ from those in an importing country," McKenzie says, "and recent international recognition of the legitimacy of diverse approaches led to the concept of equivalence becoming a core principle of the WTO SPS Agreement."

At a national level, HACCP has clarified the role of industry as having primary responsibility for food safety. Development of quality assurance-based systems audited by accredited third parties are also pioneering the privatization of inspection delivery.

New Zealand recently introduced legislation that allows involvement of accredited third parties in delivery of inspection services. Risk-based evaluation of standards and rationalization of meat inspection resources has resulted in a 40 percent reduction in government meat inspectors.

"After almost 100 years of gradual evolution in food safety control, radical changes such as these inevitably engender considerable resistance from consumers and trade organizations," McKenzie says. "This has been particularly noticeable in the United States, where increasing consumer concern over food-borne hazards has been fueled by perceptions of inadequate regulatory controls in a new, risk-based environment."

The public often views scientists with suspicion, yet demands the best science for risk estimates. Political success often depends on regulatory decisions conforming to widely-held perceptions of risk. Public perceptions of risk change slowly, and often remain persistent in the face of contrary evidence.

"Conflicting influences on scientific risk management are difficult to resolve," McKenzie warns. "The irony is that all stakeholders in the food chain want safe food, however, considerable differences in perception remain as to how this should be achieved. Therefore, regulators and industry must increasingly recognize the critical importance of effective risk communication, and consumer groups must increasingly realize the benefits of transparent and consultative risk management programs."

The requirements for a risk-based approach to developing international beef safety standards for these hazards are included in several general standards of the Codex Committee for Food Hygiene.

"New Zealand is particularly interested in developing a risk-based approach to beef process control," McKenzie says, and the national microbiological database has become an essential tool in the evolution of this approach. It provides a statistical monitor for demonstration of hygiene performance at both a premises and a national level, a framework for altering monitoring specifications according to prevailing food safety concerns, a means of validating HACCP plans on an ongoing basis and ensuring regulatory intervention when hygiene is deficient, a tool for epidemiological investigation of specific pathogens, and a reference system for regulatory and commercial assurances for purposes of market access."

Contemporary process control programs incorporating farm-to-plate strategies must also include consideration of pre-harvest controls, McKenzie says.

"It is generally acknowledged that different densities of microbial pathogens in gastrointestinal contents are likely to have a significant effect on subsequent contamination levels of fresh meat carcasses," he says.

General attention to livestock management, environmental hygiene and transport may limit the numbers of cattle shedding salmonella, however, specific interventions to significantly reduce infection with campylobacter, E. coli 0157:H7 and L. monocytogenes have yet to be identified.

"The United States Beef Industry Food Safety Council has already stated its commitment to addressing beef safety at a national level by strongly supporting research and science," McKenzie says. "The strategic plan focuses strongly on identifying measures to reduce contamination with E. coli 0157:H7 at several steps in the beef production chain, but it is noteworthy that the question of risk assessment is not mentioned. In the absence of data on predictive microbiology and risk, new beef safety standards based solely on reducing contamination rates at specific steps in the beef production chain may be of unknown value."

The industry must promote self-driven quality assurance systems that optimize hygiene practices and interventions, McKenzie insists.

"Regulatory agencies often have limited jurisdiction over different sectors of the beef production chain, and this can lead to restrictive, process-based safety standards that have little relevance to hazard levels at the point of consumption," he points out.

Industry initiatives must also be scientifically defensible. Lot testing of carcasses for E. coli 0157:H7 as a means of assuring food safety is not generally supportable on scientific grounds.

"Lessons in effective risk communication for meat-borne hazards are quickly emerging," McKenzie says. "If a potential hazard is perceived with concern by consumers, there should be strenuous attempts to ensure that standard setting is the result of a transparent and effective risk analysis process. Further, the integrity of alternative meat hygiene delivery systems should be openly debated with all stakeholder groups. These responsibilities primarily fall to governments and industry, and only in this way will the potential conflict between scientific and political risk management be reduced.

"Thus, industry's role in risk communication as it affects setting of safety standards includes investing in risk assessment and design of optimal safety systems, presenting all stakeholder groups at a national level with the outputs of such research, and participating in international standard setting via national Codex delegations."