FSIS’ Strategic Performance Working Group (SPWG) said a correlation program, assessments on how sanitary dressing verification is performed, compliance guidance, training, photographs and the possible use of indicator bacteria.
E. coli O157 illnesses since 1998 have dropped by over 50%, but the most recent data (from 2013) shows a slight increase.
The six actions
SPWG said a correlation program should focus on methods to assess sanitary dressing procedures and on how to look at information from the slaughter process to evaluate the entire process as a food safety system.
The second point was for the agency to create a process for assessing how FSIS personnel perform sanitary dressing verification.
Photographs in all sanitary dressing directives would illustrate how to perform and verify, like the process in veal.
When issuing compliance guidance, the working group said a major part is communicating to industry steps in the dressing process that are particularly challenging to do a sanitary manner.
“The Compliance Guidance will emphasize that plant management should properly design its facility to avoid crowding, train its employees properly, take steps to ensure that animals coming into the plant are as clean as possible, and be committed to preventing contamination rather than merely trimming from the carcass after contamination incidents,” it said.
For developing and providing training, SPWG recommends training specifically for EIAOs to help them understand their role in assessing sanitary dressing performance, what they need to be looking for in observing performance, and how they should go about making observations.
The final action was the possibility of using indicator bacteria or pathogens to assess success in maintaining sanitary control.
The Office of Public Health Science (OPHS) is working on a survey on beef and veal carcasses after hide removal (and prior to any interventions) and as the carcass enters the hot box.
Ways to decrease STEC
SPWG said improving sanitary dressing practices designed by industry and how FSIS in-plant personnel and Enforcement Investigations and Analysis Officer (EIAOs) understand and assess these practices were the most promising means of bringing down STEC levels.
It said an analysis of FSIS data indicates there is uncertainty on how to identify and document a systematic breakdown in sanitary dressing deficiencies at a plant.
“Further training for field personnel will improve the agency’s ability to understand the rate and types of sanitary dressing deficiencies that are common among FSIS-regulated establishments.”
During a meeting with FSIS, a food safety official from New Zealand highlighted efforts to reduce pathogens in poultry products by standardizing and improving sanitary dressing procedures.
“The official stated that New Zealand had achieved a marked decrease in the levels of Campylobacter by focusing solely on sanitary dressing processes.
“While these efforts were focused on a different product class, it is likely that the same principles would be effective in reducing pathogens at FSIS regulated beef slaughter establishments.”
Industry believes sanitary dressing should be considered from a systems perspective.
It said FSIS personnel may be focused on finding discrete insanitary events (e.g., plant employee failed to sanitize a knife or failed to trim contamination) rather than assessing whether multiple hurdles are in place to ensure product is made under sanitary conditions, and whether the hurdles are functioning effectively.
During a meeting last year, industry representatives said achieving true zero tolerance for sanitary dressing deficiencies is not practical, and the food safety (HACCP) system is designed to handle occasional lapses in proper practices.
They suggested FSIS should train employees to consider the entire slaughter process when evaluating the impact of specific sanitary dressing deficiencies and differentiate between a single incident and a systems failure.