Although we currently have the safest food supply in history, we also have the highest level of expectation for food free from any risks. Food production and processing units are getting larger, which increases the risk of spreading a contaminant to more consumers. Changes in commercial products include new kinds of foods, many of which international in scope and may represent production, processing, packaging, and distribution methods that fail to meet domestic standards. More of our food dollars are spent in restaurants than ever before. In addition, increased public demand for heat and serve ready to eat foods raise new issues relative to potential pathogen transmission and growth. All together, these changes result in less personal control over our food sources, handling practices, storage, and preparation, and can impact its ultimate safety.

The Federal Government responded to highly publicized food borne disease outbreaks in the early 1990s with a national program to revamp the meat and poultry food inspection system. On January 27, 1997, the first phase of the new regulations went into effect at slaughtering and processing plants with more than 500 employees. In January 1998, medium sized plants, defined as those with 10 to 499 employees, will be required to implement the changes. In January 1999, small plants, defined as those with up to 9 employees and less than $2.5 million in annual sales, will complete the implementation.

Government estimates the new regulations will add about 1.2 cents per pound of meat and poultry during their initial implementation, and an additional 0.5 cents per pound to support the ongoing program.

The new regulations consist of three major components. First is a Hazard Analysis Critical Control Point (HACCP) plan designed by industry on a plant-by-plant basis, and requiring the approval by the Food Safety Inspection Service (FSIS) of USDA. Each plant is required to develop, adopt, and implement a HACCP plan for each of their processes. Plants identify critical control points during their processes where hazards such as microbial contamination can occur, establish controls to prevent or reduce those hazards, and maintain records documenting that the controls are working as intended. As a part of this process the plants are required to establish critical limits within each step, to monitor their procedures, to take any corrective actions necessary, to maintain records, and to develop systems to verify the HACCP process.

The second requirement is for Pathogen Reduction Performance Standards. FSIS will culture for the bacteria Salmonella, and require each plant to culture for generic E. Coli, to verify that meat and poultry plants are achieving acceptable levels of food safety performance. Results of Salmonella culturing will lead to standards for slaughter plants and processors that produce raw ground products. Generic E. coli testing is used to indicate fecal contamination during processing, which is the primary pathway for contamination of meat and poultry with bacteria such as E. coli 0157:H7, Salmonella, and Campylobacter.

The third requirement is for each plant to develop Plant Specific Standard Operating Procedures for Sanitation (SOP). These must describe the specific activities plant management has determined are necessary to maintain good sanitation and prevent direct product contamination. The SOP must specify the person(s) responsible for carrying out these activities. Daily records must be kept showing when procedures are accomplished and when corrective actions are taken. SOPs include antimicrobial treatments and carcass cooling procedures.

Foreign countries exporting meat and poultry to the United States must establish inspection systems requirements that are equivalent to U.S. requirements. State inspection systems must operate programs equal to the Federal program.

These regulations apply by law to all aspects of food production, slaughter, and processing. At this time, implementation is restricted to slaughter and processing plants and is not targeting on-farm practices. There currently exists insufficient information to determine if HACCP principles can be exported from a processing plant to live animal production units. As an example, the common fly can leave as many as 2,000 Salmonella bacteria behind each time it lands on an animal or other surface. The amount of pesticide necessary to eliminate all flies on a farm could represent a greater health risk to the animals and consumers of animal products than the presence of the fly-borne Salmonella. This is especially true when you consider that of the greater than 2,000 types of Salmonella recognized, only about a dozen are known to cause disease in animals or humans. Additional research is necessary to determine the optimum role for HACCP applications on the farm.

World wide microbial contaminants cause significant illness and death, and many are associated with food borne disease. We are lucky to live in a part of the world where the safety of our food is extremely high. An acceptable risk level from consuming food is difficult to define, for each of us has our own personal standards that apply. We may be willing, for example, to accept the risks associated with smoking but feel that food should be 100% safe. To help maintain our perspective let me offer this 1978 study on the risk of death associated with Salmonella contamination of food:

	Risk of Death Per 1 Million People	Odds Ratio Times Salmonella Risk
Salmonella	0.01	1
Automobile Accident	220	22000
Child Bearing (UK c.1970)	100	10000
Electrocution at Home (US 1978)	1	100
Lightning	0.6	60
Venomous Bites Snakes/Insects	0.2	20

E. coli 0157:H7 associated food borne disease seems to be an emerging issue, and has driven much of the activity for the change in regulations. This pathogen can cause human disease with relatively low exposure doses, especially in children. The reasons for this emergence are not completely clear, but could represent better detection methods, better reporting within the health sector, better reporting within the popular press, and/or more vendor prepared foods in larger batches that have the potential of amplifying a problem to more people.

A study done by FSIS from sampling ground beef for E. coli 0157:H7 demonstrates how infrequently it is found:

	10/17/94­ 09/30/95	10/01/95­ 09/30/96	10/11/96­ 03/16/97*
Federal Plants	2485	1657	343
Retail Stores	2740	3415	2392
State Plants	37	34	20
Imports	29	220	84
TOTAL	5291	5326	2839
Positives	3	4	0

*Partial year reported

The number of positive samples distributed between the reported sites was not reported in this information. Other surveys agree that E. coli 0157:H7 is rarely found in animals, is not associated with clinical disease in the animal host, and little is known about its ecology. These and other questions surrounding E. coli 0157:H7 need to be investigated to understand whether elimination is possible and practical on a production unit. We do not have to wait for all of these answers, though, because we know that adequate cooking will eliminate any danger associated with this organism.

We have the safest food supply in our history. We have, however, experienced well-publicized cases of food borne illness and death. Few would disagree with the statement that eating should not represent a potential death penalty. The question is how to find ways to share the responsibility for food safety between the producers, the processors, the distributors, those that participate in preparing our food, and the consumers.