Remarks prepared for delivery by Dr. Richard Raymond, USDA Under Secretary for Food Safety, at the Listeria Control Input and Planning Workshop, September 26, 2006, Denver, Colorado.

Note: Slides are available in an attached PDF document (500kb); individual pages are linked within the text.

Introduction
(Slide 1)
Good afternoon. I appreciate this opportunity to talk about USDA's recent efforts to control and prevent foodborne illness with an audience that has such a range of food safety experience.

Before I go any further, I would like to congratulate the dedicated scientists who have been working to understand the transmission of Listeria monocytogenes (Lm) through ready-to-eat products from processing plant to consumer. This project complements USDA's Lm risk assessment and control final rule to help prevent listeriosis, which I will address today.

I noticed that three of the scientists on this project work for Colorado State University, and two work for the University of Nebraska. I'm happy to see that the Rams and the Huskers are represented today because my son is a student at Colorado State and my daughter attends Nebraska. [Comment on previous Saturday's football games.]

100 Years of Meat Inspection
(Slide 2)
This year marks the 100th anniversary of the passage of the Federal Meat Inspection Act, a watershed event in the history of food safety and public health in the United States.

In 1906, only 163 establishments were federally inspected. Today we inspect over 6,000. However, the scope of our activities is not the only thing that has changed since then. Our approach to food safety has evolved since 1906. We have taken on a much more comprehensive farm-to-table view.

People 100 years ago could not have dreamed that scientists would be studying a bacterium called Listeria. We have made tremendous progress in the fight against foodborne illness, but we still have a long way to go. That is why I take my job so seriously.

Office of Food Safety
(Slide 3)
As the Under Secretary for Food Safety, I oversee the Food Safety and Inspection Service, which carries out USDA's food safety regulatory program, as well as public health outreach and education activities focused on enhancing the safety of the U.S. food supply.

Our mission is to ensure the safety and wholesomeness of the nation's commercial supply of meat, poultry and egg products. It doesn't matter if those products are imported to, or exported from, the United States. Our efforts include protecting the food supply from both unintentional and intentional acts of contamination.

My position also means that I head up the U.S. delegation to the Codex Alimentarius Commission, the international body for food safety standards.

(Slide 4)
FSIS has more than 10,000 employees, approximately 7,700 of whom are inspection and veterinary personnel present daily in nearly 6,000 meat, poultry and egg product processing plants throughout the United States and its territories.

The products they inspect represent more than one-third of all consumer spending on food in the United States and about 40 percent of all domestic food production.

(Slide 5)
One of my most important tasks is to ensure that every one of our stakeholders plays a role in the creation and implementation of sensible, effective science-based policies.

(Slide 6)
Today's workshop and the Food Safety Education Conference starting tomorrow serve to as unique opportunities for government, academia, industry and consumers to share ideas about the future of food safety. We can do more together, cooperatively and collaboratively, than we could ever think of doing alone.

(Slide 7)
A collaborative approach doesn't mean that you're going to agree with every one of our policy decisions, but you'll be certain that your voice is heard, and that your views are considered.

And it guarantees that consumers can be confident that the products plants produce are the safest they can possibly be. They will know that public health and the safety of the food supply trumps all other issues when policies are made.

This approach is made possible by our reliance on the best available science to strengthen our food safety systems. Good science needs good data, and we are committed to both.

The Office of Food Safety remains dedicated to a collaborative science-based approach because we know that it works.

Food Safety Successes
The best indicators of this success are those that directly relate to pathogen reduction and public health outcomes.

(Slide 8)
The recent release of the 2005 data on the Incidence of Infection with Pathogens Transmitted Commonly through Food by the Centers for Disease Control and Prevention (CDC) clearly shows that the reductions in human illness from foodborne pathogens witnessed during the past few years have been dramatic.

Comparing human foodborne illness data from 2005 data with 1998 data, Listeria monocytogenes human illness rates are down 32 percent.

(Slide 9)
In particular, our testing for Listeria monocytogenes (Lm) in all ready-to-eat (RTE) products shows success in pathogen reduction. Compared to a decade ago, we have made substantial progress in Lm control.

Since 2000, the percentage of regulatory samples that tested positive for Lm has fallen by 56 percent so that in 2005 only 0.64 percent of regulatory samples taken were positive for this dangerous pathogen.

These numbers are a direct reflection of FSIS' science-based policies implemented in the past 12 years.

Listeria Control Efforts
One of these science-based policies was to implement new ways to detect and control Lm in RTE products.

(Slide 10)
USDA's 2003 interim final rule on control of Listeria monocytogenes in ready-to-eat (RTE) meat and poultry products, based on a thorough risk assessment, outlined three pathogen control strategies that an establishment could choose from, depending on its product(s) and the environment in which it operates. The first strategy provides for a combination of a post-lethality treatment and a growth-suppressing agent or process; the second strategy provides for either a post-lethality treatment or a growth-suppressing agent or process; and the third strategy relies on sanitation as the primary mitigation.

Since implementation of the interim final rule, 57 percent of establishments that were not already testing for Lm have now begun testing, 27 percent have initiated the use of an antimicrobial agent to inhibit the growth of this organism, and 17 percent started using post-lethality treatments.

(Slide 11)
In January 2005, FSIS revised its Listeria monocytogenes sampling verification procedures so that FSIS collects more product samples at establishments that rely solely on sanitation practices for Lm control, and collects fewer samples in establishments that have more aggressive process control measures and interventions. Thus, plants have an incentive to do more to control Lm.

(Slide 12)
Even in the wake of disaster, FSIS was fully committed to improving food safety. In response to Hurricane Katrina, FSIS implemented new measures to control foodborne illness in the affected areas. On September 20, 2005, FSIS began increased Salmonella testing of raw meat and poultry products in the affected areas of the Gulf Coast to provide microbial data to compare with nationwide data.

FSIS also trained additional non-field staff to assist in conducting intensified verification tests in ready-to-eat establishments for Listeria monocytogenes, including collecting food-contact surface and environmental samples, to supplement product sampling and food safety assessments. These provided an additional layer of microbial testing and verification to ensure the safety of the ready-to-eat meat products.

Risk-Based Systems
(Slide 13 and 14) The development and implementation of our Lm rule was an important component of our existing risk-based inspection system. However, FSIS must continue to develop the ability to act proactively. That's why we are laying the foundation for a more robust risk-based inspection system.

(Slide 15)
Our recent Salmonella initiative is also an important step toward a more robust risk-based inspection system. Salmonella is the number one cause of foodborne illness — 14.4/100,000 — 42,000 per year — reported only 500 deaths — all sources, not just poultry.

According to our sampling data, the number of product samples testing positive for Salmonella has been on the rise in several poultry categories over the past few years, specifically in young chicken (or broiler) carcasses — 16 %.

Our initiative to reduce Salmonella in meat and poultry products incorporates 11 steps, including increased sampling in plants where it's most needed and quarterly publication of nationwide Salmonella data by product class. Carrot and stick.

The specifics of this important 11-step plan can be found on FSIS' Web site at www.fsis.usda.gov.

Regardless of the type of foodborne pathogen we are fighting, our risk-based approach will be driven by data. FSIS is working to build a Public Health Data Infrastructure that will enable us to collect the data we need, analyze that data, detect potential problems, and redirect resources as necessary to protect public health. In short, we need to get the right data to the right people at the right time to make the right decisions.

We're after a common sense, cost-effective public health strategy that best serves the American consumer and the meat and poultry industry by preventing human illness.

To illustrate why we need to be more proactive, let me give you an example of an inspector who inspects three plants.

(Slide 16)
Plant A produces a high-risk product, for example, ground poultry. In addition, Plant A has a less than stellar food safety record with a long list of Noncompliance Records, or NRs, many of them very serious sanitation and hazard violations. It just had a recent customer complaint and was warned that it's likely to lose its grant of inspection unless it shapes up.

Plant B also produces ground poultry, but in this case, it's spic-and-span. From the top management to the newest line employee, everyone in this plant is dedicated to producing a safe product and it shows. The plant has gone for years with very few NRs. There have been no recalls or consumer complaints at this plant.

Now Plant C also has a record as spotless as the plant itself. This plant produces canned hams, a product with lower inherent risk.

So our inspector — we'll call her Anne — knows perfectly well from years of consistent experience with all three plants that every day B and C will pass inspections with flying colors. She also knows that Plant B, even though its record is as good as C, needs to be watched more closely because it produces a higher risk product, ground poultry.

On top of that, Anne knows that Plant A, which also produces ground poultry and has a bad inspection record, needs to be watched extra closely.

But right now she can't do that. She is forced to spend approximately the same amount of time and effort inspecting each plant, regardless of the level of risk that these plants pose to public health. So we're working to change that.

And of course, we're still going to go to each plant everyday. And each inspector's work shift will probably still be around eight hours long. But within that time, some plants will get a closer look than others.

This would allow FSIS to direct its resources and attention to those plants having difficulty meeting critical food safety standards.

Currently, FSIS' efforts are focused on developing an objective science-based measure that can meaningfully quantify how well potential risks are being controlled in FSIS-inspected processing establishments. We are also working on developing a science-based measure for the inherent risk in a product.

We'll couple these two to develop an algorithm that will tell us the risk for plant and product and allow us to concentrate resources, appropriately.

This measure is in the very early stages of its creation, so we don't know how exactly it will affect individual plants yet. However, we'll be sure to answer questions from stakeholders before any final decisions are made.

(Slide 17)
That's not to imply that FSIS doesn't have its own ideas about what should be measured and how. For example, we believe that any enhanced measurement of establishment risk control should differentiate between NRs that pose significant threats to food safety and those that don't.

Our goal is to create a measure that uses objective data from NRs, food safety assessments, microbiological testing, consumer feedback and other sources that can make similar differentiations to measure how well an establishment controls its inherent risk.

(Slide 18)
But the final product will be the result of input from employees, consumer groups, industry, academia and all of our other food safety stakeholders. I'm very serious when I say that everyone needs a seat at the table.

That's why Resolve Inc., a neutral third party was selected by FSIS, through a competitive bidding process, as recommended by the National Advisory Committee for Meat and Poultry Inspection (NACMPI). It will work in the coming months to gather and organize the wide range of views concerning what needs to be included.

Resolve is currently conducting interviews to gather stakeholder input. There is an upcoming NACMPI public meeting on October 10 and 11 in Washington, DC; and then this information will be integrated into a cohesive risk-based policy.

I encourage your input during these meetings, as it will be key to the development of a system that better protects public health.

Closing
I want to thank you again for inviting me here today. These are important issues that need to be talked about. We have a strong system in place, and that's due in large part to scientific experiments and studies such as this Listeria project.

But we have to continue to improve and enhance our nation's food safety system. This is something that we must accomplish together.

(Slide 19)
The state of public health is constantly evolving. We can't afford to let ourselves, our partners, or our nation's food safety systems stagnate. Standing still in public health is really just a polite way of saying that we're moving backward.

The bottom line is that we all have the same objectives — safe food and healthy people. We must never lose sight of these common goals.