1. Caroline Smith DeWaal Food Safety Director, CSPI Feb. 16, 2012 Tampa, Florida NATIONAL TURKEY FEDERATION ANNUAL CONVENTION

2.  Bi-national consumer advocacy organization founded in 1971 by Michael Jacobson, Ph.D.  Focuses on nutrition, health, and food safety  Publishes award-winning Nutrition Action Healthletter  Represents over 900,000 subscriber/ members in the U.S. and Canada CSPI: FOUR DECADES OF CONSUMER ADVOCACY

3.  New Poultry Inspection System (P.I.S.)  Emerging Pathogens  Performance Standards  FSMA  Safe Meat and Poultry Act  Outbreak Alert!: Results from 1999-2008 for the turkey industry CHARTING OUR COURSE 3

4.  Major overhaul of poultry inspection announced last month  Agency stresses that this is not HIMP…  Data on HIMP is less than definitive:  No thorough independent review since 2001  Testing data show some plants exceed the performance standards; others do not  Clear that the poultry inspection system needs updating:  Goals of new P.I.S:  Decrease risk of foodborne illness  Decrease expenses for government and industry  Focus FSIS inspectors on aspects most related to food safety  Worthy goals, but are these steps the right ones? NEW POULTRY INSPECTION SYSTEM

5.  Establishment must document plans to prevent:  Carcass contamination by enteric pathogens and fecal material, and to enforce zero tolerance for fecal contamination entering the chill tank.  Establishments must test to validate the effectiveness of those plans.  Establishments must maintain enhanced recordkeeping requirements to document that products meet the definition of ready-to-cook (RTC) poultry. Devil is in the details– some proposed ‘improvements’ need fleshing out before we will know how effective they’ll be. THE NEW P.I.S. IMPROVEMENTS

6. Mandatory elements (affecting all 289 poultry, non-ratite establishments):  New testing conducted by each facility but the adequacy of testing regime is unclear: no required frequency or target organisms  Removal of previous testing requirements for generic E. coli  Replacement of prescriptive time/temperature chilling with requirement for establishment-developed procedures  Aligned with HACCP, but Agency must review SIP waivers to determine effectiveness of alternative methods THE NEW P.I.S. WAIT-AND-SEE 6

7. Voluntary elements (affecting those establishments operating under the new P.I.S.):  Reassignment of carcass sorting activities from FSIS - inspector to the establishment  Who sets the standards for sorting? How much discretion do they have? Is there adequate training for sorters?  Line speed changes  Is “stopping the line” a real enforcement tool for inspectors? How frequently do they use it, and do they feel pressured to avoid doing so?  What is the line speed for the company sorter? THE NEW P.I.S. WAIT-AND-SEE

8. RECOGNIZING EMERGING PATHOGENS AND NEW VEHICLES  E. coli O104:H4 sprout outbreak in Europe, summer 2011  Over 4300 ill, 900+ HUS cases, approx. 50 deaths  S. Heidelberg outbreak in ground turkey in 2011  26 states, 136 ill, 37 hospitalizations, 1 death  Listeria monocytogenes cantaloupe outbreak in Colorado, fall 2011  At least 30 deaths  Ubiquitous, grows at refrigeration temperatures

9. ANTIMICROBIAL RESISTANT OUTBREAKS  Mostly Salmonella  Ground beef and unpasteurized dairy products most common sources  Ground turkey – 2 outbreaks in 2011, S. Hadar and S. Heidelberg  Ground beef – 7 outbreaks since 2002, S. Newport and S. Typhimurium

10.  The Food Safety Modernization Act passed Congress and was signed into law on January 4, 2011.  It is the beginning of a longer term effort to modernize the national food safety system.  The legislation has no specific impact on the meat and poultry industries, but there are elements to consider.  The provision on Performance Standards requires consultation with the Secretary of Agriculture to determine the most significant contaminants. MODERNIZING FOOD LAW IN THE UNITED STATES : PERFORMANCE STANDARDS

11. FSMA REQUIREMENTS FOR DEVELOPING PERFORMANCE STANDARDS New law requires FDA to take a number of steps in setting performance standards:  Determine the most significant foodborne contaminants  Emphasis on contaminants with robust public health data  Pathogen–food category pairing demonstrates the need for good attribution data  Set guidelines or regulations requiring industry controls by product or product classes  Re-evaluate list of significant contaminants every two years; periodically review guidance or regulations

12. If enacted, SMPA would:  Update food safety laws governing the meat and poultry industry to better protect public health through a more integrated food safety system.  Provide the Food Safety and Inspection Service at USDA with statutory direction on managing new and emerging pathogens.  Require FSIS to conduct a public health assessment to improve understanding of the risks associated with meat, poultry and egg products to inform public education and research efforts. SAFE MEAT & POULTRY ACT, S. 1529

13.  Under this provision, FSIS will have a clearly defined program for determining which pathogens pose the greatest risk to public health and establishing standards that reduce that risk.  A performance standard establishes the degree to which “a step or combination of steps in the production, processing, distribution, or preparation of a food must operate to achieve the required level of control over microbiological contamination.”  A statutory mandate would provide the industry with greater certainty regarding its responsibilities. PERFORMANCE STANDARDS UNDER SMPA

14. FSIS is required to:  Conduct a survey to determine current levels of food contamination.  Establish public health goals and objectives.  Define pathogen reduction performance standards that are sufficient to reduce pathogens in food and achieve public health goals and objectives.  To assure the effectiveness of the standards – they are reviewed every three years against the goals and availability of improved controls. PERFORMANCE STANDARDS

15.  The bill complements the recently passed FDA Food Safety Modernization Act; it would establish better targets for pathogen control, stronger surveillance for foodborne diseases, and new traceability and recall authority.  These steps will help reduce the risk of foodborne disease outbreaks, or provide faster detection and response if an outbreak occurs. HOW SMPA FITS WITH FSMA

16.  CSPI’s database uses outbreak information primarily from the CDC – only analyzing foodborne outbreaks with identified food sources and etiologies.  Between 1999 and 2008, CSPI analyzed 4,742 outbreaks, which caused 120,570 illnesses in the U.S.  The database is updated and reports are published regularly. OUTBREAK ALERT!

17. TURKEY OUTBREAK TRENDS ILLNESSES

18. TURKEY OUTBREAK TRENDS PATHOGENS

19. RELATIVE RATES OF ILLNESS 19

20. Illnesses per Billion Pounds Consumption 1999-2008 Yearly Average Illness Data from Outbreak Alert! Yearly Average Consumption (Billion lbs.) USDA ERS Data Illnesses/Billion lbs.Relative Rate: Beef103511.95878 Dairy62255.33111 Eggs3336.35525 Pork4918.07616 Produce278591.54303 Fruits46238.86121 Vegetables119551.79232 Seafood6343.1220318 Poultry128712.2810510 Turkey5122.6119618 Chicken8349.67868 CONSUMPTION AND ILLNESSES TURKEY VS. CHICKEN 20

21. Most commonly identified foods in CDC’s line-listing:  Turkey – 21  Roasted turkey – 21  Smoked turkey – 11  Baked turkey – 8  Deli meat, sliced turkey – 10  Sandwich, turkey – 25  Turkey, gravy – 8  Turkey, stuffing – 8 TURKEY PRODUCTS IMPLICATED

22. THANK YOU! Caroline Smith DeWaal Food Safety Director Center for Science in the Public Interest 1220 L St., NW Suite 300 Washington, DC 20005 Phone: (202) 777-8364 Fax: (202) 265-4954 E-mail: cdewaal@cspinet.orgcdewaal@cspinet.org On the internet: www.cspinet.org and www.safefoodinternational.orgwww.cspinet.org www.safefoodinternational.org