Food Protection Trends - July 2008 - (Page 465)

is not an effective tool for monitoring CCPs within a slaughter/ processing HACCP plan. In addition, pathogens are often absent from a carcass and, when present, their uneven distribution makes it difficult to obtain a truly representative sample. In contrast, microbiological testing can be applied within a HACCP plan to validate and verify the effectiveness of carcass decontamination procedures. It is important to note that on-going verification activities are more accurately conducted to verify the effectiveness of the process that will control hazards rather than to verify the safety of the food product. That is, you want to know whether the control procedures are working, whether there are actually pathogens present or not. So why does the red meat industry spend a “gazillion” dollars sampling their end products for enteric pathogens every year? To ensure safety? I hope that is not what they are thinking, although I often get that impression from hearing comments that testing is the “last line of defense.” Sorry, testing is not an intervention. We have known for decades that testing will not ensure safety. I know consumers think testing is the best safety precaution, but as scientists, we know better. Now don’t get me wrong – I am not saying that we should not test food. I am simply saying that we need to test smarter. We need to spend our resources validating our critical control points to make sure they actually do what we say they do. We need to use testing to demonstrate the effectiveness of our HACCP plans and process control. We need to challenge our process control in innovative ways and make sure we are controlling the identified hazards. While validation and verification of HACCP systems may initially seem intimidating, careful thought and planning can make the process logical, reasonable and extremely helpful. Many tools are available to assist, such as rapid and sensitive microbiological tests, extensive publication of research results in the scientific literature and numerous HACCP experts. The human tendency is to find a single tool that works and use it to excess; however, successful validation and verification will most likely be attained through the efficient utilization of as many tools as possible. Continuous, regular challenging of the validity of a HACCP system through verification will only serve to strengthen confidence in the ability of the process to control hazards. So, I know exactly what some of you are thinking. If product testing is not the answer, why is it we sometimes detect the presence of a pathogen like E. coli O157:H7 in ground beef and thereby prevent its entry into the food supply? Isn’t that worthwhile? Step back, and view the situation with a broader perspective. Do you really think we are catching all of the lots of ground beef with low levels of O157:H7 that way? It is more likely that we are just randomly detecting the low-level presence of that pathogen through the haphazard selection of a contaminated sample unit. Other lots of ground beef with low levels of contamination probably proceed through to the consumer undetected. But we already knew that, right? That’s why we tell consumers to cook to 160°F. And how much time and money did we spend on negative samples to find that one positive? It sure would have been helpful to use those resources for validation of process control. Keep in mind, I am not trying to single out the red meat industry, it is just that I am most familiar with that process, and I don’t believe that we have sufficiently validated existing CCPs. I also believe that we could be further down that road except that, in our attempt to meet the demands of regulator y agencies and expectations of a well-meaning but misinformed consumer, we have wasted an enormous amount of time and money testing end products when we could have been improving process control. Here is the question I believe we should all be asking: If we occasionally detect the presence of enteric pathogens in ground beef, why are we not concerned that our process control could be better? Obviously, the critical control points that we have in place for slaughter/processing are not sufficient to prevent the presence of enteric pathogens in a raw product (if that is even possible), so our testing simply confirms what we already know. We can’t possibly be testing to ensure food safety, can we? If that is the case, it is a shame, because we have known that doesn’t work for a long time now. We need to put our resources, both intellectual and monetary, to work solving problems, not just continually detecting that we still have them. And that is what Advancing Food Safety Worldwide is all about. As always, please feel welcome to comment on any of my columns. I always enjoy hearing from you (gacuff@tamu.edu). JULY 2008 | FOOD PROTECTION TRENDS 465

Table of Contents Feed for the Digital Edition of Food Protection Trends - July 2008

Food Protection Trends - July 2008 Contents Sustaining Members Lone Star Perspective from Your President Commentary from the Executive Director An Integrated Assay for Rapid Detection of Escherichia coli O157:H7 on Beef Samples Listeria Prevention Practices for Small Cheese Operations New Members News Industry Products Award Winners Committee Meetings Ivan Parkin Lecture John H. Silliker Lecture Preliminary Program Networking Opportunities General Information Registration Form Workshops Exhibitors Special Contributors and Sponsors Coming Events Advertising Index Journal of Food Protection Table of Contents Audiovisual Library Order Form Booklet Order Form Membership Application

Food Protection Trends - July 2008

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