Meat + Poultry - September 2010 - 18

Washington
BERNARD SHIRE
meatpoultry@sosland.com

Test-and-hold: Policy or Pandora's Box?
The new US Dept. of Agriculture
Food Safety and Inspection Service
policy requiring meat and poultry
plants to hold product being tested for
pathogens by the inspection agency
or the company itself may have some
surprising support - the small meat
and poultry processing industry, including the association representing
that industry, the American Association of Meat Processors.
"Depending how it is written and
imposed, it may not be such a bad
thing," says Dr. Jay Wenther, executive director. "AAMP has always promoted and supported holding tested
product. AAMP was one of the national trade associations involved in
developing the original test-and-hold
document (a best-practices document

The Federal Register notice on
withholding the stamp of inspection
on meat products until adulterant test
samples are returned with negative
results will have a 60-day comment
period when it is issued.
The decision by FSIS to change
its procedures and to withhold a determination as to whether meat and
poultry products are not adulterated until all test results are received,
was made due to a petition from the
American Meat Institute to FSIS.
Last October, AMI President J. Patrick Boyle urged Secretary of Agriculture Tom Vilsack to mandate 'testand-hold.' He noted more than 80
percent of the recalls due to the presence of E. coli O157:H7 and all recalls
due to Listeria monocytogenes last year
could have been
prevented if tested products had
been held until
cleared. USDA
comments and action is a positive
response to AMI 's petition.
There's no doubt recalls are eroding consumer confidence in meat
products produced in the US, so legislation and regulation are created to
resolve the issue.

"Depending on how it is written and
imposed, mandatory 'test-and-hold'
may not be such a bad thing."
developed by all the national meat
and poultry trade associations advising plants how to do test-and-hold)."
But Wenther is concerned this required FSIS policy could lead to a
continual chain of future mandatory
USDA requirements, posing difficulties for the meat and poultry industry.
During the recent summer meeting of the National Meat Association,
FSIS Assistant Administrator Kenneth Petersen announced, during the
next few months the agency would issue a Federal Register Notice about
the issue. Rosemary Mucklow, NMA's
director emeritus, says the inspection
agency will not put the mark of inspection on (meat or poultry) products
when a sample is being taken to test
for adulterants until there is a negative result. She said NMA has always
supported 'test-and-hold' for plants,
but is undecided if it would support
a mandatory requirement.
"We still have 'propose and comment' rulemaking, and I expect that
will continue," Mucklow said.

Fewer recalls will help
Wenther says while legislation and
regulation are not always the best
tools to work with when the meat
industry is so diverse, fewer recalls
are helpful to the entire meat industry regardless of size.
FSIS is taking action because the
inspection agency sees no other way to
solve the problem. While it would be
nice to think all establishments would
hold tested product, avoidable recalls
have continued, so all meat and poultry establishments are not voluntarily
holding tested product. Industry efforts to avoid recalls were bolstered
five years ago when eight national associations representing the industry
and the International HACCP Alli-

18 * Meat&Poultry * September 2010 * www.MeatPoultry.com

ance developed "Industry Best Practices for Holding Tested Products."
The document was helpful to plants,
large and small, because it provided
guidance beyond simply asking the industry to hold all tested product. FSIS
supported the documents.
Wenther believes the mandatory
FSIS requirement will cause problems for some plants that haven't
addressed the issue or don't hold
product being tested. Other establishments may have issues because
they produce short shelf-life product
and current micro testing takes an
extended amount of time. Storage or
the ability to fi ll orders may be issues
for some plants. But he also thinks
there is little reason for plants not to
hold product being tested. "Just-intime orders should be limited anyway...it takes good customer relations to communicate that you don't
do business that way. The concern is
over how plants will actually have to
control the product. Can the mark of
inspection be applied on pre-printed
labels or do you have to wait to package products? Again, it all depends
on how it is implemented," he says.
Industry is expected to make many
comments on the proposal once published. It hopes FSIS will review the
comments completely and make adjustments if unachievable expectations
are established. But concern exists
over USDA's continued movement
toward requiring more activities that
used to be done voluntarily. Wenther
agrees, saying it is happening with
food defense, as well as test-and-hold.
FSIS has stated if 90 percent of federally inspected plants don't establish
a food plan, the agency will move toward rulemaking. ■
Bernard Shire is M&P's Washington correspondent,
a contributing editor and a feature writer based in
Lancaster, Pa. Shire also works as a food safety
consultant and writer for Shire & Associates LLC.
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Meat + Poultry - September 2010

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