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Web Content Viewer (JSR 286)

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Web Content Viewer (JSR 286)

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Strategic Performance Working Group: Shiga Toxin-Producing E. coli Findings

The FSIS Strategic Performance Working Group (SPWG) conducted a series of meetings in 2014 to discuss how to better control STECs (Shiga toxin-producing E. coli) in FSIS-regulated beef products. FSIS has tracked E. coli O157:H7 illnesses associated with FSIS-regulated products through the FSIS All Illness Measure, and this tracking shows that the overall number of E. coli O157:H7 illnesses nationally has either plateaued or increased over the past 18 months (as reported by CDC’s FoodNet program). The SPWG’s goal with respect to STECs is to define a set of actions that would likely reduce contamination and thereby reduce STEC-related illnesses.

FSIS personnel from throughout the Agency participated in several meetings of the SPWG. In addition the Agency solicited the views of Agency employees from four Districts as well as an active blog discussion. The SPWG reviewed the information from these meetings and the blog. It concluded that improving sanitary dressing practices designed by industry and improving how FSIS in-plant personnel and Enforcement Investigations and Analysis Officer (EIAOs) understand and assess these practices were the most promising means of bringing down STEC levels.

This conclusion is supported by two additional findings. An analysis of FSIS data indicates that there is still uncertainty on how best to identify and document a systematic breakdown in sanitary dressing deficiencies at an establishment. Further training for field personnel will improve the Agency’s ability to understand the rate and types of sanitary dressing deficiencies that are common among FSIS-regulated establishments. Additionally, during a meeting with FSIS, a food safety official from New Zealand highlighted that country’s efforts to reduce pathogens in poultry products by standardizing and improving sanitary dressing procedures at the establishments that it regulates. The official stated that New Zealand had achieved a marked decrease in the levels of Campylobacter by focusing solely on sanitary dressing processes. While these efforts were focused on a different product class, it is likely that the same principles would be effective in reducing pathogens at FSIS regulated beef slaughter establishments.

Three District Offices (Des Moines, Dallas, and Denver) gave presentations at the third SPWG meeting that highlighted measures that they have employed to improve both inspection personnel’s and industry’s knowledge and understanding of sanitary dressing procedures. These Districts also discussed why these measures are working, and what FSIS can do better. After these presentations, the sanitary dressing training materials developed by the Des Moines District office were disseminated among FSIS personnel, giving them an opportunity to discuss how these materials could be incorporated into the Agency’s approach to STECs.

At the request of industry representatives the SPWG met with members of industry on July 28, 2014. The industry representatives stressed that FSIS should consider sanitary dressing issues from a systems perspective. They stressed that FSIS personnel may be focused on finding discrete insanitary events (e.g., plant employee failed to sanitize a knife or failed to trim contamination) rather than assessing whether multiple hurdles are in place to ensure that the resulting product is produced under sanitary conditions, and whether those hurdles are functioning effectively.They indicated that achieving true zero tolerance for sanitary dressing deficiencies is not practical, and that the entire food safety (HACCP) system is designed to handle occasional lapses in proper practices. Therefore, they suggested that FSIS should train its employees to consider the entire slaughter process when evaluating the impact of specific sanitary dressing deficiencies and differentiate between a single incident and a systems failure for sanitary dressing procedures. Industry also asked FSIS to emphasize employee awareness of their own hygiene and practices. FSIS personnel need to be aware when their actions may have an adverse impact on sanitary dressing, and the industry representatives suggested that the Agency should take steps to minimize such actions.

Recommendations

As a result of its consideration of the STEC issue, the SPWG has identified a number of actions involving sanitary dressing that should be taken by FSIS to reduce STEC contamination:

  1. Conduct Correlations: The Des Moines District sanitary dressing correlation has proved to be an effective tool to inform both FSIS personnel and industry on proper sanitary dressing practices. The Agency should use these materials as a foundation for a correlation program that can be implemented in all Districts. The final correlation program should focus on effective methods to assess sanitary dressing procedures and on how to look at information collected throughout the slaughter process to evaluate the entire process as a food safety system.

Milestones: Develop correlation program (Office of Field Operations (OFO), Office of Outreach and Employee Education and Training (OOEET), Office of Policy and Program Development (OPPD)); implement correlation in all Districts (OFO, OOEET).

  1. Perform Assessments: The Agency should create a process for assessing how FSIS personnel perform sanitary dressing verification. The Des Moines District has developed a model for such assessments. The District Manager sends an EIAO, or an Inspector-in-Charge (IIC) from a plant that is doing sanitary dressing well, or both (the correlation team), to another establishment to correlate with that in-plant team and observe how that establishment and the in-plant team at the establishment are implementing sanitary dressing procedures. The correlation team has an entrance and exit meeting with both the in-plant team and the plant management. At the exit meetings with the in-plant team and with the plant, the correlation team discusses its observations and identifies and discusses any vulnerabilities. Thus, the correlation team’s visit is of value to both the establishment and the in-plant team.

Milestones: Develop an assessment process for sanitary dressing (OFO, OOEET); develop a “train the trainer” program for personnel to facilitate using the assessment process in all Districts (OFO, OOEET, OPPD); implement the process in all Districts (OFO). In addition, consider adding a line item under mission support in the In-Plant Performance System (IPPS) tool that focuses on sanitary dressing procedures (OFO).

  1. Use photographs: Information gathered by the SPWG showed that the FSIS Notice concerning sanitary dressing in veal was well received by the in-plant inspection teams. This Notice contained photographs to illustrate the instructions on identifying deficiencies and on best practices for sanitary dressing. Therefore, it appears that it would be useful for the Agency to include photographs in all sanitary dressing directives to clearly illustrate how to perform and how to verify sanitary dressing. Additionally, there is material in the Des Moines sanitary dressing correlation that would be useful to include in these directives and the attachments. At this time, the Agency is planning to revise the FSIS beef sanitary dressing directive with significant input from the field. The revised directive should make clear how sanitary dressing deficiencies affect downstream processes, and how information from various points in the process (system) is interrelated.

Milestones: Revise sanitary dressing directive for beef (OPPD, OFO); include materials in the directive that illustrate common sanitary dressing deficiencies (OPPD, OFO).

  1. Issue Compliance Guidance: The SPWG noted that the Agency intends to provide additional information to industry about common sanitary dressing deficiencies. A revised Beef Slaughter Compliance Guidance will include photographs of common sanitary dressing deficiencies in beef slaughter and will explain how sanitary dressing should be performed. The development of the Compliance document will be highly collaborative among Offices within the Agency including (OPPD, OFO, OPACE) to ensure that the document effectively communicates how establishments meet requirements related to sanitary dressing. A major part of this effort should include communicating to industry the steps in the dressing process that are particularly challenging to implement in a sanitary manner.

    The Compliance Guidance ought to reflect the insights that the Districts provided in their presentations to the SPWG as well as common questions received from the field and industry through askFSIS. The Districts emphasized that certain factors contribute to an establishment’s success in performing sanitary dressing. The Districts found that the most important factor is the establishment’s willingness to take responsibility for sanitary dressing. The Compliance Guidance will emphasize that plant management should properly design its facility to avoid crowding, train its employees properly, take steps to ensure that animals coming into the plant are as clean as possible, and be committed to preventing contamination rather than merely trimming from the carcass after contamination incidents. Additionally the Guidance should reflect how establishments can incorporate information throughout their slaughter process, including sanitary dressing procedures, to evaluate their food safety system. The Guidance will include photographs to effectively convey proper sanitary dressing procedures to the industry.

Milestones: Develop and issue revised Beef Slaughter Compliance Guidance (OPPD, OFO, OPACE); assess impact of Compliance Guidance on industry (OFO, OPACE, OCIO).

  1. Develop and Provide Training: The SPWG recommends that the Agency develop new training for FSIS personnel on how to verify that sanitary dressing procedures are being implemented in an effective and appropriate manner by the establishment. The SPWG noted that the Agency is updating the sanitary dressing training materials for FSIS that are in AgLearn.

    In revising these training materials, the group intends to include a number of real-world scenarios that illustrate situations that are commonly encountered in the field. These scenarios will highlight common vulnerabilities seen in establishments, strategies on how to develop defensible regulatory actions, and information on how to interpret and use FSIS microbiological data to support documented failures in sanitary dressing. Similar materials will be located on InsideFSIS so that all FSIS personnel can review them. These materials, along with the Des Moines sanitary dressing correlation, should provide FSIS inspection personnel with robust training to ensure that they can effectively verify that sanitary dressing procedures are being implemented in an appropriate manner by the establishment. The training materials that are developed need to inform FSIS personnel about how to differentiate between isolated deviations by individual plant employees and a failure of the establishment’s food safety system.

    The SPWG recommends that the Agency develop a training component specifically for EIAOs to help them understand their role in assessing establishment of sanitary dressing performance, what they need to be looking for in observing establishment performance, and how they should go about making observations. The Agency ultimately may decide to provide this training throughout all field personnel possibly through webinars or other methods to efficiently disseminate training materials.

Milestones: Develop revised training materials for sanitary dressing and deploy using webinars and AgLearn (OOEET, OPPD, OFO, Office of Public Health Science (OPHS)); develop and post additional training material including common scenarios on InsideFSIS (OOEET, OPPD, OFO); present material at FSIS OFO correlation meetings (OFO,OOEET, OPPD); assess avenues to disseminate training materials throughout the Agency (OOEET, OPPD).

  1. Assess the Use of Indicator Bacteria to Assess Effectiveness of Sanitary Dressing: Additionally, the SPWG discussed whether indicator bacteria or pathogens could be identified whose presence and level at various points in the slaughter process could be used to assess the establishment’s success in maintaining sanitary control. One of the objectives of the Nationwide Beef and Veal Carcass Microbiological Baseline Survey being conducted by OPHS is to measure levels of indicator bacteria and pathogens at two points in the slaughter process, immediately after hide removal (and prior to any interventions) and as the carcass enters the hot box. OPHS intends to analyze the baseline data to assess its potential applicability for use in future guidance documents and risk assessments. These data may help establishments identify a baseline of indicator organisms that could be used in determining whether their sanitary dressing processes are adequate and in control. The Agency is exploring whether it can use the results of sampling that the United States Department of Agriculture’s Agriculture Marketing Service (USDA AMS) requires in plants that are under contract with that Agency as an additional source of data on how to measure sanitary control and for establishing a standard for assessing the adequacy of the establishment’s sanitary dressing procedures.

Milestones: Collect and analyze microbiological data from FSIS and other sources (such as AMS) as available (OPHS, OFO, ODIFP, USDA Agricultural Marketing Service (AMS)); identify trends, or levels of bacteria that indicate sanitary dressing deficiencies and possibly develop performance criteria of indicator organisms (OPHS, OFO, ODIFP, OPPD); incorporate findings into appropriate guidance, notices, directives (OPPD, OPHS, Office of Data Integration and Food Protection (ODIFP), OFO).

Revising the Directive and training on sanitary dressing, creating an assessment process for a plant’s sanitary dressing procedures/process, and a revised compliance guide will reinvigorate the Agency’s approach to sanitary dressing, which should lead to improved plant performance of this important activity. The SPWG thinks that these action items will improve industry’s understanding and implementation of proper sanitary dressing. The revised directive and training will improve FSIS personnel’s verification of sanitary dressing and lead to more effective enforcement strategies by the Agency. This, in turn, will ultimately lead to a reduction of STECs in FSIS regulated products and lower illness rates from beef products.

Last Modified Mar 12, 2015