TESTIMONY OF MICHAEL P. DOYLE, PH.D.

DIRECTOR, CENTER for FOOD SAFETY and QUALITY ENHANCEMENT

UNIVERSITY OF GEORGIA

On behalf of

THE COUNCIL for AGRICULTURAL SCIENCE and TECHNOLOGY

(CAST)

Before the

U.S. SENATE

AGRICULTURE, NUTRITION and FORESTRY COMMITTEE

FULL COMMITTEE HEARING on FOOD SAFETY

WASHINGTON, D.C.

SEPTEMBER 20, 2000

Thank you Mr. Chairman and members of the Committee. I appreciate the invitation to present testimony for the Senate Committee on Agriculture, Nutrition and Forestry, especially as related to approaches to increase the microbiological safety of foods. I hope my testimony will be helpful in understanding the value of the Hazard Analysis and Critical Control Points (HACCP) approach to increasing the safety of foods, and in identifying changes needed in the food safety system to aid in the reduction of microbial contamination.

I am Michael P. Doyle, Director of the Center for Food Safety and Quality Enhancement at the University of Georgia. My primary professional experience has been focused on research for developing methods to detect and control foodborne bacterial pathogens at all levels of the food continuum, from farm to table. My primary involvement in the topics of interest to this committee include membership on the National Academy of Sciences, Institute of Medicine Committee to Ensure Safe Food from Production to Consumption; on the Council for Agricultural Science and Technology (CAST) Task Force on Food Pathogens: Risks and Consequences; on the National Advisory Committee on Microbiological Criteria for Foods; and on the International Commission on Microbiological Specifications for Foods. All of these groups have issued reports addressing approaches to improve the microbiological safety of foods.

I am testifying on behalf of CAST, which is a nonprofit consortium of 38 scientific societies representing more than 180,000 scientists and many individual, student, company, nonprofit, and associate society members. The mission of CAST is to identify food and fiber, environmental, and other agricultural issues and to interpret related scientific research information for legislators, regulators and the media for use in public policy decision making.

The information I shall provide largely has been extracted from three sources. These include: (1) the CAST report Foodborne Pathogens: Review of Recommendations, Special Publication No. 22, October 1998; (2) the CAST report Foodborne Pathogens: Risks and Consequences, Task Force Report No. 122, September 1994; and (3) the Institute of Medicine report Ensuring Safe Food from Production to Consumption, National Academy Press, 1998.

A large variety of microorganisms, having varied growth characteristics, unique niches in animals and processing facilities, and differing tolerances or sensitivities to food preservatives and processing treatments, are responsible for an estimated 76 million cases of foodborne illness annually in the United States. Considering the wide diversity in sources, tolerances, and growth properties of foodborne pathogens, there is no single process that can assure absolute safety of all foods and retain desirable eating characteristics. For this reason, a science-based systematic approach that identifies and assesses the microbiological hazards and risks associated with a food and incorporates effective treatments for their control was needed to effectively reduce the risk of foodborne illness. The HACCP system subsequently was developed to meet this need, largely through the efforts of the International Association of Microbiological Societies (IAMS) International Commission on Microbiological Specifications for Foods (ICMSF), and the U.S. Department of Agriculture (USDA) and U.S. Food and Drug Administration (FDA) National Advisory Committee on Microbiological Criteria for Food. The ICMSF is linked to the World Health Organization (WHO) and hence is a body of the United Nations. Many refinements and improvements of HACCP have been made since the HACCP concept was first introduced; however, the HACCP system is believed by the food safety community to be the best approach available, both nationally and internationally, for reducing the risk of foodborne illness. CAST recommends that HACCP principles be applied from farm or other production sources through consumption.

It should be recognized that HACCP is not a panacea. For example, it will not detect emerging hazards and no minimal level of safety is guaranteed. Furthermore, the HACCP approach is a dynamic process, and refinements and adjustments will continually need to be made as new foodborne hazards are detected and processes are modified. A major limitation to the adoption of HACCP by food processors is that small firms have minimal resources to develop, implement, and maintain effective HACCP plans. Progress is being made at this level but more resources may be needed to assist small processors in adopting the HACCP system.

Under current statutory and budgetary constraints, however, the benefits of HACCP systems cannot be fully realized. For example, current resources are inadequate to continue traditional inspection and to implement HACCP systems fully. A glaring defect in the present USDA meat and poultry inspection system is that substantial resources are directed to problems that do not have the greatest human health impact (for example, carcass-by-carcass organoleptic [primarily visual and odor detection] inspection of meat and poultry). The elimination of continuing inspection for meat and poultry would not necessarily end all ante- and postmortem inspections of carcasses if HACCP programs were appropriately developed and implemented. Such programs would have to include appropriate methods to identify diseased animals, which might require some level of carcass inspection as identified by hazard analysis.

An additional impediment to the application of HACCP to reduce the risk of foodborne illness is the failure of many segments of food production to adopt effective intervention strategies that could be used on the farm in a HACCP program. When practical and effective intervention strategies at the farm and on-site preharvest levels are made available, food producers should be provided resources where needed and should be required to use such strategies in the interest of enhancing public health. The importance of preharvest practices has been highlighted by several recent developments such as the increasing identification of fruits and vegetables causing U.S. outbreaks of foodborne illness, the specter of bovine spongiform encephalopathy in United Kingdom cattle and E. coli O157:H7 in U.S. cattle, and worldwide increases in bacterial resistance to antibiotics. Produce and animal preharvest practices are important opportunities for controlling or minimizing spread of foodborne pathogens. Attention should be given to development and implementation of practical and effective control strategies at the production level.

An overarching impediment to providing efficient and effective regulatory attention to microbiological food safety issues is the major statutory shortfall that exists for our current system. Specifically, there are inconsistent, uneven, and at times archaic food statutes that inhibit use of science-based decision-making in activities related to food safety. Also these statutes can be inconsistently interpreted and enforced among agencies. For example, the current directive embedded in statute (Meat Inspection Act, 1909; Poultry Products Inspection Act, 1957) requires each meat and poultry carcass to be subject to physical inspection. Although physical inspection may have been appropriate for the hazards present 70 years ago, the process impedes the Food Safety Inspection Service's (FSIS) efforts to allocate its substantial regulatory resources in ways that correspond to the health risks presented by contemporary sources of food or modern means of food production and processing; specifically, the implementation of HACCP-based inspection. In short, the hazards of greatest concern today are microbiological contamination and they are not readily detectable with the traditional inspection methods of sight, sound, odor, and touch. This regulatory statute impedes coherent, risk-based regulation to enable implementation of a more science-based inspection system now available to regulatory agencies.

Again, thank you Mr. Chairman for the opportunity to comment on this very important issue. I will be happy to answer any questions that you or members of the committee may have.

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The mission of the Council for Agricultural Science and Technology (CAST) is to identify food and fiber, environmental, and other agricultural issues and to interpret related scientific research information for legislators, regulators, and the media for use in public policy decision making.

Dr. Michael P. Doyle is Director of the Center for Food Safety and Quality Enhancement, University of Georgia, Griffin, Georgia, telephone: (770) 228-7284, fax: (770) 229-3216.

Council for Agricultural Science and Technology, 4420 West Lincoln Way, Ames, IA 50014-3447, USA. Phone: (515) 292-2125, fax: (515) 292-4512, E-mail: cast@cast-science.org, Web: www.cast-science.org.