Testimony of the American Public Health Association

Concerning Food Safety and Microbial Contamination

Richard Levinson, MD, DPA

Presented to the Senate Committee on Agriculture, Nutrition and Forestry

September 20, 2000

9:00 AM

Testimony of the American Public Health Association

Concerning Food Safety and Microbial Contamination

Presented to the Senate Committee on Agriculture, Nutrition and Forestry

September 20, 2000

Mr. Chairman and members of the committee, my name is Richard Levinson. I am the Associate Executive Director of the American Public Health Association. APHA is the oldest and largest public health association in the world, representing more than 50,000 public health professionals in the United States and abroad. I appreciate this opportunity to discuss our members' views on the subject of the microbial safety of our food supply.

I plan to discuss surveillance and performance-based standards as effective public health tools generally, and specifically as they affect the microbial safety of foods.

Surveillance

The Merriam-Webster dictionary defines surveillance as "close watch kept over something." Public health surveillance is defined as the "ongoing, systematic collection, analysis, and interpretation of health-related data, essential to the planning, implementation and evaluation of public health practice, closely integrated with the timely dissemination of these data to those responsible for prevention and control." Public health surveillance has been conducted since at least the 1600's, when mortality statistics were first collected in England.

The global eradication of smallpox was an extraordinary public health achievement. It resulted not only from massive vaccination campaigns, but also from targeted campaigns that were based on an extensive global surveillance system. Even in remote and developing areas, cases of smallpox would not go unnoticed, but would be recognized, confirmed quickly and accurately, and followed with targeted vaccinations to stop further spread. We are nearing the global eradication of polio, again based upon an extraordinary, rapid and accurate surveillance system.

With increasing recognition of the role of microbial pathogens in foodborne illness, public and private-sector surveillance for foodborne pathogens has increased. In some cases, such as E. coli O157:H7 and Cyclospora, newly-emergent foodborne pathogens were discovered. In other cases, such as non-typhoidal Salmonella and Campylobacter, these pathogens were important decades earlier, but we weren't looking for them.

It has been said that testing food for pathogens doesn't make food safer. In a broad sense this is untrue. Microbial testing at appropriate Critical Control Points is essential to establish, and later to verify, the effectiveness of preventive measures and critical limits, ensuring that the entire process is producing a safe end product. People manage what they measure. Pathogen surveillance is an essential first step in pathogen control.

We have an outstanding new surveillance system for foodborne illness. The FoodNet system, a collaboration of USDA, CDC, FDA, and nine state health departments, allows us, for the first time, to know with some confidence both the burden of foodborne illness, and whether we are doing better or worse over time. And there is good news. For most of the foodborne pathogens under surveillance, the incidence of reported illness has declined just within the four years FoodNet has been in place.

Much of this progress can be attributed to the new HACCP system for meat and poultry inspection and, especially, the Salmonella performance standard. In the first two years under the Salmonella standard, the prevalence of Salmonella on meat and poultry products declined as much as 50% from baseline levels measured a few years earlier. It is unreasonable to feel that these declines are irrelevant, given parallel declines in rates of foodborne illness. It is also logical to believe that these reductions were achieved, at least in part, because we were looking for them.

Performance standards

Performance-based standards achieve the best balance of public and private intervention in public health. Regulating according to relevant outcomes is an efficient use of federal funds, and has been repeatedly mandated by Congress, as in the Clean Air and Clean Water Acts. It is not the best role of government to dictate how to keep pathogens out of the food supply, but rather to test and assure that products meet established standards.

Enforcing performance-based standards leaves technological innovation and creativity within the private sector, where it belongs. Food suppliers can incorporate interventions they feel are effective in meeting standards, whether before, during or after harvest or slaughter. For example, processors are free to negotiate voluntary microbial standards into purchasing contracts. In the first two years of the USDA's Salmonella compliance program, plants have met the standard 87% of the time.

APHA members submitted comments to USDA in support of the Salmonella performance standard when the HACCP/ Pathogen Reduction rule was first proposed. We believe that only mandatory and frequent end-product microbial sampling will prove that HACCP systems work and give consumers confidence that they are getting safe products. Microbial testing at appropriate Critical Control Points is essential to establish, and later, to verify, the effectiveness of preventive measures and critical limits, ensuring that the entire process is producing a safe end product. There is simply no other effective means by which to evaluate the efficacy of a HACCP plan in action.

APHA members support S. 823, The Fruit and Vegetable Safety Act, which would establish good manufacturing practices and process verification standards for processed fruits and vegetables. While APHA recognizes that the Food and Drug Administration and industry have taken important steps in developing guidance for producers of fresh fruits and vegetables, we think it is likely that a voluntary program provides an insufficient level of safety. Microbial foodborne illnesses have been linked to produce as well as meat and poultry. FDA should make the commitment to begin the process of developing microbial performance standards for these foods.

APHA supports the efforts of the USDA Agricultural Marketing Service to develop microbiological standards for their school lunch ground beef purchases. Just as industry must consider its source materials when developing Critical Control Points for microbial safety, government must also use the power of procurement contracts to assure the safety of foods in the federal feeding programs.

APHA recognizes that industry should have and use food safety tools that are technologically timely and appropriate. In 1998, APHA members endorsed the use of irradiation from electronic sources as a food safety intervention, and called upon USDA and FDA to support this technology, along with HACCP, good manufacturing practices, and consumer safe handling methods, in a coordinated public health education campaign.

APHA members are serious about performance-based standards. APHA is working with the Centers for Disease Control and Prevention, and with state and local public health partners, to develop measurements of public health performance. We believe that excellence in public health practice will follow from recognized, science-based standards. The National Public Health Performance Standards Program stresses three goals of performance measurement; improved quality and performance, accountability, and a better science base for public health practice.

The National Public Health Performance Standards Program (NPHPSP) is based on three basic principles: public health must be accountable to its constituencies; public health professionals need a system for ensuring that the provision of essential public health services meets a defined level of quality; and the public health decision-making process must be based on strong scientific evidence. Through a series of performance measurement tools, the NPHPSP will identify system strengths and weaknesses, provide policy makers with information necessary to implement effective health interventions, and assist decision makers in targeting resource investments.

This is one of the most significant events of my lifetime. It will be the main thing that will carry public health forward in the new century.

Mr. Chairman, this concludes my prepared remarks. I thank you for the opportunity to present our views to the Committee, and would be happy to answer any questions.