# Presentation: 911625

## RISK MANAGEMENT

_**RISK MANAGEMENT**_
**Current**
**FSIS Activities**

- Daniel Engeljohn, Ph.D.
- Office of Policy and Program Development
- Food Safety and Inspection Service
- U. S. Department of Agriculture

- Listeria Summit - Washington, DC November 2002

## FSIS is the nation’s public health regulatory agency, housed in USDA, addressing meat, poultry, and egg products

***Risk Management***
- FSIS is the nation’s _***public***_*** ***_***health***_ regulatory agency, housed in USDA, addressing meat, poultry, and egg products
-  FSIS has the administrative responsibility for protecting consumers from harm and deceit associated with these products
-  FSIS operates under 3 statutes providing authority to inspect these products and to ensure that they are not ***adulterated*** or ***misbranded***:
-  **FMIA** - Federal Meat Inspection Act (enacted 1907)
-  **PPIA** - Processed Poultry Inspection Act (enacted 1957)
-  **EPIA** - Egg Products Inspection Act (enacted 1970)

- Listeria Summit - Washington, DC November 2002

## 1999 Reassessment

*** ******Risk Management***
- _1999 Reassessment_
**Compliance with the HACCP system regulations **(64 FR 28351, May 26, 1999)
-  Almost all plants responded by taking some action
-  A majority of plants addressed *Listeria monocytogenes* in the hazard analysis
-  Many plants deleted CCPs; handled in Sanitation SOPs
-  A very small proportion of plants used antimicrobial additives; one out of five plants addressed this use in their HACCP plan
-  Over two-thirds of the plants conducted environmental testing at least weekly
-  Less than two-thirds of the plants conducted product testing

- Listeria Summit - Washington, DC November 2002

**Notes:**
FR Notice on reassessment issued because FSIS believed that the findings from testing a range of RTE products and information from investigations of outbreaks of listeriosis constituted changes that could affect an establishment’s hazard analysis or alter the HACCP plan for affected products.

Reassessment had to occur within 30 days of publication of the FR Notice.

A May 18, 2000, evaluation report by FSIS reflected the findings of the effectiveness of the reassessment

Public Health Model:
Assessment
Assurance
Policy Development
Specific Goals and Strategy
Secure our food supply from intentional harm
Base policy decisions on science
Improve management of agency programs
Improve coordination with sister agencies
Engage in aggressive education programs 

## 2001 Proposed Rule

*** ******Risk Management***
- _2001 Proposed Rule_
**Performance Standards for the Production of Processed Meat and Poultry Products** (66 FR 12590, February 27, 2001)
-  Addressed control of *Listeria monocytogenes *either in:
-  _HACCP_ plan  (i.e., food safety hazard reasonably likely to occur after lethality treatment), **or**
-  _Sanitation SOPs_ by testing food contact surfaces (after lethality treatment but before final packaging) for *Listeria spp.* at a specified frequency
-  Testing used to verify that the Sanitation SOPs were effective
-  Results had to be available to FSIS for review
-  If a test result was positive, corrective actions had to include procedures to demonstrate that product was not adulterated* *

- Listeria Summit - Washington, DC November 2002

## Existing Directive

*** ******Risk Management***
- _Existing Directive_
-  10,240.2 – Microbial Sampling of RTE Products
-  Effective since January 24, 2001 (revision 1; amendment 1)
-  FSIS collects product sample if plant does not test:
-  One product/HACCP Plan/month, or
-  One product every 3 months and
-  Conducts on-going environmental tests (both food contact surface and non-food contact surface tests) for indicator organism
-  Conducts targeted product testing for *Listeria monocytogenes *when there is a positive result for *Listeria *spp. on a food contact surface

- Listeria Summit - Washington, DC November 2002

## Draft Directive

*** ******Risk Management***
- _Draft Directive_
-  10,240.3 – Microbial Sampling of RTE Products for the FSIS Verification Testing Program
-  Draft for comment available today on the FSIS website until December 2, 2002; effective December 9, 2002; FSIS focus:
-  Deli/hot dog products in large plants (high/medium risk)
-  Smaller plants with high volume, NRs, construction
-  FSIS will collect multiple product and environmental samples if plant does not:
-  Have a HACCP Plan, Sanitation SOP, or other prerequisite program that is scientifically-based, includes testing for *Listeria *monocytogenes or indicator organisms, or shares testing results

- Listeria Summit - Washington, DC November 2002

##  2002 FSIS Survey

*** ******Risk Management***
- _ __2002 FSIS Survey_
-  FSIS in-plant personnel in RTE operations producing deli/hot dog products
-  Unpeeled; peeled; whole; chopped/formed; sliced
-  Approximate production volume per shift; number of shifts; number of lines; number of production weeks; storage capacity (e.g., during hold/test)
-  Use of antimicrobial agent; validation support
-  Use of post-lethality treatment; validation support
-  On-going microbiological sampling program
-  Samples/week; action taken when indicator/pathogen found; frequency/intensity changes based on positive results; where program is addressed (HACCP Plan; Sanitation SOP; Other Prerequisite)

- Listeria Summit - Washington, DC November 2002

## 2003 Reassessment

*** ******Risk Management***
- _2003 Reassessment_
-  Annual adequacy determination of the HACCP Plan
-  Includes determining whether the hazard analysis has been affected by recent events.  Also, for RTE operations:
-  _Sanitation SOP_ – Plant must routinely evaluate the effectiveness of the procedures (for high/medium risk operations, FSIS will focus on environmental testing results as one measure of effectiveness)
-  _Prerequisite Program_ – Plant must document why a food safety hazard is not reasonably likely to occur and include the procedures and testing results it employs to ensure that the program is working (for high/medium risk operations, FSIS will focus on environmental testing results as one measure of effectiveness)

- Listeria Summit - Washington, DC November 2002

## 2003 Final Rule

*** ******Risk Management***
- _2003 Final Rule_
-  FSIS will be evaluating the effectiveness of the Directive
-  FSIS will be completing work on the FSIS risk assessment, addressing cost/benefit scenarios
-  FSIS will be publishing a science-based regulation
- _Stakeholder Input_
-  Today, FSIS is listening to stakeholders about feasible and effective measures to control *Listeria monocytogenes*:
-  _Dr. Randall Huffman_ will talk about practical considerations for controlling *Listeria monocytogenes*
-  _Dr. Payton Pruett_ will talk about the role of environmental and product testing
-  _Dr. Don Zink_ will talk about post-lethality treatments

- Listeria Summit - Washington, DC November 2002

## Contact Information

_**Contact Information**_

***DANIEL L. ENGELJOHN**** *
- Office of Policy and Program Development
- Food Safety and Inspection Service
- United States Department of Agriculture
- 300 12th St., S.W., Rm. #112, Washington, DC  20250-3700
- Office:	202-720-5627
- Fax:  	202-690-0486
- E-mail: 	daniel.engeljohn@fsis.usda.gov
- _Web-based Meat, Poultry, and Egg Policy Documents_
**http://www.fsis.usda.gov/OPPDE/rdad/publications.htm**

- Listeria Summit - Washington, DC November 2002