USDA's proposed changes to HACCP have many processors reeling

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USDA's proposed changes to HACCP have many processors reeling

 USDA's proposed changes to HACCP have many processors reeling.


D.C. FILE: While all eyes were on Congress -- as work began on the Child Nutrition Act reauthorization legislation and new bills such as the Meat Safety and Accountability Act were introduced -- USDA hit the meat processing industry with something more immediately pressing: proposed changes in its requirements for HACCP and prerequisite programs.

A March 19 letter to meat industry organizations from FSIS brought a decade of debate to a head over how processors validate their food safety intervention critical control points and the prerequisite programs they sometimes depend on in lieu of CCPs.

With just a month to respond to the proposed new rules (though that deadline was later extended to June 19), groups such as the American Association of Meat Processors and the North American Meat Processors Association went into high gear to galvanize their members over concerns the rules might be overly burdensome and costly for small and medium-sized processors.

"What they are asking is extremely disconcerting," says AAMP Executive Director Jay Wenther. "And it goes completely against the administration's 'know your farmer, know your food' initiative," which is meant to support small, local food producers.

At issue is how much is enough when it comes to proving that a CCP or a prerequisite program is working. But it's a hard case to make that new rules might cost too much or take too much time.

"What doesn't get measured doesn't get done," warns USDA Under Secretary for Food Safety Jerold Mande, who at a food safety conference in Washington compared the current push to reform food safety to that after Upton Sinclair's book "The Jungle" was published. Ouch.

It remains to be seen how the proposed rules will look in final form, but regardless, food safety expert and Kansas State Professor James Marsden warns that processors can soon expect their retail and foodservice customers to start asking for the same type of proof that their food safety practices are working.


Legal liability

Q+A: Attorney Shawn Stevens with Gass Weber Mullins LLC in Milwaukee has defended some of the nation's largest meat processors in the aftermath of a recall, often playing opposite foodborne illness lawyers like Bill Marler. Meatingplace asked Stevens this question:

What is your advice for a company that finds itself implicated in a foodborne illness case?

The instant a food company learns that its product may be associated with an emerging outbreak, it should directly engage federal, state and local health investigators. Proactive engagement is not only essential to help solve the immediate public health issue but, more importantly, to ensure that the investigation is conducted appropriately. Such oversight is critical for numerous reasons.

First, public health officials are increasingly being asked to investigate and solve a growing number of overlapping outbreaks at any given time. With limited resources to conduct investigations properly and methodically, we have found that federal and state investigators will sometimes prematurely adopt and embrace incorrect assumptions about the source of an outbreak.

And, whether explained by inadequate resources, limitations in time or a lack of individual expertise, once an incorrect hypothesis is embraced, it becomes very difficult for public health officials to admit possible errors, set aside potential bias and identify alternative sources.

Second, the level of proof necessary for FSIS to associate a product with an outbreak has been lowered in recent years. In the past, FSIS was unwilling to link any outbreak with a meat product until it had an epidemiological association and a positive sample from product (still in its original packaging).

Today, however, an epidemiological association alone is sufficient. Surprisingly, this is true even though experts would agree that association does not in all cases equal causation. Thus, although more and more outbreaks are being epidemiologically associated with presumed sources, the fact remains that many of these associations are not being adequately tested and confirmed before being announced to the public.

The moment any association is suspected, a food company should:

1. Actively engage public health officials to address their immediate questions and concerns.

2. Learn as much as possible about the status, scope and direction of the investigation.

3. Aggressively identify the full range of both potential cases and alternative sources.

4. Politely but forcibly challenge, where issues are identified, developing assumptions and hypotheses.

5. Persuasively demonstrate, where possible, that its product is not likely involved.

From our experience, investigators tend to be more open and, frankly, more thorough when all parties are actively engaged and at least someone -- even if only emblematically -- is looking over their shoulders.


Doors opening: The United States and Brazil have agreed to settle a dispute on U.S. cotton subsidies that includes the possible re-entry of Brazilian beef and pork products into the United States. Washington agreed to pay $147 million per year to assist Brazil's cotton growers while also initiating the removal of barriers on Brazilian beef and pork.

Doors still closed: While the United States and Japan agreed to continue discussions about Tokyo's import restrictions on U.S. beef, Japan Agriculture Minister Hirotaka Akamatsu was quoted in early April as saying he "has no plan to ask the government's food safety commission to review U.S. beef." Japan still limits imports of U.S. beef to product from cattle younger than 20 months of age.


Good sports

With the weather warming up and consumers heading outside to play, it's only fitting that many meat and poultry processors are using sporting events and venues to market their products.

Cargill is offering four different Schweigert brand hot dogs at the Minnesota Twins' new stadium, Target Field. One of the varieties, the pork and beef Original Twins Dog, is made from the same recipe as the franks served in the team's old Metropolitan Stadium.

Also stepping up to the plate is Chelsea, Mass.-based processor Kayem Foods, which is partnering with the Tampa Bay Rays to distribute Kayem hot dogs and sausages at Tropicana Field.

Meanwhile, Bubba Burger, the frozen burger produced by Jacksonville, Fla.-based Hickory Foods, went full speed ahead on a new NASCAR sponsorship. Bubba Burger is now the official burger of Virginia's Richmond International Raceway, and the April 30 NASCAR Nationwide Series race there was renamed the Bubba Burger 250.

ConAgra Foods meat snack brand Slim Jim pinned down an agreement to serve as the presenting sponsor of World Wrestling Entertainment's Wrestlemania XXVI and SummerSlam in addition to Slim Jim being the "Official Meat Snack of WWE." As part of the deal, WWE's Superstar Edge will act as Slim Jim's spokesman.

And outside the world of sports, but still all in good fun, Jack Link's is sponsoring the new official iPhone application for news satire publication the Onion. The Onion also will launch several new projects this year that are sponsored by the Minong, Wis.-based meat snack processor, including a dedicated Onion News Network video app and an "Eye On America" iTunes video playlist.

Says Jeff LeFever, director of marketing for Jack Link's Beef Jerky, "The untamed spirit that embodies the Jack Link's brand makes it a perfect match with the Onion."


Home to roost

If the impact of government-mandated increases in ethanol production on the meat industry wasn't clear a couple years ago when corn prices climbed over $7 per bushel, it is now.

Per capita consumption of all red meat and poultry dropped more than 10 pounds from its peak in 2006 (221.7 pounds) to 210.5 pounds in 2009 and, according to Jim Robb, director of the Livestock Marketing Information Center, will decrease by 1 percent in 2010, to 208.1 pounds -- the lowest annual per capita amount since 1997.

Robb notes that per capita consumption largely reflects industry output, whereas demand is not only what people eat but also what they're willing to pay for it. The problem, he says, is that both are going south.

Producers have cut output to boost prices, while consumers have adjusted their budgets during the recession. Meanwhile, production cuts in foreign countries mean fewer imports, and increased exports leave fewer supplies in the domestic market.

If that's not bad enough, say livestock economists Steve Meyer and Len Steiner, there are other considerations. They note that 85 million baby boomers are getting older and will be eating less meat. Plus, younger people increasingly are buying into initiatives such as "Meatless Mondays."

The solution, Robb says, is building demand via an increased focus on growing segments, such as Hispanics.


Protecting Ronald's honor

Almost as identifiable with McDonald's Corp. as those great big golden arches is the company's bright red-haired brand ambassador Ronald McDonald. So much so that the company's "Chief Happiness Officer" is now being targeted by Corporate Accountability International, a coalition of health professionals, parents and consumer advocates. The group wants McDonald's to give Ronald an early retirement as part of its efforts to diminish the company's influence on children during what they called a "fast-food-industry childhood obesity crisis." McDonald's is sticking up for its 50-year veteran, noting his commitment to charity work and teaching the importance of physical activity and balanced food choices.


Wal-Mart watch

Wal-Mart Stores Inc. said in late March groceries accounted for more than half of its U.S. sales in the fiscal year ended Jan. 31. The Bentonville, Ark.-based company reported that 51 percent of its revenues were generated by grocery sales, a 2 percent increase from the year-ago period. This is no small coincidence. Wal-Mart is making groceries -- and cheap prices on them -- the main draw for consumers increasingly discretionary about products they need versus product they want. To that end, the company recently launched a price rollback program for all of its groceries to woo consumers away from supermarkets.


Silver linings

The restaurant industry still doesn't lack for bad news, but there appear to be some silver linings amid the dark clouds. For example, according to foodservice consultancy Technomic's annual report on the 500 largest restaurant chains, McDonald's grew 2.9 percent, with sales estimated at $30.9 billion. Subway continued to dominate Technomic's "other sandwich" segment with 4.2 percent sales growth and total sales of $10 billion -- considerably better than the 0.8 percent growth posted by the other sandwich chains collectively.

It's not surprising, then, that both chains have been introducing new menu items recently. McDonald's Canada debuted McMini chicken sandwiches across that country in early April. And Subway jumped into the breakfast daypart at all of its U.S. and Canada locations, launching four Fresh Fit Egg White Muffin Melts -- including the Western Egg & Cheese made with black forest ham, red onions and green peppers.

Even the casual- and family-dining segments, among the industry's poorest performers, are trying new things. Outback Steakhouse -- known for decadent offerings -- debuted several entrées with fewer than 500 calories. And Denny's introduced a "$2 $4 $6 $8 Value Menu" to provide customers with affordable meals, such as a pulled barbecue chicken sandwich, throughout the day.

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