On March 19, 2014, GFSF participated in USDA
Economists Group’s seminar about cost-benefit analyses for food safety-related
regulations in Washington, DC. The seminar was divided into 3 sections:
pathogen; mechanically tenderized beef products; and donning and doffing.
James Wilkus, an economist with the Office of Policy
and Program Development, FSIS / USDA, led the discussion about the role of
economics in pathogen control regulations. FSIS’s 2014 quarterly objectives are
E. coli, listeria, and, especially salmonella as there were 21,540; 897; and 413,965
illnesses, respectively, from 2007 to 2009 according to FoodNet. FSIS’ Public
Health Driven Program has designed salmonella verification sampling program for
raw product.
Considering impacts, producers would be categorized
into 3 establishments: large, small, very small, as with FSMA. The proposed
rule would impact them on new hires, training, and equipment modifications and
purchase. They would add inspection stations, dressing performance standards.
Talking about the economic impact, he showed an influence diagram of a new
inspection system for catfish.
From USDA FSIS office of Policy and Program Development
Click the picture to enlarge
The proposed rule would require resources, as the new
inspection system requires applications for inspection, labeling, marketing of
containers, sanitation standard operating procedures, testing, record keeping, government
office space and equipment.
Chinese exporters to the US, especially catfish
exporters, need to pay attention to the rule as China is one of the biggest
exporters of catfish to the US, and the new regulation would influence the
entire exporting process, from beginning to end.
Hazel Robinson, an economist with FSIS presented a proposed rule for mechanically tenderized beef products. The rule requires official establishments to label beef that was mechanically tenderized as such and to provide labels that contain cooking instructions, which if followed, would destroy any pathogens that may have been trans-located from the surface to the interior.
Hazel Robinson, an economist with FSIS presented a proposed rule for mechanically tenderized beef products. The rule requires official establishments to label beef that was mechanically tenderized as such and to provide labels that contain cooking instructions, which if followed, would destroy any pathogens that may have been trans-located from the surface to the interior.
Tenderization involved repeated penetration of the
muscle surface with blades or knives to disrupt muscle fibers and render the
muscle tenderer. The problem is that, the effect of the physical tenderization
process is not visible to the naked eye.
She said, “Without these labels, consumers and
retailers would not know that the beef was tenderized, and without instructions
may not cook meat so that pathogens are destroyed,” since it would move
pathogens on the surface of sub-primal cuts to beneath the surfaces.
The proposed rule would affect many industries, as
well as household consumers, retail consumers, and restaurants. There were 555 official
establishments that produced blade, needle, and both blade and needle
mechanically tenderized beef products in 2011, and a total of 176 patients who
became ill due to a mechanically tenderized product from 2000 to 2009. The proportion
of beef products that are mechanically tenderized is about 10 percent of total
the US production of beef.
The benefits of the proposed rule are the truthful and
accurate labeling of beef products, increased public awareness of product
identities, and better market information to consumers which could promote
better competition among establishments. In addition, adding cooking
instructions will make consumers aware how to cook a mechanically tenderized
beef product properly. Quantified expected benefits would be the reduction of
illness.
Non-quantified expected costs would include a minimal
cost to validate cooking instructions and costs associated with food service
providers that change their standard operating procedures related to intact and
mechanically tenderized beef products.
The proposed rule requires resources for labeling. The
estimated amount is about $1,162,000 if the rule is finalized. However, the
proposed rule would not have a significant economic impact on small or very
small entities as labeling cost is a one-time cost and they generally have a
smaller number of unique products, requiring smaller number of labels to be
modified.
The last presenter Flora Tsui, senior economist at
FSIS, discussed the analysis of donning and doffing measurement. The Donning
and Doffing Measurement regulation was finalized in November 2012. The goal is
to include donning, doffing, knife-sharpening, and walking time as working time
for slaughter industry. It would have little influence on food industry in
China.
GFSF has been striving to create food safety
e-courses, especially for the Chinese regulators, technicians and managers of good
companies. We are planning to provide a preview of some e-courses at the Global
Food Safety Forum summit in Beijing, which will be held on 14-15 June.