Proposed rules about pathogens, mechanically tenderized beef products and donning and doffing

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.

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.