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Food Safety and
Inspection Service
United States Department of Agriculture
Washington, D.C. 20250-3700
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Draft Report
December 1999
The Future of FSIS Veterinarians:
Public Health Professionals For the 21st Century
This Draft Report represents the
work-in-progress of a Task Force composed of a diverse group of
individuals including veterinarians from inside and outside of FSIS, a
variety of FSIS management personnel, and individuals affiliated with
academe, non-government organizations and foreign governments, convened
in early 1999. A public meeting to discuss the Draft Report will be held
February 1, 2000, at the Washington Plaza Hotel, Washington, D.C.
Table of Contents
12/8/99
In 1999, the leadership of the Department of
Agriculture’s Food Safety and Inspection Service (FSIS) convened a
select panel of individuals charged with examining how veterinary
medicine, and the profession representing the art and the science of
veterinary medicine, should be utilized in food safety. This Blue Ribbon
Task Force was made up of a diverse group of individuals including
veterinarians from inside and outside of FSIS, a variety of FSIS
management personnel, and individuals affiliated with academe,
non-government organizations (NGOs) and foreign governments. The findings
and recommendations herein contained embody the collective thinking of all
perspectives represented on the Task Force. The Task Force met numerous
times through 1999 and has concluded its efforts in the following report.
The Task Force Members hope the reader will view their
findings as a fundamental work that establishes a considered baseline of
reasoning about the role of veterinarians in public and animal health, and
food safety that must be continuously reconsidered and reevaluated. The
role of the veterinarian as the purveyor of knowledge and expertise that
will act as the foundation for the bridge between agriculture and medicine
is paramount. Therefore the intent of this report is to fuel a renaissance
in thinking about how veterinary medical expertise is considered, but more
importantly how veterinary medical expertise is cultivated, nurtured, and
utilized.
The profession of veterinary medicine, and the
individual veterinarians representing the profession, are continually
evolving with the discovery of new knowledge. Therefore in the final
analysis the question will be how society is best served through the
sustained use of the appropriate knowledge and expertise available in
order to achieve the maximum safety in the food supply at a reasonable
cost. The following pages contain five issue areas that the Task Force
considered predominant for immediate consideration. The following
recommendations will require a complete recasting of how the veterinarian
is viewed inside and outside the Agency and even the individual
veterinarian’s view of him or her self will change. The suggested
changes are not without difficulty and will require great work and
diligence by leadership and the workforce. Nevertheless, hard labor
produces great results and the Department of Agriculture’s Food Safety
and Inspection Service of the 21st century will be born.
In 1996, the Food Safety and Inspection Service (FSIS)
issued the Pathogen Reduction; Hazard Analysis and Critical Control Point
(HACCP) Systems final rule to control and reduce pathogens (harmful
bacteria) on meat and poultry. Federal and State meat and poultry plants
must adopt HACCP, a system based on hazard prevention, with performance
standards set by FSIS. Effective implementation of HACCP by industry will
ensure safe food and should alter relationships with FSIS. Astute
utilization of veterinary resources will enhance farm-to-table food
safety. FSIS employees increasingly make science-based judgments that
impact a broad range of entities.
Despite major changes, many still perceive FSIS
veterinarians employed in the field as technicians rather than as public
health professionals. Their role remains unclear. To meet its mandate for
the 21st century, FSIS must better utilize the skills and talents of its
current veterinary workforce and enhance efforts to recruit and retain
highly qualified and motivated veterinarians in the future.
The Task Force developed recommendations around five
major issues, which are discussed in detail later in this report. The
issues are:
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DEFINING THE ROLE OF THE FSIS VETERINARIAN
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EDUCATION, TRAINING, RECOGNITION AND RECRUITMENT
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PARTNERSHIPS
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COORDINATED DATABASES AND ANIMAL IDENTIFICATION
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VETERINARY CONTRIBUTIONS TO INTERNATIONAL
CREDIBILITY OF FSIS
In 1996, the Food Safety and Inspection Service issued
the Pathogen Reduction; Hazard Analysis and Critical Control Point (HACCP)
Systems final rule to control and reduce pathogens (harmful bacteria) on
meat and poultry. Federal and State meat and poultry plants must adopt
HACCP, a system based on hazard prevention, with performance standards set
by FSIS.
The rule gives all FSIS employees a much greater role
in food safety and public health. FSIS employees increasingly make
science-based judgments. Previously, FSIS relied on prescriptive
regulations, using organoleptic (sight, smell, touch) inspection. In-plant
veterinarians were primarily limited to inspecting animals before and
after slaughter, detecting lesions, residue testing, supervising food
inspectors, and performing other procedural duties. While these functions
served the American public well, implementing HACCP and striving for
farm-to-table food safety provide new opportunities to utilize FSIS's
veterinary expertise to improve public health.
Despite major changes, many still perceive FSIS
veterinarians employed in the field as technicians rather than public
health professionals. Veterinarians have successfully filled most
scientific, technical and leadership positions in FSIS, yet their
contributions remain unrecognized and their future role remains
ill-defined. To meet its mandate for the 21st century, FSIS must better
utilize the skills and talents of its current veterinary workforce and
enhance efforts to recruit and retain highly qualified and motivated
veterinarians in the future.
FSIS veterinarians can enhance food safety from farm
to table by interacting more with other animal and human health
professionals, promoting interactive quality systems and better
information flow, integrating better scientific analysis of complex
information with improved performance, enhancing public health through
better use of resources, and making scientifically credible decisions.
The Food Safety and Inspection Service convened a Task
Force to look at The Future of FSIS Veterinarians: Public Health
Professionals For the 21st Century. The Task Force was
charged with developing recommendations on the roles of veterinarians in
meeting the Agency’s needs, particularly with the implementation of
HACCP systems and pathogen reduction requirements for meat and poultry.
Moreover, the Task Force planned to look beyond current statutory and
regulatory limitations to a visionary future. FSIS Administrator Tom Billy
asked the Task Force to focus on the following areas:
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Define how veterinarians can contribute to the
Agency’s vision of risk-free food.
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Identify the opportunities to best utilize the
FSIS veterinarians to optimize public health from farm to table.
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Assess the impact of HACCP on the duties and role
of veterinarians.
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Identify expertise needed by the Agency as it
relates to skills possessed by veterinarians.
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Define the international role of veterinarians,
and assess the implications within the international community.
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Identify potential uses of technology.
The Task Force has 23 members from FSIS (both
headquarters and field), other Federal and foreign agencies, associations,
and universities. It includes veterinarians and others who can help
identify the role of veterinarians in the context of Agency needs. The
Task Force Co-Chairs are Dale Boyle, DVM, Executive Vice President,
National Association of Federal Veterinarians, and Ronald Hicks, Deputy
Administrator, Office of Management, FSIS. A brief biography of each Task
Force member appears in Appendix B.
Government inspection of meat began in Europe,
supported mainly by physicians. In Germany between 1779 and 1819, Johann
Peter Frank, a pioneer in social medicine, emphasized the need for central
slaughter in public abattoirs with inspection of slaughter animals and
meat for zoonotic diseases by specially trained veterinarians. In Dresden,
Germany, Friedrich Kuchenmeister developed scientific meat inspection by
veterinarians.
In England, in 1862, veterinarian John Gamgee led a
commission which recommended a national system of specially trained
veterinarians to inspect meat sold in public trade. France, Austria and
Prussia also were developing meat inspection systems. By 1880 in England
and continental Europe, the role of veterinarians was being accepted by
physicians, demanded by society and implemented into law by politicians.
Robert Van Ostertag, the "Father of Veterinary Meat Inspection,"
developed a rigorous scientific inspection program in Berlin in the 1890s.
He wrote: "Veterinarians must do the important tasks of food hygiene
for public health."
In the colonial United States, raising livestock and
marketing meat was a local activity. Often, people grew their own food and
raised a few livestock. Consumers generally knew the source of their food.
Writings, but little action for safety inspection of meat from zoonotic
diseases (diseases communicable from animals to humans), appeared as early
as the 1600s. In 1642, a Boston city ordinance placed animal slaughter
under city control. In 1879, the Board of Health of Brooklyn appointed the
first veterinary inspector, Lachlan McLean, who advocated that
veterinarians be in charge of meat inspection.
By the mid-1800s, U.S. cities were growing.
Transportation systems developed and increased the distance between food
production and consumers. Meat was produced in large packing plants,
shipped in interstate commerce and exported to Europe. In the late 1800s,
England restricted importation of U.S. cattle for slaughter and several
European countries excluded U.S. pork because of Trichinella. In
1890, the U.S. enacted a law requiring veterinary inspection of live
animals for export and inspection of cured meat for both export and
interstate commerce. While the act was comprehensive, its application to
domestic trade was limited. However, the "Guide to Practical Meat
Inspection," written in 1900, stated that the act "opened the
way whereby the veterinarians are the profession appointed for this work.
Therefore the practice of meat inspection rests in the hands of
veterinarians." Specially-trained "stock inspectors" were
also authorized to be "to the veterinarian what the nurse or midwife
is to the physician." The act was amended in 1891 to establish the
Federal Meat Inspection Service as part of the Bureau of Animal Industry
in the U.S. Department of Agriculture, and to require antemortem (before
slaughter) and postmortem (after slaughter) inspection for meat for
export. The act was further strengthened in 1895, with stricter inspection
requirements for interstate transport of meat.
The Meat Inspection Act of 1906 signaled the real
beginning of domestic meat inspection in the United States. A year
earlier, Upton Sinclair published The Jungle, portraying unsanitary
conditions in Chicago slaughterhouses. The book caused a public and
political outcry. Meat sales around the country dropped nearly a third.
The 1906 Act began a system of continuous veterinary inspection in
slaughterhouses. It called for mandatory inspection of all meat and meat
products moving in interstate commerce. It required antemortem and
postmortem inspection of cattle, hogs, sheep, and goats. It established
sanitary standards for slaughter and processing facilities. The inspection
workforce in packing plants became teams of inspectors specifically
trained to separate abnormal animals at antemortem and abnormal carcasses
at postmortem. Veterinarians with advanced training in inspection further
examined the separated animals and carcasses and made final dispositions.
Veterinarians also collected tissues for laboratory examination, prepared
records and submitted reports. This model has been continued in the United
States through subsequent meat and poultry acts.
At that time, there were 163 plants under Federal
inspection; there are now over 6,000. In 1927, Congress created the agency
that later became the Food and Drug Administration (FDA). FDA remained in
the Department of Agriculture until 1940. The FDA has authority for all
foods not covered by the Meat and Poultry Products Inspection Acts.
The first attempts at poultry inspection began in
1926. Until then, many consumers bought their poultry from farmers or
markets, either live or "New York dressed" with only the blood
and feathers removed. Consumers eviscerated poultry just before cooking.
Voluntary poultry inspection began in 1926, with canning plants seeking
most of the inspection. By the 1930s, the industry produced ready-to-cook
poultry. World War II increased demand for poultry products. The military
had its own specifications and required either its Veterinary Corps or
USDA to inspect all poultry products consumed by the armed forces.
Congress conducted many hearings on poultry inspection and in 1957 passed
the Poultry Products Inspection Act, which established mandatory
antemortem and postmortem inspection of poultry entering interstate
commerce and mandatory inspection of slaughter and processing facilities.
The major revisions in the slaughter and inspection of
meat and poultry were established in the Humane Slaughter Act of 1958, the
Wholesome Meat Act of 1967, the Wholesome Poultry Products Act of 1968,
and the Humane Methods of Slaughter Act in 1978. These laws, which placed
direction of local humane slaughter and inspection operations under
veterinarians, are in force today. They set standards and requirements for
commercial slaughter and processing plants operating under either Federal
or State inspection.
Public health in the United States changed
significantly since the first meat inspection acts. At that time, the
leading cause of human illness and death was infectious disease. Today,
chronic diseases such as cancer and cardiovascular disease cause more
deaths. Microbiological hazards remain a significant risk to human health
via the food supply. Chemical and physical hazards must also be
effectively controlled and are of particular concern to certain
international trading partners. There is also a growing concern and
controversy about the use of antimicrobials in animal feed and in
treatment of animals and the transfer of antimicrobial resistance by these
pathogens in the food supply and the effectiveness of on-farm controls.
From the beginning of the 20th Century,
USDA inspectors have relied primarily upon organoleptic examination of
products, equipment, and facilities to detect and correct food safety
problems and to conduct other consumer protection activities, first in
meat plants and later in poultry plants. At the beginning of the century,
diseased animals were an important human health risk. Today, most animals
are slaughtered in large automated facilities which specialize in younger,
healthier, and more uniform animals, with few diseases that constitute
foodborne threats to humans. Cull animals generally go to specialized
plants where veterinary disposition still plays an important role in
preventing pathology and drug residues from entering the human food
supply. Today, most meat-related foodborne disease outbreaks trace back to
animals or birds free from signs or symptoms of disease. Invisible
microbiological hazards are the greatest risks to human health.
Animal health has changed as well. Many infectious
animal diseases are now controlled. Animal health improvements have
increased animal production. More animals are slaughtered at a younger
age. Animals and birds are produced more efficiently with the help of
growth promotants and genetic manipulations. Modern production practices
will continuously evolve in order to survive in the world market place.
Studies by the National Academy of Sciences (NAS), the
U.S. General Accounting Office (GAO), and FSIS itself have established the
need to fundamentally change the FSIS inspection program. The studies have
consistently recommended that the Agency reduce its reliance on
organoleptic inspection of individual animals for food safety, shift to
prevention-oriented process control inspection systems based on risk
assessment, and redeploy its resources in a manner that better protects
the public from foodborne diseases. Outbreaks of microbial foodborne
illness caused by Salmonella, E. coli O157:H7, Campylobacter
and Listeria and recalls of unsafe meat and poultry over the last
several years have reinforced the need for a more effective food safety
regulatory system, based upon the best science available.
The Pathogen Reduction; Hazard Analysis and Critical
Control Point (HACCP) Systems Final Rule was published July 1996. The new
law fundamentally changed the way FSIS approached its mission and required
a major cultural shift by all Agency employees. The rule states the FSIS
goal:
FSIS believes its food safety goal should be to reduce
the risk of foodborne illness associated with the consumption of meat and
poultry products to the maximum extent possible by ensuring that
appropriate and feasible measures are taken at each step in the food
production process where hazards can enter and where procedures and
technologies exist or can be developed to prevent the hazard or reduce the
likelihood it will occur.
The Agency has targeted a 25% reduction in foodborne
illness attributed to meat and poultry by the end of the year 2000. FSIS
is redeploying its resources to reduce foodborne illness and to provide
regulatory oversight within its statutory authorities along the
farm-to-table continuum. For instance, FSIS envisions intensifying its
food regulatory activities, within its statutory authorities, to address
safety hazards and other consumer protection as product moves out of the
plant and is transported, stored, and distributed to consumers.
WHAT VETERINARIANS BRING TO THE FOOD
SAFETY TABLE
Veterinarians bring a broad combination of knowledge
and skills to the interdisciplinary farm-to-table public health team. To
obtain a Doctor of Veterinary Medicine (or Veterinary Medical Doctor)
degree in the U. S., they usually complete four years of pre-veterinary
and four years of veterinary college education. Their education includes
extensive clinical practice in diagnosing diseases in seven major animal
species. Their education includes extensive knowledge of microbiological,
chemical and physical health hazards of food animals. Upon graduation,
Doctors of Veterinary Medicine have the basic foundation for building
advanced public health and preventive medicine skills in risk assessment,
management and communication, and in human and animal population
epidemiology and statistical evaluation. Many veterinarians also have
advanced degrees such as a Master of Public Health, Master of Science,
PhD, or Master of Business Administration. They often take post graduate
training to qualify for Board Certification in Veterinary Preventive
Medicine, Pathology, Microbiology, Toxicology and other specialties.
Graduates of foreign veterinary colleges must be a U.S. citizen, and pass
an English proficiency examination and the U.S. National Board for Foreign
Graduates to be employed by FSIS.
Doctors of Veterinary Medicine bring critical skills
to ensuring the safety of foods of animal origin:
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Veterinarians are the predominant
internationally recognized authority to audit and inspect foreign
establishments that export animal foods to the United States. They
assess the safety of animal products from foreign sources, including
freedom from unsafe levels of chemical residues, exotic pathogens and
emerging agents of public health importance. Veterinarians are
recognized internationally for possessing the scientific competence
and integrity to sign certification for animal products attesting that
the products were produced within a system of controls which meet both
food safety and disease freedom requirements of importing countries.
They help ensure public and international confidence in the safety of
the animal-based food supply.
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Veterinarians have an in-depth
understanding of production practices and animal disease and the
linkages between them. They can identify and scientifically evaluate
the potential human and/or animal health significance of the wide
variety of clinical signs in animals submitted for slaughter (antemortem
inspection). These skills help veterinarians make individual animal
disposition judgments and target animals that may need more intensive
inspection and/or diagnostic work. Examples include: (1) surveillance
for exotic or notifiable diseases (e.g. bovine spongiform
encepholopathy, brucellosis and tuberculosis); (2) monitoring for
disease or physiological states which can increase the potential for,
or significance of, contamination occurring during processing (e.g.
severely stressed animals tend to be high shedders of Salmonella);
(3) assessing suitability for entering slaughter of non-ambulatory
animals (downer animals), injured animals or animals approaching
parturition (about to give birth), and then examining them after
slaughter; (4) checking for signs indicating likely recent drug
treatment or exposure to contaminants; and (5) monitoring for disease
or physiological states which make the animals unsuitable for
slaughter for human consumption (e.g. septicemia, toxemia etc); humane
slaughter oversight. While other specialists may be able to evaluate
animals as "normal" or "not normal," a
veterinarian should make a specific diagnosis and interpret the
significance of the findings. This information is increasingly
important in ensuring reliability of producer and processor quality
assurance programs in the farm-to-table continuum.
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Veterinarians have knowledge and
experience in pathology, microbiology and toxicology to evaluate human
health hazards during the slaughtering process (at postmortem). They
are able to evaluate and correlate risks that may impact food all the
way to the consumer. Suspicion or diagnosis of exotic disease is
reported to Animal and Plant Health Inspection Service (APHIS)
veterinarians immediately to facilitate traceback and prevent local or
national disease spread. Doctors of Veterinary Medicine are trained to
assess lesions, microbiological and chemical residue findings and
other laboratory data to advise animal and human health authorities
and industry on prevention, decontamination and/or product recalls.
Veterinarians can collect and evaluate specimens for specific hazard
identification and for monitoring for chemical residues, infectious
diseases, emerging pathogens, and zoonotic parasites.
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The scientific training and
diagnostic skills of veterinarians make them particularly well
equipped to identify and solve problems. They understand those factors
which contribute to food safety from farm to table. This enables them
to assess and verify HACCP plans and systems at production,
processing, and retail levels. Their perspectives and evaluative
skills extend well beyond applying the FSIS regulations. They are well
trained to perform oversight and verification, assess performance
standards of FSIS food inspection and microbiological laboratory
personnel, and verify industry quality and safety controls throughout
the food chain.
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Veterinarians have a strong
foundation upon which they can build capabilities to supervise, train,
and interact with others. This includes knowledge and professional
experiences in record keeping, systems analysis, administrative
skills, and client education. Veterinarians have skills in developing,
implementing and analyzing public and animal health policies,
correlating and analyzing information systems, managing and leading
complex and extensive government programs and personnel, and building
national and international partnerships for food safety systems.
Veterinarians can train food inspectors, laboratory personnel, and
sanitarians. These skills will be especially important in helping
educate very small plant operators to meet pathogen reduction and
HACCP requirements.
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Veterinarians are well-trained and
experienced in animal welfare during production and in humane handling
as animals are transported, unloaded, stunned and handled at plants.
They are well able to evaluate compliance with the Humane Slaughter
Act, especially proper stunning, bleeding, rail insensibility, pen
maintenance and handling, truck unloading procedures and handling of
non-ambulatory animals.
Outside of FSIS, veterinarians provide leadership to human and animal
health programs in other Federal and State agencies and promote public
health and the safety of animals presented for slaughter. They help
prevent animal disease, protect against exotic diseases, certify
animal health, and control animal drug and agricultural chemical use.
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Veterinarians in food animal
practices are first line promoters of the production of animals that
are healthy, free of violative residues and other public health
hazards. They prevent, control, and eradicate animal diseases. Skilled
in examining animals for specific public health hazards, they form
important links to FSIS veterinarians by validating and maintaining
food safety and quality assurance certification programs and auditing
systems.
I. DEFINING THE ROLE OF THE FSIS
VETERINARIAN
Issue Statement:
FSIS must define the roles of FSIS veterinarians to
meet the challenges of HACCP implementation within the farm-to-table
continuum and to fulfill their functions as FSIS public health officials.
Discussion:
The 1996 Pathogen Reduction/HACCP rule fundamentally
changed FSIS’s approach to its food safety mission. The historic role of
FSIS veterinarians in plants was to prescriptively regulate processes and
procedures to ensure product safety and quality. The Rule clarifies
industry’s responsibility to ensure food safety. Under HACCP, the FSIS
role is to verify in-plant compliance with regulatory performance
standards. For example, if a plant proposes a unique method to meet the
performance standard for reducing Salmonella in cooked beef, the
veterinarian could verify that the method will allow the product to meet
the performance standard. This might include evaluating scientific
literature, monitoring processing controls and examining in-plant data,
and independent laboratory verification of end product compliance.
This change from prescriptive oversight to a more
flexible HACCP system requires broad-based scientific knowledge, critical
thinking, and the authority to make professional judgments at the lowest
level. HACCP requires science-based decisions which impact across a wide
range of entities. With performance standards in place, veterinarians will
better utilize their knowledge, skills, and abilities to evaluate control
efforts within the HACCP system contributing to improved food safety.
However, several issues need to be addressed before new roles for the FSIS
veterinarian can be fully implemented.
Specifically, the effectiveness of HACCP
implementation is limited by lack of experience and expertise and
resistance to change at all levels of FSIS. Lack of teamwork, mixed
messages and unwise decisions discourage industry cooperation and destroy
employee morale. Effective representatives of the veterinary profession,
microbiology, food science, compliance and processing should work together
to design effective HACCP oversight which encourages innovation and
progress. FSIS needs a more diversified HACCP implementation team at all
levels. The Agency is requiring HACCP implementation in three stages,
depending on plant size. This challenges veterinarians to demonstrate
their qualifications as public health program managers. During the
transition to HACCP, they must manage traditional inspection and lead the
change into the new science-based system. Such a major change is
difficult. Technical training is being provided to veterinarians and
inspectors, but they will gain confidence only through experience and
additional training on oversight and verification. Changes in the
interpretation of some regulatory provisions after the training and the
complexity of enforcement procedures add to the complexity for inspectors.
Veterinarians as public health program managers must commit to study and
understand HACCP and lead the workforce to fully understand all its
provisions.
In addition to the concerns noted above, there are
other issues to be addressed before the veterinarian role can be expanded
to fully utilize their skills within the HACCP environment. The historic
role of FSIS in-plant veterinarians has been limited to detecting lesions;
testing and sampling for chemical, drug, and pesticide residues;
supervising food inspectors; and performing other procedural duties
dictated by regulations, directives, and managerial requirements. In many
plants these duties consume the entire day and prevent FSIS veterinarians
from assisting in evaluating food safety and verifying HACCP plan
verification. Examples of such duties include:
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Providing line breaks for bargaining unit
employees
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Performing residue "quick tests"
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Preparing and sending samples to laboratories
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Staffing and scheduling of line personnel
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Administrative supervision of inspectors
(Recommend delegation of first-line supervision)
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Facilitating labor and management relations (e.g.,
grievances and appeals, EEO actions)
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Resolving employee and industry disputes
Therefore, FSIS needs to redefine the responsibilities
of veterinarians to ensure adequate time for food safety activities for
HACCP implementation. Effective HACCP oversight requires flexibility,
informed judgments, and continuous learning within a science-based
inspection program. This refinement of roles may require effectively
delegating day-to-day in-plant line inspection and administrative and
staffing duties to senior inspection personnel. Technical and
administrative responsibility should remain with the veterinarian in
charge.
In addition, FSIS needs to define, clarify, and expand
the in-plant veterinarians’ role as a systems manager with the overall
responsibility for assessing data on incoming materials and in-plant
activities. This would include performing trend analyses for meeting food
safety performance standards. This expanded role will require overseeing
the entire process within plants to verify HACCP compliance and to assess
risks. Using multiple data sources and visual observations, veterinarians
will make professional judgments about the adequacy of HACCP systems. This
includes evaluating data and observations on live animals and processing
materials. For example, veterinarians can compare on-farm certifications
with their medical evaluations of animals presented for slaughter and with
other live-animal information.
Establishments can use the data on identifiable risks
to modify their HACCP plans for continuous process improvement. For
example, livestock production practices which reduce food safety risks at
slaughter could enable plants to modify HACCP plans and may support Agency
revision of a science-based standard. Such modifications will require
oversight from a broad-based professional who can assess the potential
changes and public health impacts of such changes. These activities
require collation of a wide range of information resources both within and
external to the Agency. Such activities will require timely interactions
between field (in-plant, circuit and district) veterinarians and other
Agency programs (e.g., Technical Services Center, Office of Public Health
and Science, and the Office of Policy Program Development and Evaluation).
In addition, the field veterinarians will interact with industry
personnel, State and private veterinarians, animal producers, academia,
consumer groups, and other governmental entities.
Successful farm-to-table HACCP implementation also
requires that all groups within the food production system work
cooperatively to define and maintain food quality systems and safety
objectives. Exchange of timely data is essential to process and product
evaluations and the resulting food safety decisions. Evaluating
information is part of the process for ensuring accountability for food
safety.
To successfully achieve these cooperative
relationships, FSIS should expand the field/in-plant veterinarians’ role
for these food safety activities as facilitators, creators, and/or
managers of teams and partnerships to address industry and consumer needs
from farm to table. FSIS veterinarians are well placed to team with local
authorities, producers and other partners to facilitate discussions and
evaluations of alternative processes and technology. This team interaction
may require inputs, agreements and information exchange by in-plant
personnel, other State and Federal agencies, suppliers and other partners.
Inspection oversight should also be tailored to meet
the diverse nature of the meat industry and be based on an assessment of
public health risk. Premium high quality plants that have effective HACCP
systems, and produce massive quantities of uniform product tailored to
meet customer demands for consistent quality, need fewer inspection
personnel to protect the public’s health. Conversely, meat production
facilities still exist that have not modified their methodologies or
facilities significantly in the last 40 years. Some of these plants
improve only when threatened or are penalized. Many plants possess less
effective quality programs where production and economic concerns may
cause them to take risks which could affect public health. Sufficient FSIS
staffing must remain present to encourage and assure industry adherence to
food safety principles.
Some plants specialize in slaughtering animals not
utilized by the premium animal facilities. They slaughter spent layers,
dairy cattle, inefficient breeding stock, and injured, diseased and downer
animals. Stringent sanitation and effective process controls are needed to
produce safe food. Since these facilities slaughter animals with a greater
percentage of disease and pathologic conditions, as well as a greater
likelihood of drug residue violations, veterinarians must provide more
intense oversight and scrutiny to ensure food safety. However, despite
these challenges, FSIS staffing of these facilities is still based on
numbers of animals slaughtered, rather than on their potential as risks to
human health. FSIS needs to improve food safety oversight of cull
slaughter operations by reassessing and maintaining an appropriate level
of veterinary staffing in these operations. In conjunction with increased
staffing, it is also suggested that the Agency provide promotions and
other incentives to encourage, motivate and retain an effective veterinary
workforce at these more challenging facilities. Greater utilization of
such facilities for education and training would be of considerable
benefit to the Agency as well.
Cull animal slaughter facilities also provide a great
source of animal health/disease information that could help improve herd
and flock health and ultimately food safety. These are also the facilities
where antibiotic and chemical residues and humane issues are most
probable. These facilities should monitor their animal suppliers. Food
safety oversight would be greatly improved by positive animal
identification requirements to facilitate effective traceback for residue
or animal health issues. The veterinarian could play a key role in
compiling and analyzing data from these facilities, and work in
partnership with industry, State veterinarians and APHIS to enhance
food safety and animal health.
Lastly, as the Agency reassesses the veterinarian’s
role in the plant, the consideration should be given to a more integrated
approach to policy development and implementation. Currently the Agency
does not fully utilize field (Districts and Technical Service Center)
expertise in developing policies and action plans. With its more
science-based inspection program, FSIS can also benefit from
veterinarians’ expertise by ensuring they are key players in the
development and evaluation of public health policy. It will be important
to utilize employees from all disciplines, located at various
organizational levels both vertically and horizontally, and from
headquarters and the field to ensure successful implementation of new
programs.
Recommendations:
-
Reassess the responsibilities of FSIS
veterinarians to ensure their role in food safety takes precedence
over all others.
-
Utilize more of the skills of
veterinarians to oversee the implementation and interaction of system
controls, rather than just verify their application, to ensure better
critique of the appropriateness and adequacy of these systems.
-
Provide clarified authority for FSIS
veterinarians that ensures food safety performance standards
compliance from farm to table. Such activities will require making
informed judgments to prioritize inspection actions to verify control
processes within the HACCP systems.
-
Define the in-plant veterinarian's
role as the only government official who is responsible and
technically accountable for assessing and making a scientific
judgment, as a result of analysis of available data, whether the plant
is operating under a sufficient and appropriate food safety control
and monitoring system.
-
Encourage in-plant veterinarians to
regularly interact with other relevant health professionals (animal
and human), producer groups, and others in the supply chain (animal
auctions, dealers) in the surrounding area to foster better lines of
communication and understanding of how each group can better ensure
the farm-to-table food safety assurance concept is better actualized.
-
Enhance the systems oversight role
for FSIS veterinarians utilizing all the available information and
documentation within a risk-based (HACCP) system.
-
Enable FSIS veterinarians as
educators, facilitators and/or managers of teams and partnerships to
address researchers, industry and consumer groups in food safety needs
from farm to table.
-
Provide opportunities for FSIS
veterinarians to educate industry and the public. FSIS veterinarians
should help develop educational materials and be allowed official time
and compensation for this function.
-
Recognize the international role for
FSIS veterinarians as technical liaison with other countries and
international organizations.
-
Appoint an FSIS Chief Veterinary
Public Health Officer to coordinate domestic and international
technical issues related to food animal and public health and oversee
veterinary personnel credentials, education, training and support.
-
Maintain liaison with the Chief
Veterinary Medical Officer of the USA (Currently resides in APHIS).
That position would coordinate domestic and international technical
issues related to food animal and public health.
-
Create department level Chief
Veterinary Officer for the United States as advisor to the president
via the Secretary of Agriculture to coordinate international animal
health plus meat and poultry food safety control issues.
-
Provide leadership for food safety
initiatives to meet established domestic and international standards.
Veterinarians are qualified by a broad biological education and
experience to deal in a wide range of areas important to food safety,
including, but not limited to:
-
Disease recognition, especially zoonotic
diseases
-
Emerging pathogens
-
Bioterrorism threats
-
Foreign animal disease threats
-
Public health
-
Epidemiology
-
Science-based certification and auditing
processes
-
Animal science and population medicine
experience
-
Pathology
-
Parasitology
-
Microbiology, virology, bacteriology
-
Comparative medicine and multi-species
experience chemistry/toxicology and pharmacology.
-
Drug resistance mechanisms
-
In plants which slaughter cull
animals, FSIS should:
-
Reassess staffing of personnel to ensure
protection of the public health.
-
Upgrade veterinary positions to attract and
keep the appropriate level of veterinary expertise.
-
Encourage the utilization of diagnostic
information in partnership with FSIS epidemiologists, industry,
State veterinarians and APHIS.
-
Utilize such facilities for education and
training programs trainee and refresher courses.
II. EDUCATION, TRAINING, RECOGNITION
AND RECRUITMENT
Issue Statement:
FSIS must clarify, expand and promote career tracks
and educational opportunities for veterinary public health professionals.
The Agency needs to change how it recruits, develops, recognizes and
retains highly qualified veterinarians.
Discussion:
As FSIS employees assume a new role in a farm-to-table
food safety and HACCP environment, the Agency must assess how to fully
develop and utilize FSIS veterinarians. This issue is multi-faceted. It
requires examining veterinarians’ skills and education, how to
continually develop and utilize their skills, and how to recruit and
retain highly qualified, motivated veterinarians to meet public health
challenges in the 21st century.
The current Pathogen Reduction/HACCP environment
requires greater professional judgment and expertise to make broad
science-based decisions. The need for individuals educated in the
traditional areas of pathology, microbiology, epidemiology, toxicology,
public health sciences, and production medicine will increase. Other
important areas include business management, risk assessment and
management, manufacturing engineering, food science, international
studies, environmental sciences, and leadership, management and
administrative skills. Veterinarians’ education, training, and
experience closely mirror many of these specialties.
FSIS veterinarians should take more advantage of their
expertise and training to apply for positions as program managers, policy
analysts, compliance officers, HACCP experts, and scientific staff and
leadership opportunities. For example, because of their broad-based
education of analyzing health systems, veterinarians can integrate
information from farm through table. Specifically, in-plant veterinarians
can correlate slaughter data, and evaluate on-farm pathogen reduction
efforts to confirm the effectiveness of on-farm quality assurance programs
for animal producers. Veterinarians can also work with public health
authorities to better identify sources and causes of public health
concerns, and then correct or prevent them. Furthermore, the Agency can
tap into the veterinarian’s analytical and problem solving skills in
order to perform broad public health policy development and evaluation,
risk assessment, data management and evaluation, leadership and
administrative activities which have both national and international
impact. These activities offer only a sampling of the type of work that
can be performed by a veterinarian. For example, in many agencies, such as
State health departments, veterinarians serve as administrators,
environmental health officers, and epidemiologists.
To take advantage of the diverse experience described
above, FSIS needs to first examine how it has been utilizing veterinarians
to date. Historically, veterinary recruitment and careers in FSIS have
focused primarily on in-plant positions with most of the emphasis placed
on the responsibility for detecting lesions and violative residues in
animals presented for slaughter and supervising line inspectors.
Veterinarians usually remain in this career track until advancing to
higher-graded supervisory positions. Traditionally the Agency has filled
in-plant positions with outside candidates and filled higher-level
veterinary management positions from the ranks of field veterinarians.
In-plant jobs are the usual entry-level positions and, subsequently, most
FSIS veterinarians have followed this career track regardless of their
expertise or interest.
While FSIS field experience is critical, veterinarians
qualify and should compete for many other positions that do not require a
veterinary medical degree and are outside the plant. Many veterinarians
may perceive that they can only compete for positions classified in the
Veterinary Medical Officer (VMO) series, GS-701—the numerical
occupational designation used for veterinary positions in the Federal
Government. FSIS needs to educate its workforce, including veterinarians
and selecting officials, that veterinarians may qualify for many other
positions and do not lose credentials by accepting such positions.
Management needs to embrace and endorse this philosophy.
In conjunction with utilizing veterinarians in a wider
range of positions, the Agency can take better advantage of the skills
offered by its current workforce. Throughout the Agency, many employees
have advanced degrees, Board Certification, and knowledge and skills that
are unrecognized and underutilized in their current positions. For
example, veterinarians currently in the Agency hold graduate degrees in
molecular biology, pathology, microbiology, toxicology, business
administration, etc. Many are multi-lingual and could assist the Agency in
activities such as reading labels, communicating with a migrant workforce,
and making presentations. In these times of tight budgets and limited
resources, veterinarians’ varied background can allow the Agency to
cross-utilize its current workforce to meet changing priorities and new
opportunities in food safety.
FSIS can enhance food safety oversight by continuously
investing in educating and training all employees, including
veterinarians. To effectively move into the 21st century public
health arena, FSIS needs to maintain, update, refine and expand its
employees’ skills. In the past, the Agency offered advanced training
programs in science and technology, such as genetic engineering, but did
not support continuing education and development in those fields. The
Agency must develop and utilize training programs in HACCP, statistical
process control, problem solving, risk assessment, molecular epidemiology,
food science, epidemiology and other bioscience specialties to maintain
basic expertise. The Agency could increase the number of employees
participating in the Supervisory Educational Program, HACCP Expert
Training, employee development programs, continuing education and
seminars, graduate education, Board Certification, international
exchanges, sabbatical leaves, inter-agency liaison programs and
fellowships, and industrial/corporate externships.
The Agency should support, and veterinarians should
seek opportunities such as the Senior Executive Service Candidate
Development Program and other fellowships and exchange programs for
leadership, management and administrative skills. Veterinarians should
seek mentors external and internal to FSIS to introduce them to new
perspectives and career paths in the administrative areas. FSIS needs
strong, effective leadership. A leadership development program will
enhance managerial skills at all levels. Veterinary leadership will add
scientific knowledge and credibility to the management team. Veterinarians
have a strong foundation for transitioning into an administrative
management and leadership career path.
It may also be helpful to look at professional
development programs in other agencies. For example, CDC, APHIS, and the
Department of Defense (DOD) have enhanced their effectiveness by
establishing professional development programs which include preventive
medicine, public health, epidemiology, microbiology, food science,
leadership, management and administrative skills. This expanded expertise
will broaden the perspective of FSIS veterinarians and ensure that the
Agency stays abreast of new developments in public health and science.
In conjunction with ongoing professional development
and training, employee recognition is also critical to motivating and
retaining a highly qualified professional workforce. Agency management
needs to encourage supervisors to publicly recognize employee achievements
and outstanding performance. In addition to broader use of existing
recognition systems, such as awards of cash or time off, supervisors
should be encouraged to use non-monetary awards such as plaques, letters,
and newsletter articles. By fully utilizing, developing and recognizing
the existing and developing cadre of veterinarians, FSIS will be able to
attract, recruit and retain new employees in the future. In addition, it
will be important for prospective applicants to possess the skills the
Agency needs to carry out its priority food safety mission goals.
By fully utilizing, developing and recognizing the
existing cadre of veterinarians, FSIS will be in a better position to
attract, recruit and retain new employees in the future. In addition,
prospective applicants will need to possess the skills that the Agency
needs to carry out its food safety mission. Presently, FSIS is the leading
employer of veterinarians in the nation and actively recruits graduates
from colleges of veterinary medicine. However, the current veterinary
college curriculum focuses primarily on large and small animal clinical
practice. To provide effective food safety oversight in the 21st century,
FSIS leadership and veterinarians could participate as adjunct faculty to
encourage career paths and curricula in public health. FSIS could also
create joint, mutually-beneficial programs, such as programs leading to a
special degree or certification in areas such as risk assessment.
To promote food safety as a viable career option for
veterinary graduates, FSIS and veterinary students may participate in the
Virginia-Maryland Regional College of Veterinary Medicine’s Center for
Government and Corporate Veterinary Medicine and other special academic
programs focused on veterinary career opportunities other than clinical
practice. FSIS should closely partner with the Center and other veterinary
colleges to provide practical, rewarding, hands-on experience in food
safety and public health settings. Linkages with the Center could be
enhanced through cooperative agreements and memoranda of understanding for
clerkships and graduate opportunities. Partnering with the Center’s
executive fellowships in leadership and policy could expand FSIS’s
network of future veterinary leaders.
In summary, how the Agency develops, uses, and
recognizes the skills and talents of the current FSIS veterinary
workforce, and how the Agency can best prepare and recruit public health
professionals in the future will be key to enhancing the effectiveness of
FSIS in the next century. The recommendations outlined here will be key to
recruiting and retaining highly qualified and motivated veterinarians to
accomplish the Agency's program goals and objectives.
Recommendations:
-
Develop a robust education and
training program in both traditional and non-traditional specialties
to maximize the value of employees, including veterinarians.
-
Identify and communicate career
tracks which may not be readily understood by veterinary medical
colleges, new recruits, and the current FSIS veterinary workforce. A
Career Planning Guide for Veterinarians and a strong mentoring program
could accomplish this. The career tracks could be:
-
Public Health Policy and
Assessment Track: The Agency could use veterinary analytical and
problem solving skills for risk assessment, data management,
epidemiology, research, and policy development and evaluation.
This track could also encourage FSIS veterinarians to interact
with others in academia, States, and other organizations.
-
Inspection Application Track: In
addition to traditional roles in antemortem and postmortem
inspection, FSIS veterinarians could monitor animal health and
product safety from farm to table. They could monitor feed testing
results, drug therapy and withdrawals; verify HACCP systems; and
conduct enforcement and compliance activities.
-
Administration/Management Track:
Veterinarians and the Agency should seek opportunities to develop
and mentor future leaders in administration and management.
-
International Track: FSIS
veterinarians could contribute to international communications
(using foreign language skills), policies, exports and imports
involving foods of animal origin.
-
Provide information on job
qualification requirements and how they are used in evaluating
applicants. Use vacancy announcements and other information vehicles
to provide guidance on how applicants may qualify for other job series
and still remain competitive for higher-graded GS-701 positions.
-
Conduct a needs assessment to
determine the kinds of professional knowledge and skills the Agency
needs now and in the foreseeable future to accomplish its public
health mission.
-
Conduct an FSIS employee skills
survey to identify the professional knowledge and skills Agency
employees already possess and better utilize them in accomplishing the
Agency’s public health mission.
-
Establish and maintain a talent
resource database that captures employee advanced education, board
certification, language skills, and other specialized knowledge and
skills to enhance job enrichment and advancement and allow the Agency
to more efficiently tap these valuable resources.
-
Reserve a budget for 10% of the
workforce to be in employee development, training, education, or team
building at any given time. Maintain an encumbered educational fund
dedicated to enhancing traditional and non-traditional skills and
knowledge activities to ensure availability of needed proficiencies
within the Agency. These skills should include leadership and staff
skills necessary in developing and implementing public health policy,
risk analysis and food safety initiatives, with both domestic and
international focus.
-
Encourage networking and mentoring to
assimilate new employees and support new and existing FSIS
veterinarians.
-
Improve recruitment efforts to
undergraduate and professional levels, with incentives to attract
highly motivated and qualified veterinarians to FSIS and encourage
them to become broadly trained public health scientists. Expand
recruitment efforts to include potential applicants from the private
sector and State and local governments to introduce new ideas and
enrich Agency programs.
-
Create a Veterinary Recruitment
Officer(s) Program. Establish the criteria and select Veterinary
Recruiters to build a better presentation package. Promote and use
veterinary internships for new veterinary graduates interested in a
food safety career, and veterinary externships for veterinary students
interested in a food safety career.
-
Establish a dedicated full-time
position to work with universities to encourage curriculum development
and to present food safety as a career alternative to students,
faculty and public health professionals. FSIS should:
-
Identify veterinarians who have skills to
instruct food safety classes and promote careers in FSIS.
-
Develop a course on HACCP and food safety, at
the Technical Services Center, to be offered in the colleges of
veterinary medicine.
-
Develop FSIS recruitment presentation.
-
Promote and implement advisory programs at
veterinary colleges.
-
Promote continuing education and graduate
study (with continuing service agreements) and place individuals
in positions which use the training.
-
Encourage combined degrees, such as Doctor of
Veterinary Medicine with a Masters of Public Health or Masters in
Business Administration.
-
Encourage achieving qualifications for Board
Certification.
-
Make food safety presentations to veterinary
students.
-
Promote and use veterinary internships for new
veterinary graduates interested in a food safety career.
-
Promote and use veterinary
internships for new veterinary graduates interested in a food safety
career.
-
Establish a competitive training
option for two-year assignments with the Epidemic Intelligence Service
at the Centers for Disease Control and Prevention (CDC) and other
preventive medicine programs. Consider developing a "commissioned
corps" within USDA or using Public Health Service Veterinarians.
-
Publicly recognize achievement and
reward excellence in service.
-
Develop a program for veterinarians
and other specialists to obtain and retain technical expertise which
enhances the effectiveness of the food safety oversight system.
-
Expand FSIS partnering with Colleges
of Veterinary Medicine and Centers of Excellence (e.g., Center for
Government and Corporate Veterinary Medicine) to develop FSIS adjunct
faculty opportunities, veterinary student clerkships, externships,
fellowships, graduate programs, etc., in public health, food safety,
leadership, and administrative career path development.
III. PARTNERSHIPS
Issue Statement:
Partnering with diverse farm-to-table stakeholders is
necessary to achieve the common goal of a safe, wholesome and affordable
food supply. National, State and local government agencies need to
interact to expand food safety activities and services from farm to table.
Veterinarians can contribute important skills in these partnerships.
Discussion:
The President’s Food Safety Initiative of 1997
instructed key Federal food safety agencies to cooperate to improve the
safety of the nation’s food supply. Currently, at least 12 Federal
agencies have significant food safety responsibilities, including USDA (FSIS;
Cooperative State Research, Education and Extension Service; Agricultural
Research Service; Economic Research Service; and the Office of Risk
Assessment and Cost Benefit Analysis), Health and Human Services (Food and
Drug Administration; National Institutes of Health; and the Centers for
Disease Control & Prevention), Environmental Protection Agency;
Commerce; and the Department of Defense. A 1997 report to the President
outlined research and educational priorities and a need for further
coordination. The President created the Council on Food Safety, co-chaired
by the Secretary of Health and Human Services, the Secretary of
Agriculture, and the Director of the White House Office of Science and
Technology Policy. The Council is developing a food safety strategic plan
with coordinated budget requests.
State and local agriculture and health agencies
provide significant food safety services from farm to table. For years,
governmental agencies have cooperated, with a delineation of
responsibilities. Because partnering encourages the sharing of technical
and budgetary resources, the development of common interests and goals and
the opportunity to share information and work together, partnerships will
be significantly expanded in the future. The broader functions will
include a more seamless, coordinated food safety system beginning at
animal production, extending through transport, holding facilities,
slaughter and processing, distribution and wholesaling, to final food
preparation and consumption. One of the most important outcomes of
successful partnerships is improved educational outreach efforts to small
business producers and processors and consumers. Veterinarians can play
expanded roles in enhancing cooperative education among national, State
and local governments and the food industry and the public.
Many examples of partnerships, both long-standing and
recent, can be cited among all levels of government. Veterinarians
participate in many of the teams and will increasingly be members and
leaders in these partnerships. FSIS is championing partnerships at many
levels. In 1997, it committed $1 million and since has committed
additional technical and financial resources to partnerships to develop
food safety and HACCP programs for small and very small plants. FSIS
veterinary field officers and epidemiologists are well positioned to
interact in traditional Federal/State relations and to be catalysts for
new partnerships.
FSIS is also a key player in the Partnership for Food
Safety Education involving partners in and beyond government. Ednet, a
partnership among FSIS, FDA, and CSREES delivers food safety data and
information via the Internet. Veterinarians are welcome partners in food
safety education. FSIS is partnering with CDC, FDA, and eight states in
the federally-sponsored FoodNet, an active foodborne disease surveillance
network which collects, analyzes and provides data on Salmonellosis and
other human illnesses. These data are valuable in assessing the
effectiveness of HACCP implementation; the first annual HACCP analysis
shows a decline in the prevalence of Salmonella on meat and poultry
and FoodNet identified a corresponding decline in human foodborne
illnesses. More comprehensive sampling at slaughter and correlation with
on-farm data collected in the APHIS National Animal Health Monitoring
System (NAHMS) would provide more seamless data from farm to table.
Veterinarians can be extremely valuable to these partnerships by
developing effective protocols, collecting samples, assessing data and
reporting progress.
FSIS veterinarians are also very important in
developing the Animal Production Food Safety Partnerships between FSIS
and, currently, 18 State pilot projects. Veterinarians work together
locally to address key food safety and animal health issues. Veterinarians
may be major participants in the Outbreak and Recall Response Coordination
Groups being organized to coordinate responses to foodborne outbreaks. For
example, both Washington and Georgia hold quarterly interagency meetings
to coordinate responses to food, water and other public health
emergencies. A formal animal health/public health partnership between the
California Department of Health and the State Veterinarian recently
demonstrated its effectiveness in tracing back and controlling an
egg-associated disease outbreak.
In addition to the State pilot projects, FSIS
partnerships with colleges of veterinary medicine may be very important in
maintaining animal production food safety. FSIS has important partnerships
with Texas A&M University in education and training, and with Tuskegee
University in risk assessment. Locally, FSIS district offices are
developing partnerships with the University of Arkansas and North Carolina
State University to proactively solve food safety and HACCP implementation
problems. Veterinarians and food scientists at Iowa State University and
the University of Arkansas are participating in the FSIS Models Project.
The future may hold more partnering with universities, especially land
grant universities and schools of public health, in education and
training.
Veterinarians at FSIS headquarters, veterinary field
epidemiologists at District Offices, and veterinarians at the Technical
Services Center and the National Training Center play active roles with
information leaders and multipliers in government and academe, by sharing
epidemiological data from live-animal, in-plant and post-processing
pathogen and residue recognition and testing. This role can expand
significantly in the future. FSIS, ARS, ERS, FDA, and APHIS have long
partnered with academe in research and development, training, and
recruiting veterinarians and other scientists. Land grant universities and
extension services actively work with FSIS to provide HACCP training and
development for small and very small plants. In the future, partnering may
include joint studies with FSIS in-plant veterinarians. Effective
oversight will contribute to a mutually beneficial and productive learning
experience.
Commodity groups and the food industry are key
partners in producing safe food. FSIS veterinarians will play important
roles in auditing and verifying animal health and treatment records for
certified and branded meat and poultry products produced under
partnerships involving producers (such as the National Pork Producers’
Council), practicing veterinarians, and processors. These partnerships
will include residue avoidance in production (NPPC Pork Quality Assurance
Program, Level 3), joint partnerships with USDA (NPPC Trichina Safe
Certification), and other HACCP compatible farm-to-table food safety
assurance systems.
Recommendations:
-
Develop Cooperative Agreements and
Memoranda of Understanding with other Federal food safety agencies,
including specific activities and resource provisions for advancing
public health goals. Veterinarians may be important members and
leaders in these partnerships.
-
Identify and staff official
veterinary liaison positions in FSIS partnerships with other Federal
agencies, State food safety programs for animal production and State
food inspection programs. Encourage participation of FSIS field
veterinarians and District Office veterinary epidemiologists in
Federal/State partnerships with identified liaison positions and in
animal production level partnerships. Job descriptions for FSIS Office
of Public Health and Science field epidemiologists should include
these duties as a critical performance element.
-
Expand participation of FSIS field
veterinarians in pathology, microbiology and residue specimen
collection, analysis and reporting (e.g., in partnership with the
Center for Veterinary Medicine, FDA, which assess drug safety and
withdrawal times).
-
Detail or provide administrative
leave to FSIS veterinarians to partner with academic institutions in
research and development projects, workshops, and educational
programs.
-
Partner with academic institutions in
national and district conferences to scientifically assess proposals
and solve problems. FSIS veterinarians may partner with veterinarians
in academe at all levels of such development.
-
Encourage FSIS Veterinarians to work
with commodity groups, State and local governments, industry, and the
public to provide education on HACCP and HACCP-compatible programs,
especially for animal producers, and for food safety certification
programs.
-
Utilize FSIS veterinarians as
professionally-skilled members of international partnerships involving
import and export of foods of animal origin.
IV. COORDINATED DATABASES AND
ANIMAL IDENTIFICATION
An important charge to the Task Force was to identify
potential uses of technology. Databases and positive animal identification
are fundamental tools for a food safety system today and in the future.
Issue Statement:
Current gaps exist in food safety information which
limit the entire public and private food safety mission. There are
information voids in public and animal health monitoring and surveillance.
Issues of scarce resources, confidentiality, jurisdiction, and expensive
technologies have promoted these data gaps. Public and private interests
must construct and maintain coordinated databases to provide food safety
at all levels.
Discussion:
The Task Force members believe that they have a
responsibility to highlight the absolute necessity of maintaining
coordinated databases that serve all food safety and public health
professionals, including veterinarians to execute their mission. A
nationally-coordinated database containing animal health and food safety
data would support science-based decision-making and assist both public
and private interests in safe food. Producers and processors would have
access to information empowering them to produce safer foods. Government
regulatory agencies would be able to monitor epidemiological public health
and animal health trends. Academia would have a phenomenal information
source to direct research and put food safety research on the leading edge
of discovery.
Without the basic tools to monitor, track, and
ultimately evaluate the safety of the Nation’s food supply the best
trained workforce in the world will be limited. Currently, segments of
such a database are widely dispersed and often not readily available.
Information gaps exist in the current farm-to-table information systems.
This situation needs immediate attention since emerging pathogens are
frequently zoonotic. Specifically, information is lacking on the pathogens
associated with food animals and on the prevalence of chemical and
physical hazards. Methods and critical control points for reducing or
eliminating pathogens in different parts of the food system are
insufficient. There is not enough correlation between key players in the
food system and as a result, there are few feedback systems for continuous
evaluation and improvement. This lack of information impedes new efforts
and the measurement of progress.
One of the most apparent gaps is the lack of a
slaughter-based data system combining diagnostic microbiology,
antimicrobial resistance, residue analysis, serology and pathology which
would provide an early warning surveillance system to detect emerging
animal and human pathogens, exotic/foreign animal diseases, and
bioterrorism. Slaughter facilities are a concentrating point for
monitoring food animal diseases and detecting emerging pathogens.
Therefore, a reliable, coordinated data system that includes data from
farm through plant is needed. It would correlate plant data with on-farm
quality assurance information and could be linked to human health
outcomes. For example, there was a parallel decline in human salmonellosis
identified by FoodNet and in the Salmonella recovered from foods of
animal origin in the HACCP program.
In addition, coordinated databases would also allow
evaluation of on-farm quality assurance programs. Public and private
entities could contribute segments to such a coordinated database with
appropriate assurances of confidentiality. Its success would depend on
voluntary buy-in from producer and industry groups. It would generate more
rapid and efficient response to animal and public health issues.
Data collection and coordination is also essential for
risk assessment, risk management and risk communication. Effective and
adequate monitoring and surveillance to identify risks are necessary to
improve the allocation of resources and to develop the knowledge needed to
manage the hazards that pose the greatest risk. As epidemiology and risk
analysis become recognized as critical to public health and food safety,
demands will increase for accurate, timely information to control
infectious diseases, including foodborne diseases, and to enhance the
safety and value of animal-source foods. The design and sampling criteria
for this system will require constant input and evaluation by the in-plant
veterinarian in collaboration with food safety professionals involved in
production and product processing.
The data would guide veterinary epidemiologists in
studies to further investigate a particular health hazard. Even with the
current limited resources, targeting existing studies to correlate with
the APHIS National Animal Health Monitoring System (NAHMS) would enhance
understanding and control of pathogens while maximizing the use of
existing capabilities. For example, studies of each slaughter class in
sentinel slaughter plants would be rotated on a 3- to 5-year basis in
parallel with NAHMS studies providing baseline and trend information
without exceeding laboratory capacities.
In conjunction with the development of effective
coordinated databases, the development of animal identification systems is
essential. A national, standardized animal identification program would
allow information on pathology, microbiology, residues, etc., to be added
to the database at the slaughter facility. Such a database could help
verify the effectiveness of domestic and international HACCP systems,
facilitating global trade. An animal identification system would enhance a
comprehensive surveillance system. It would also promote coordinated
involvement from diverse government agencies. Development of an animal
identification system must respect the need for voluntary compliance by
the animal production community. FSIS should support APHIS-industry
efforts already underway to develop an animal identification system. FSIS
in-plant veterinarians are in a unique position to validate the
effectiveness of an animal identification system and their involvement is
integral to making any animal identification system work.
It will also be important to develop a national
integrated surveillance system which would collect information from a
variety of sources to feed into the coordinated database. This would
entail commitment and extensive funding. Initially, a model multi-state
network could be piloted to speed and simplify electronic reporting,
analysis and dissemination of data. Again, a major challenge that must be
addressed is overcoming fears regarding confidentiality, data ownership,
international trade issues, and misuse and misinterpretation of data.
There are many potential users of a coordinated
database that correlates animal health data with comprehensive
microbiology, pathology, and serological data. Potential partners with
FSIS in building a coordinated database include animal producers, APHIS,
ARS, CREES, States, diagnostic laboratories, academe and others involved
in animal health and food safety research. The database must be
transparent for all; however, privacy issues must be addressed, and the
overall system be user friendly.
However, because of the diverse number of potential
users, the successful creation of the described centralized food safety
coordinated database will have obstacles. Several technical and policy
issues must be addressed. They include technology standardization,
information/computer security, responsibility and control of
identification devices, and data capture responsibilities. In addition,
ultimately, coordination of effort and funding for developing and
maintaining a coordinated database will be at issue.
Another area for discussion concerns the housing of
the coordinated database. An excellent comparison for this food safety
coordinated database is the National Weather Service. This weather
information system is housed within NOAA and functions in partnership with
a variety of stakeholders for both input of and use of data. A comparable
centralized site for housing the food safety coordinated database might be
the National Agricultural Library. Data from the system could be shared
with other public health agencies to prioritize food safety activities and
for prevention/education efforts. At the National Agricultural Library,
the database would be available to the general public and the research
community. The important overarching goal would be to use such integrated
systems to facilitate the translation of findings from surveillance into
improved long-term prevention measures. Collaboration with industry to
document and disseminate successful intervention strategies would be the
most important product. Therefore, housing the food safety coordinated
database within the library community is logical.
In short, developing and implementing a coordinated
food safety database is a principal component of any successful food
safety system of the future. It would empower both public and private
sectors to improve food safety. A successful coordinated database would:
-
Support and enhance voluntary producer quality
assurance;
-
Verify on-farm practices;
-
Enhance food hazard identification and prevention
programs;
-
Support risk assessment and provide data to
prioritize activities;
-
Support national animal identification systems
linked to information sharing and certification/branded market
programs;
-
Better utilize FSIS veterinarians for public
health/food safety;
-
Expand the ability of government at all levels to
respond effectively to food safety concerns, including outbreaks;
-
Verify international trade requirements.
Recommendations:
-
Determine gaps in existing food
safety, public and animal health databases in order to understand and
survey the farm-to-table continuum.
-
Integrate existing and yet to be
developed segments of the public and animal health surveillance system
in order that information is fed into a centralized coordinated food
safety database.
-
Cause the integrated surveillance
system to provide data on early detection of emerging pathogens and
bioterrorism threats, provide evaluation of quality assurance
programs, and monitor food safety program progress and effectiveness.
-
Utilize the FSIS veterinary medical
workforce as the logical central collection point for data points at
slaughter.
-
Establish a working group from key
commodity groups, agencies, industry, and academia to update the data
systems needs on a yearly basis. The creation of such a working group
should be done in an atmosphere of partnership. Furthermore, the
working group should be challenged to maintain the transparency of the
system while protecting confidentiality issues of participants.
-
Support APHIS in its
government-industry partnerships in developing and implementing an
animal identification system.
-
A Presidential-level body should
address issues of coordination and funding in order to comprehend the
need for policy and budget management at the highest level of
government. The leadership of the President's Council on Food Safety
should be tasked to develop a proposal, with input from academia, to
facilitate buy-in, coordination, planning, and funding of a
coordinated food safety database.
V. VETERINARY CONTRIBUTIONS TO
INTERNATIONAL CREDIBILITY OF FSIS
Issue Statement:
FSIS needs to develop and maintain stronger
international relationships with the increasing global movement of food. A
cadre of scientific, medical and veterinary expertise is needed to enhance
the credibility of U.S. government officials in international negotiations
governing food safety and animal health.
Discussion:
Technology, international agreements, and the
increasing ease with which information, people and products move have made
international trade very complex. The business sector has rapidly changed
to accommodate the global nature of economics. The importance of
agriculture to most nations and the potential for the spread of disease
through the food supply present agencies which regulate food or
agricultural products with complex and unique trading challenges. FSIS
should make management and cultural shifts to be ready for global
marketplace demands. Business will want to explore and capitalize on
markets around the world. Consumers will demand new goods and services.
Increased importation of food and agricultural products into the U.S.
brings the risk of importing animal and public health problems. The U.S.
also needs to maintain credibility and confidence in U.S.-produced food,
with a system that prevents exporting unwholesome food products.
Preserving an international market for U.S. producers and processors
depends upon product quality and safety.
Almost all governments require technical assurances
that meat and poultry meet their requirements. Foreign markets must
respect the credibility and integrity of FSIS export certification. Strong
relationships with the controlling authorities of foreign countries can
also assure the American public about the safety of imported foods. Most
governments want their consumers to receive the safest food possible and
grapple with similar food safety issues. Emerging pathogens, drug
resistant bacteria, hormone/antimicrobial utilization, pesticide/antimicrobial
residues, as well as new technologies for producing, processing, and
marketing food, are global issues. A high level of technical cooperation
and communication between governments is vital if these issues, and
occasional crises, are to be effectively managed to maintain the highest
level of commercial predictability for U.S. import and export businesses.
Recognizing the growing global marketplace is only
half the issue. The political desire for fairer international trade is
contingent on eliminating trade barriers, quotas and tariffs. Sanitary and
phytosanitary issues will be used as international trade barriers. U.S.
agencies will need to defend the safety of U.S. products with appropriate
oversight and prevent foreign food safety problems from entering the U.S.
Therefore, US agencies desiring a global food marketplace need to work
with their international colleagues to maintain knowledge of each
others’ circumstances regarding disease or pathogen claims. Developing
relationships, and gathering and sharing phytosanitary and sanitary
information are the best defense against excessive standards or misuse of
standards as trade barriers.
As a result of the expanding international marketplace
and its complicated myriad of issues, the international demands upon FSIS
will increase. The Agency needs a sustained awareness of global human
health, animal health and food safety systems. It needs strong
relationships with similar agencies around the world. All agencies which
protect societies from foodborne illness and animal and human diseases
need to focus on international risk management. International trading
partners rely on veterinarians’ expertise and credibility when working
with FSIS on food safety issues.
Opinion polls reveal that the veterinary profession
enjoys a high level of credibility. Worldwide, customers expect veterinary
authentication that animals and animal products meet import requirements.
The food animal production industry relies on the veterinary
profession’s commitment to protect animal health and welfare. The U.S.
must meet the requirements of global customers or risk losing market share
to competitors. Reliable veterinary authentication of compliance with
customer requirements will enhance trust and increase the value of U.S.
exports.
Veterinarians are well suited to assess the
appropriateness of U.S. standards for other countries and to advise
whether different controls may be more appropriate. In addition to using
equivalency reviews to assess the safety of imported products, FSIS
veterinarians can utilize their expertise in other areas. For instance,
they could help establish a national microbiological database to be used
as a baseline against which both U.S. processors and exporting processors
could measure themselves. This database could house global foodborne
disease information, which could be analyzed by epidemiologists to design
"true risk-based" preventive measures. Since many pathogens are
zoonotic or have an animal food product as the vehicle, FSIS should assume
a greater leadership role in international food safety.
As international markets expand, all countries need to
accept the concept of equivalency, not just of individual measures but of
whole systems of control. Efforts to promote equivalency facilitate,
promote, and maintain cost-effective risk management and honest trade.
Counties should ensure that flexibility is written into their laws to
harmonize with international standards wherever possible. Codex
Alimentarius and the Office of International Epizootics are taking the
first steps in harmonization, by developing standards to ensure safety of
internationally-traded food products. However, the Sanitary and
Phytosanitary Standards Agreement recognizes that individual countries
have a sovereign right to determine their own level of protection. The
U.S. needs to actively participate in all efforts to better harmonize
standards around the world. Therefore, FSIS should consider placing
permanent positions as liaisons with the international organizations
seeking to harmonize and standardize food safety regulation. Select
veterinarians should be encouraged to participate in international food
safety and animal health negotiations at all levels. Gifted communicators
with established scientific credentials add credence to defendable U.S.
negotiations.
In order to effectively participate in these
international activities, FSIS needs to develop and maintain an awareness
of the epidemiology of global foodborne illness. Currently, a variety of
U.S. agencies gather global information on foodborne disease. his
information should be integrated and available to identify animal and
public issues and trends around the world. FSIS should collaborate more
effectively with the national and international animal and public health
infrastructure. Such efforts will contribute to risk-based decisions. For
example, decisions could recognize a potential emerging public health
threat outside the U.S. or the need to defend U.S. products that come
under political economic attack from pseudoscientific phytosanitary and
sanitary claims.
To facilitate such efforts, FSIS will require a robust
infrastructure to support governmental sectors that oversee international
trade. Verification and validation will still be needed, even though
harmonization and equivalence should minimize oversight. Although the
Agency currently maintains this function for approved trading partners,
budget and resource constraints restrict its frequency and effectiveness.
Through the establishment of an organizational
component with an international focus, the Agency will be able to fully
develop a more comprehensive international perspective as well as
effectively promote an understanding of what other countries are doing
regarding food safety. The desire and ability to analyze and gain
knowledge from other trading partners is wise. In addition, international
interaction will promote acceptance of U.S. methods that promote safe food
and assist the mission of safe food in a global marketplace.
Recommendations:
-
Develop and fund an FSIS technical
unit to describe and justify the U.S. system of controls, stay abreast
of international initiatives and/or innovative ideas, gather
international food safety data and work cooperatively with the
technical agencies of foreign countries.
-
Provide a continual veterinary
medical presence in appropriate locations to interact with
international organizations on public and animal health issues.
-
Consistently include veterinarians in
international negotiations on food products of animal origin.
-
Maintain, validate and audit a
reliable and credible export certification process which better meets
the expectations of foreign markets.
-
Collaborate with APHIS to validate
production industry quality assurance programs.
-
Maintain, validate and audit reliable
import controls and ensure veterinary oversight.
-
Encourage select veterinary
participation in international food safety and animal health
negotiations at all levels. Examples include Codex Alimentarius and
Office of International Epizootics.
TASK FORCE MEMBERS –
BIOGRAPHIES
[Note – more complete biographical information will
be presented in the final report]
-
Ron F. Hicks (Co-Chair), FSIS/OM;
-
Dale Boyle (Co-Chair), DVM, MPH, Diplomate
American College of Veterinary Medicine, Executive Vice President,
National Association of Federal Veterinarians;
-
George W. Beran, DVM,PhD, Diplomate American
College of Veterinary Preventive Medicine, AVMA;
-
Chris Bratcher, DVM; President, National
Association of Federal Veterinarians; Circuit Supervisor, FSIS/FO-Lawrence
District Office;
-
Dana Broussard, DVM, FSIS;
-
Bonnie Buntain, DVM, MS, Diplomate Emeritus
American Board of Veterinary Practitioners, Acting Assistant Deputy
Administrator. Office of Public Health and Science, FSIS;
-
Jere Dick, DVM, APHIS;
-
Ruth Etzel, MD, MPH, FSIS/OPHS-ERAD;
-
Douglas L. Fulnechek, DVM, FSIS;
-
W. David Goolsby, DVM, MS, MPH, Diplomate ACVPM
[Could we spell out?], District Health Director, South Carolina Dept.
Of Health and Environmental Control;
-
Karen W. Henderson, DVM, FSIS/FO-Raleigh District
Office;
-
Bill Jolly, BVSc, MVSc, MACVSc .Counselor
(Veterinary Services).New Zealand Embassy;
-
Laurie Lindsay, FSIS/OM/HRD;
-
Curt J. Mann, DVM, Association of American
Veterinary Medical Colleges;
-
Barbara Masters, DVM, Branch Chief, Processing
Operations Staff, Technical Service Center, FSIS;
-
James McKean, DVM, Extension Veterinarian, Iowa
State University;
-
Peter Miller, Veterinary Counselor, Australian
Embassy;
-
Dennis O’Malley, Chief, Classification and
Compensation Branch, Human Resources Division, FSIS;
-
Perfecto Santiago, DVM, FSIS/FO-Beltsville
District Office;
-
William C. Smith Assistant Deputy Administrator,
Field Operations;
-
Phyllis H. Sparling, DVM, MS, Diplomate American
College of Veterinary Preventive Medicine, Specialty Epidemiology,
FSIS liaison at CDC;
-
Paul Thompson, DVM, Director, Technical Service
Center, FSIS;
-
Linda Tollefson, DVM, MPH, Director, Office of
Surveillance and Compliance, FDA/Center for Veterinary Medicine.
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