Regulatory Comments and Petitions
December 6, 2002
Secretary Ann Veneman
Re: Animal Care and Disease Prevention, Food Safety
Dear Secretary Veneman:
Many of the 76 million foodborne illnesses contracted each year in the United States result from eating meat and poultry products that are contaminated with E. coli O157:H7, Listeria monocytogenes, Salmonella, and other pathogenic bacteria. Almost weekly, consumers are confronted with news of recalls of foods potentially contaminated with those and other pathogens. The recent E. coli O157:H7 and Listeria monocytogenes outbreaks both linked to meat or poultry products demonstrate that interventions at the slaughter and processing levels alone have not sufficed to prevent food-borne illnesses. Risk reduction and prevention of food-borne illness must begin on the farm since animals and farm environments provide a reservoir for pathogens that can enter the food supply.
In 1990, Congress enacted amendments to the National Agricultural Research, Extension and Teaching Act of 1977, directing USDA to commission the National Academy of Sciences (NAS) to conduct a study of animal care and disease prevention strategies and assess opportunities to achieve food safety goals. Twelve years later, USDA has yet to comply with that congressional mandate.
On behalf of several consumer food-safety, animal-welfare, public health, and environmental organizations, we urge you to commission the NAS to conduct this important study, not only because Congress has required it, but because an expert, independent evaluation is needed to identify the impact that on-farm production and herd/flock-management practices have on animal health and welfare and the introduction of pathogens into the animal environment and, ultimately, into the human food supply.
The National Animal Health Monitoring System (NAHMS) has already collected a body of data concerning animal-husbandry systems, herd/flock management, and production practices, as well as pathogen prevalence. Those data provide a foundation upon which the NAS can conduct additional research to assess the risks and environmental consequences that result from certain production practices, including the effect of such factors as the nature of feed (e.g., grain versus forage); cleanliness of systems used to feed, water, and transport animals; forced molting of poultry; and crowding of animals in and cleanliness of concentrated animal-feeding operations.
In its recent report responding to questions posed by FSIS relating to ground beef products, the National Advisory Committee on Microbiological Criteria for Foods (NACMCF) recommended that additional data be gathered and research generated concerning, among other things, the factors that may influence the microbiological status of animals presented for slaughter. The NAS study could help answer some of the questions raised.
A key opportunity to improve food safety is on the farm, where interventions can prevent pathogens from getting into or onto the livestock or poultry in the first place. Therefore, we urge you to comply with the mandate of the National Agricultural Research, Extension and Teaching Act of 1977, as amended in 1990, and commission the NAS to study and identify effective farm-safety programs that could reduce the introduction of microbial hazards into the food supply and have the additional benefit of protecting the environment.