Food Safety: U.S. Needs a Consistent Farm-to-Table Approach to Egg Safety
(Testimony, 07/01/99, GAO/T-RCED-99-232).
Pursuant to a congressional request, GAO discussed its work on the
safety of eggs and egg products, focusing on whether: (1)
prevention-based safety practices have been applied on egg farms and at
processing plants; (2) implementation of a new federal policy on egg
refrigeration will effectively reduce the risks associated with
contaminated eggs; (3) federal and state policies and practices on
serving eggs to vulnerable populations and dating egg cartons are
consistent; and (4) federal egg safety resources are used efficiently
and policies are coordinated effectively.
GAO noted that: (1) the Food and Drug Administration (FDA) has not
established prevention-based procedures on egg farms or at shell egg
processing plants that would reduce or eliminate Salmonella Enteritidis
contamination by identifying, controlling, and monitoring known safety
risks; (2) 13 states, responsible for about 38 percent of the nation's
egg production, have established voluntary prevention-based programs for
egg farms; (3) however, these programs do not provide a uniform level of
risk reduction because they take different approaches in critical areas
such as the frequency of testing for the presence of Salmonella
Enteritidis; (4) the Food Safety and Inspection Service (FSIS) does not
require a prevention-based approach in processing plants where eggs are
broken to create egg products; (5) the first national requirement to
refrigerate eggs at 45 degrees Fahrenheit or below from the time they
are packed until they reach the consumer may not, for a variety of
reasons, effectively reduce egg safety risks; (6) implementation and
enforcement of the requirements will be split between FSIS and FDA; (7)
FSIS has issued regulations, which take effect in August, requiring that
eggs be refrigerated during storage and transportation; (8) however, FDA
has not yet proposed regulations to require that eggs be refrigerated
after they arrive at retail locations such as restaurants and grocery
stores; (9) many experts believe that greater risk reduction could be
achieved by controlling the internal temperature of the egg, something
that the new regulations will not require; (10) inconsistent policies
and practices in three other areas have weakened the nation's egg safety
efforts; (11) certain groups are more likely to suffer severe health
consequences from eating contaminated eggs; (12) only about half the
states have followed FDA's recommendation that they require food service
operators to use pasteurized eggs or egg products when serving these
groups; (13) federal policies allow some eggs to be returned from
grocery stores to processors to be repackaged, redated, and returned to
the retail level for sale; (14) there are inconsistencies in how
expiration dates are used on egg cartons; (15) the inconsistencies in
repackaging and expiration dating can mislead consumers about the eggs'
freshness and may pose a food safety risk; and (16) the involvement of
four federal agencies enforcing a variety of laws makes it difficult to
direct resources to the areas of highest safety risk and to effectively
coordinate egg safety policies.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: T-RCED-99-232
TITLE: Food Safety: U.S. Needs a Consistent Farm-to-Table
Approach to Egg Safety
DATE: 07/01/99
SUBJECT: Food inspection
Safety regulation
Contaminated foods
Consumer protection
Health hazards
Quality control
Safety standards
Poultry industry
Product safety
IDENTIFIER: APHIS National Poultry Improvement Plan
Salmonella Enteritidis Bacteria
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Cover
================================================================ COVER
Before the Subcommittee on Oversight of Government Management,
Restructuring and the District of Columbia, Committee on Governmental
Affairs, U.S. Senate
For Release
on Delivery
Expected at
10:00 a.m. EDT
Thursday
July 1, 1999
FOOD SAFETY - U.S. NEEDS A
CONSISTENT FARM-TO-TABLE APPROACH
TO EGG SAFETY
Statement of Lawrence J. Dyckman, Director,
Food and Agriculture Issues
Resources, Community and Economic Development
Division
GAO/T-RCED-99-232
GAO/RCED-99-232T
(150151)
Abbreviations
=============================================================== ABBREV
============================================================ Chapter 0
Mr. Chairman and Members of the Subcommittee:
Thank you for the opportunity to discuss our work on the safety of
eggs and egg products. Eggs are an important part of most Americans'
diets. On average, each American consumes about 245 eggs annually.
However, over the last decade, eggs contaminated with Salmonella
Enteritidis bacteria have increasingly been implicated as the cause
of foodborne illness in the United States. Salmonella Enteritidis
may have caused about 300,000 illnesses in 1997, resulting in up to
about 230 deaths. Between 1985 and 1998, when a cause could be
identified, over three-quarters of the Salmonella Enteritidis
outbreaks were linked to eggs, according to the Centers for Disease
Control and Prevention.
Given the potential for eggs to become contaminated with
illness-causing bacteria, it is critical that federal agencies, in
cooperation with the states, have a consistent farm-to-table approach
to ensure the safety of shell eggs and egg products. Of the 67
billion eggs produced in the United States in 1998, about 70 percent
were sold whole (known in the industry as shell eggs). The remaining
30 percent of the eggs produced were broken, pasteurized, and
processed into liquid, frozen, or dried egg products used, for
instance, in commercial baked goods and ice cream. The Food and Drug
Administration (FDA) has the primary responsibility for the safe
production and processing of shell eggs, and the Food Safety and
Inspection Service (FSIS) is responsible for food safety at egg
products processing plants.
My testimony is based on a report we are issuing to Senator Durbin
today on the adequacy of the nation's system for ensuring the safety
of shell eggs and egg products.\1 The testimony will examine whether
(1) prevention-based safety practices have been applied on egg farms
and at processing plants, (2) implementation of a new federal policy
on egg refrigeration will effectively reduce the risks associated
with contaminated eggs, (3) federal and state policies and practices
on serving eggs to vulnerable populations and dating egg cartons are
consistent, and (4) federal egg safety resources are used efficiently
and policies are coordinated effectively.
In summary, we found the following:
-- FDA has not established prevention-based procedures on egg farms
or at shell egg processing plants that would reduce or eliminate
Salmonella Enteritidis contamination by identifying,
controlling, and monitoring known safety risks. At the state
level, 13 states, responsible for about 38 percent of the
nation's egg production, have established voluntary
prevention-based programs for egg farms.\2 However, these
programs do not provide a uniform level of risk reduction
because they take different approaches in critical areas such as
the frequency of testing for the presence of Salmonella
Enteritidis. Moreover, FSIS does not require a prevention-based
approach in processing plants where eggs are broken to create
egg products.
-- The first national requirement to refrigerate eggs at 45 degrees
Fahrenheit or below from the time they are packed until they
reach the consumer may not, for a variety of reasons,
effectively reduce egg safety risks.\3 Implementation and
enforcement of the requirements will be split between FSIS and
FDA. FSIS has issued regulations, which take effect in August,
requiring that eggs be refrigerated during storage and
transportation. However, FDA has not yet proposed regulations
to require that eggs be refrigerated after they arrive at retail
locations such as restaurants and grocery stores. In addition,
many experts believe that greater risk reduction could be
achieved by controlling the internal temperature of the egg,
something that the new regulations will not require.
-- Inconsistent policies and practices in three other areas have
weakened the nation's egg safety efforts. Certain groups,
including the elderly in nursing homes, are more likely to
suffer severe health consequences from eating contaminated eggs.
Yet, only about half the states have followed FDA's
recommendation that they require food service operators to use
pasteurized eggs or egg products when serving these groups.
Also, federal policies allow some eggs to be returned from
grocery stores to processors to be repackaged, redated, and
returned to the retail level for sale. In addition, there are
inconsistencies in how expiration dates are used on egg cartons.
The inconsistencies in repackaging and expiration dating can
mislead consumers about the eggs' freshness and may pose a food
safety risk.
-- The involvement of four federal agencies enforcing a variety of
laws makes it difficult to direct resources to the areas of
highest safety risk and to effectively coordinate egg safety
policies. For example, FSIS is required by law to provide daily
full-time inspection of egg products plants where eggs are
pasteurized to kill harmful bacteria, whereas FDA almost never
inspects egg farms where eggs can be contaminated. In addition,
although we reported in 1992 on the need for better coordination
between FDA and the Department of Agriculture (USDA) on egg
safety issues, the agencies have still not agreed on a
comprehensive unified approach for improving egg safety.\4
--------------------
\1 Food Safety: U.S. Lacks a Consistent Farm-to-Table Approach to
Egg Safety (GAO/RCED-99-184, July 1, 1999).
\2 The 13 states are Alabama, California, Connecticut, Louisiana,
Maine, Maryland, Massachusetts, Michigan, New York, Ohio,
Pennsylvania, South Carolina, and Utah.
\3 Refrigeration at 45 degrees or less delays the breakdown of the
yolk membrane thereby retarding the growth of Salmonella in eggs.
\4 Food Safety and Quality: Salmonella Control Efforts Show Need for
More Coordination (GAO/RCED-92-69, Apr. 21, 1992).
BACKGROUND
---------------------------------------------------------- Chapter 0:1
When Salmonella is found in eggs, Salmonella Enteritidis (SE) is the
strain most commonly identified. SE was first associated with clean,
intact shell eggs in 1988 and is believed to be deposited from
infected hens' ovaries before the shells form around the eggs'
contents. SE has progressed from an infrequent cause of human
illness to one of the most common strains of Salmonella, growing from
5 percent of total Salmonella cases in 1977 to about 16 percent in
1987 and about 23 percent in 1997. Recently released data from the
Centers for Disease Control and Prevention for 1996 through 1998
indicate a possible change in trends, as SE infections decreased by
44 percent in selected counties and states.
SE, as well as other strains of Salmonella, can cause such symptoms
as abdominal pain, fever, headache, and vomiting, and can also lead
to more severe conditions, such as blood stream infections,
arthritis, and meningitis. It sometimes kills, particularly elderly
residents of nursing homes. Refrigerating eggs at 45 degrees or less
retards the growth of Salmonella, and pasteurization or thorough
cooking can kill it.
As eggs make their way from the farm to the table, responsibility for
egg safety shifts back and forth among four federal agencies in two
departments and often two agencies in each state. (See fig. 1.)
First, USDA's Animal and Plant Health Inspection Service manages the
National Poultry Improvement Plan that establishes breeding practices
to ensure that laying hens are born free from SE. At the next stage,
the farms where eggs are laid, the Department of Health and Human
Services' FDA is responsible for egg safety. Once the eggs arrive at
processing plants where they are either packed as shell eggs or
broken for egg products, the authority is split between two
agenciesFDA for shell eggs and USDA's Food Safety and Inspection
Service for egg products. While shell eggs are being processed, they
may also be inspected by the USDA's Agricultural Marketing Service
under a voluntary program to ensure shell egg quality. Once
transported to the retail level, both shell eggs and egg products are
under FDA's authority, but the millions of restaurants, institutions,
and other retail food operations throughout the United States are
generally inspected by either a state agriculture or health
department under state laws. FDA encourages uniformity among state
laws by publishing the Food Code, which recommends model practices
for ensuring safer food, and by encouraging states to adopt its
provisions.
Figure 1: Egg Production,
Processing, and Distribution
and Responsible Federal
Regulatory Agencies
(See figure in printed
edition.)
Notes: As eggs move from the farm to the table, state governments
share egg safety responsibilities with the federal government.
USDA will assume responsibility for enforcing refrigeration
requirements for shell eggs during storage and transportation in
August 1999. FDA will retain overall responsibility for shell egg
safety as well as responsibility for egg products after they leave
the processing plant.
THE FEDERAL GOVERNMENT AND THE
STATES HAVE NOT INSTITUTED A
CONSISTENT PREVENTION-BASED
APPROACH TO EGG SAFETY
---------------------------------------------------------- Chapter 0:2
Outbreaks of egg-related illness are sometimes traced to egg
production farms where laying flocks have become contaminated with
SE. Although prevention-based approaches are generally recognized as
the most effective method for identifying and reducing bacterial
contamination, no federal program exists to reduce or eliminate this
contamination during egg production on farms. Over the last few
years, the federal government has introduced prevention-based hazard
analysis and critical control point (HACCP) systems in meat, poultry,
and seafood processing. HACCP systems are designed to actively
monitor and control contamination throughout the food production
process by identifying places where the greatest food safety risks
exist, implementing methods to control the risks at those points, and
then monitoring the efficacy of the controls.
In our 1992 report on SE in eggs, we recommended that the Secretary
of Agriculture and the Commissioner of FDA work together to develop a
comprehensive program to control SE throughout the egg production,
distribution, and consumption process.\5 Six years later, in May
1998, USDA and FDA published an advance notice of proposed rulemaking
in the Federal Register requesting comments on various proposals for
improving farm-to-table egg safety. One of the proposals concerned
using the HACCP approach on egg farms. Our analysis of the comments
found strong support for a uniform, voluntary, national HACCP-based
program to reduce the risks associated with SE contamination during
egg production. As of June 1999, FDA, which has regulatory authority
over shell egg production, had not taken any actions based on the
comments received.
Thirteen states, in cooperation with the egg industry, have
established voluntary statewide HACCP-based programs to control or
eliminate SE during egg production. Seven elements are commonly
found in such plans: (1) purchasing chicks from breeders approved by
the National Poultry Improvement Plan, (2) controlling rodents and
pests, (3) using bio-security procedures,\6 (4) cleaning and
disinfecting henhouses, (5) conducting environmental testing for SE,
(6) refrigerating eggs after packing, and (7) keeping records to
document the implementation and monitoring of plan requirements.
Although the existing state egg safety programs include many of these
elements, some significant variations exist. For example, under
about half of the plans, testing the egg laying environment for the
presence of SE is only done 8 weeks before the flock will stop
producing eggs and be replaced with new birds. However, two states
have more extensive testing regimens that start before a chicken
begins to produce eggs and continues periodically throughout the 2
years that chickens in commercial production continue to lay eggs.
This testing schedule allows problems to be identified before the
chickens begin to produce contaminated eggs, whereas the testing done
in the other states near the end of production provides less risk
reduction. Moreover, 5 of the 13 plans do not include provisions for
third-party oversight to assess the reliability and validity of the
plan.
After eggs are produced on farms, they are sent to facilities where
they are cleaned, processed, and packed. Egg packers and processors
are not required to establish HACCP-based programs to prevent
microbial contamination in the plants where shell eggs are processed
and packed for consumers. FDA, which has regulatory authority over
these plants, has not proposed HACCP-based requirements in this area.
Eggs that are not sold as shell eggs are sent to egg products plants
where they are broken and pasteurized. FSIS, which has regulatory
authority over egg products, does not require HACCP programs in these
plants. FSIS has begun taking preliminary actions for a rulemaking
to require HACCP. However, as of June 1999, the agency had not yet
published a rule proposing such a requirement. In the absence of a
federal requirement, some egg products plants have begun implementing
HACCP plans on their own.
--------------------
\5 GAO/RCED-92-69, Apr. 21, 1992.
\6 Bio-security procedures are designed to prevent SE from being
carried into poultry houses from outside sources.
NEW FEDERAL REFRIGERATION
REQUIREMENTS MAY NOT BE AS
EFFECTIVE AS POSSIBLE
---------------------------------------------------------- Chapter 0:3
Beginning in August 1999, federal regulations will, for the first
time, require that eggs for consumer use be refrigerated. But the
new rules may not effectively reduce the risks from SE contamination
in eggs. The Congress originally required egg refrigeration in the
1991 amendments to the Egg Products Inspection Act. Eight years
later, USDA will begin implementing the requirement that eggs be
refrigerated at an air temperature not to exceed 45 degrees from the
time they are packed until they reach grocery stores, restaurants, or
households.
Once eggs reach restaurants, institutions, grocery stores, and other
retail locations, federal regulations will not require that they be
refrigerated. The 1991 amendments to the Egg Products Inspection Act
authorize FDA to ensure compliance with the egg refrigeration
requirements, at locations not covered by FSIS, such as restaurants,
institutions and grocery stores. In May 1998, FDA announced that it
planned to propose regulations to mandate that shell eggs be stored
for sale at 45 degrees or less in retail locations. But as of June
1999, FDA has not yet done so. In the absence of current federal
regulations requiring the refrigeration of eggs at retail locations,
responsibility shifts to the states. Our survey of regulatory
officials found that 43 states require that eggs be kept at 45
degrees or less in retail locations, 3 states have temperature limits
above 45 degrees, and 4 states have no requirements.
While implementing the 1991 amendments is an important first step,
FSIS and other experts have raised concerns about the effectiveness
of an air temperature requirement in improving egg safety. According
to FSIS, maintaining the internal temperature of eggs at 45 degrees
or below throughout processing and distribution would result in a
greater reduction in illnesses from SE than would result from an air
temperature requirement. However, when eggs are processed and
packed, according to USDA, they are often in the 70- to 80-degree
temperature range. Because of the way eggs are packed, even if they
are immediately put into a cooler, research has shown that it may
take from 3 to 6 days before the eggs' internal temperature is
reduced to the air temperature. During this time, SE bacteria may
multiply, and the more bacteria an egg contains, the more dangerous
it will be if eaten raw or undercooked. New approaches show promise
in cooling eggs more rapidly. For example, research has shown that
cryogenic gases\7 can cool eggs internally to below 40 degrees in 12
minutes. One company has developed a prototype cooling method using
cryogenic gases that it estimates will add 3 cents or less to the
cost of a dozen eggs.
--------------------
\7 Cryogenic gases are refrigerants used to obtain low temperatures.
INCONSISTENT POLICIES AND
PRACTICES HAMPER EGG SAFETY
EFFORTS
---------------------------------------------------------- Chapter 0:4
Individuals with impaired immune systems who are in institutional or
custodial care, the elderly in facilities such as nursing homes or
hospitals, and preschool children in facilities such as day care
centers are more susceptible than the general population to severe
health problems as a result of eating eggs contaminated with SE. For
example, the Centers for Disease Control and Prevention found that 54
of the 79 deaths associated with outbreaks of SE between 1985 and
1998 were of individuals in nursing homes.\8 Because of the problems
associated with SE-contaminated eggs, FDA's Food Code recommends
special procedures, such as substituting pasteurized eggs for raw
eggs in certain situations, for food service operators serving highly
susceptible populations. However, according to our survey of state
regulatory officials, many states have not adopted the FDA's
recommendations on serving pasteurized eggs to highly susceptible
populations. For example, 24 of the 50 states told us that they did
not require food service operators that serve highly susceptible
populations to use pasteurized eggs for any food item that usually
contains raw eggs, such as Caesar salad dressing. Furthermore, in 26
states, food service operators are not required to use pasteurized
eggs when they crack, combine, and hold a number of eggs for
subsequent cooking.
An egg's natural defenses to SE can break down as the egg ages or is
exposed to high or fluctuating temperatures. Consequently, concerns
have surfaced about the practice of removing eggs from grocery stores
a few days before their expiration or sell-by dates and returning
them to an egg processing plant, where they are rewashed, repackaged,
placed in cartons with fresh eggs, and given a new expiration date.
While FDA, USDA, industry representatives, and several state
officials told us that they do not believe this practice is
widespread, some state and federal officials contend that it may
present a food safety hazard. Eggs that are repackaged must be
transported to the processing plant and therefore may be subject to
temperature fluctuations as well as additional heating during
rewashing.
USDA and FDA have reacted differently to concerns about repackaging
and redating. USDA's Agricultural Marketing Service announced that,
as of April 27, 1998, the practice of repackaging and redating eggs
would be temporarily prohibited for the one-third of the nation's
eggs that are graded and packed under its voluntary grading program
because the practice can mislead consumers about the eggs' freshness.
The Service is currently developing regulations to make this
prohibition permanent. FDA, which has regulatory authority over all
shell eggs, announced in May 1998 that it was considering appropriate
measures to address repackaging, but as of June 1999, had not taken
any action to prohibit the practice. The inconsistency in the
federal government's approach to repackaging may be misleading to
consumers because USDA-graded and non-USDA-graded eggs sit side by
side in grocery store coolers. Our survey of state regulatory
officials found that only 10 of the 50 states have laws prohibiting
repackaging.
Federal policies are also inconsistent on the expiration dates
stamped on egg cartons. Although neither the Agricultural Marketing
Service nor FDA require cartons to be dated, many producers in the
Service's voluntary grading program take this optional step. If they
do, the Service requires that the expiration date be no more than 30
days from the date the eggs were packed. Egg processors that do not
participate in the agency's grading program typically include
expiration dates of either 30 or 45 days, although some do not
provide any expiration date. In addition, our survey of state
regulatory officials found that only 17 of the 50 states require
either an expiration or a sell-by date on egg cartons sold in their
states. These inconsistent expiration dating practices can be
misleading to consumers. For example, when comparing carton dates, a
consumer may be more likely to select the eggs not graded by USDA
because a later date on the carton seems to imply that those eggs
will be fresher for a longer period of time. But the eggs with the
later date may actually be older than the USDA-graded eggs in the
cooler.
--------------------
\8 An outbreak is defined as two or more people having a similar
illness that has been traced to eating a common food. In addition,
sporadic cases of illness occur outside of reported outbreaks.
According to the Centers for Disease Control and Prevention, although
foodborne diseases are extremely common only a fraction of the
illnesses are reported. Therefore the numbers of illnesses and
deaths linked to reported outbreaks of SE are much smaller than the
best estimates of the actual prevalence of SE related illness and
death.
FRAGMENTED STRUCTURE MAKES
EFFECTIVE RESOURCE ALLOCATION
AND POLICY COORDINATION
DIFFICULT
---------------------------------------------------------- Chapter 0:5
Under the current regulatory and organizational framework, egg safety
resources are not directed to the areas of highest risk. FDA has
limited inspection resources and under its regulatory authority foods
are generally allowed to enter the market without preapproval.
Consequently, the agency almost never inspects egg production farms
even though outbreaks of egg-related illness are sometimes traced to
these locations. In contrast, FSIS is required by law to conduct
daily, continuous inspections of all egg products plants in the
United States.\9 As a result, most federal resources for egg safety
inspection are directed toward egg products even though during
processing the eggs are pasteurized to kill harmful bacteria such as
SE. In fiscal year 1998, FSIS had 102 full-time inspectors dedicated
to daily, continuous inspection at all 73 egg products plants in the
country. If HACCP systems are implemented in all egg products
plants, it may be possible to reduce or eliminate the current
practice of continuous inspection, which could allow inspection
resources to be redirected to areas of higher risk.
Although USDA and FDA have worked together on various egg safety
activities, including a consumer education campaign, an SE risk
assessment study, and a foodborne disease monitoring network,
progress on developing a comprehensive egg safety strategy have been
slow. In our 1992 report on efforts to control SE, we reported that
coordination difficulties resulted from the split regulatory
structure and that consequently, the federal government had not
agreed on a unified approach to addressing the problem of SE in
eggs.\10 Now, 11 years after the problem of SE-contaminated eggs was
first identified, the federal government still has not agreed on a
unified approach to address the problem.
In May 1998, FDA and FSIS issued a joint advance notice of proposed
rulemaking seeking to identify actions that would decrease the food
safety risks associated with eggs as they move from the farm to the
table. The notice recognized that eggs contaminated with SE continue
to be a public health concern and sought comments by August 1998 on a
wide range of actions that could be taken by the two agencies to
improve farm-to-table egg safety. Although FSIS received about 70
comments from state regulatory agencies, industry associations, and
other interested parties, no official FDA/USDA group has been formed
to review these comments or to establish a unified regulatory
strategy.
--------------------
\9 There are some minor exceptions to the continuous inspection
requirement. For example, on weekends, plants are permitted to
process dried pasteurized egg whites without inspectors present.
\10 GAO/RCED-92-69, Apr. 21, 1992.
-------------------------------------------------------- Chapter 0:5.1
In conclusion, Mr. Chairman, with responsibilities distributed among
four federal agencies, the nation's egg safety efforts lack an
organizational focus and contain gaps, inconsistencies, and
inefficiencies. A prevention-based approach to food safety involving
hazard analysis and critical control point principles has not been
applied comprehensively to the production and processing of eggs and
egg products. Federal regulations soon to be implemented on the
refrigeration of eggs will not control this risk factor as
effectively as possible because they do not apply at the retail level
and because they address air temperature not the egg's internal
temperature. Raw and undercooked eggs continue to be hazardous,
particularly to highly susceptible populations such as the elderly in
nursing homes. And finally, decisions about how to allocate the
nation's egg safety inspection resources are not based on risk.
The report we are issuing today contains a matter for congressional
consideration and three recommendations aimed at improving egg
safety. To provide an organizational focus for the nation's egg
safety policies and activities, we ask the Congress to consider
consolidating responsibility for egg safety in a single federal
department. To help improve safety on egg farms and in processing
plants, we recommend that the Commissioner of the Food and Drug
Administration develop a model HACCP-based SE reduction program for
egg farms and processing plants that could be adopted by the states.
To enhance safety protections in egg products processing plants, we
recommend that the Secretary of Agriculture develop regulations to
require these plants to implement HACCP systems. And finally, to
reduce the time needed to lower an egg's internal temperature to 45
degrees, we recommend that the Secretary of Agriculture and the
Commissioner of the Food and Drug Administration jointly study the
costs and benefits of implementing rapid cooling techniques in egg
processing and packing operations.
In commenting on the draft report, USDA and FDA agreed with all three
of the report's recommendations. However, FDA said that before it
can develop criteria for a model, HACCP-based SE reduction program,
it must first develop prevention controls for egg production because
science has not yet established the optimal strategy to control SE on
farms. We agree with FDA that the scientific issues related to
identifying and establishing effective SE control measures are
complex. However, we believe FDA can take immediate action to
develop a model program that contains controls that are based on the
best currently available scientific information and the experience of
existing state programs.
This concludes my prepared statement. I would be happy to respond to
any questions that you and Members of the Subcommittee may have.
CONTACT AND ACKNOWLEDGMENTS
---------------------------------------------------------- Chapter 0:6
For further information, please contact Lawrence J. Dyckman at (202)
512-5138. Individuals making key contributions to this testimony
included Stephen D. Secrist, Mary K. Colgrove-Stone, and Robert C.
Summers.
*** End of document. ***