NFPA Supports Appropriate Use of Microbiological Testing in Food Safety System

Taken from the December 2000 issue of
"Food Production/Management"

Microbiological testing can provide important information to help produce safe foods, but only if the testing and any standards applied are science-based and used appropriately, the National Food Processors Association told a Senate Agriculture Committee hearing.

"Microbiological standards are not a new concept, as they have been applied for decades in the processed-food areas," said Dane Bernard, NFPA's Vice President of Food Safety Programs. "These criteria have been a regular part of our food safety system, and they work. Further, microbiological criteria focused mainly on indicator organisms have been used routinely by the food industry, on a voluntary basis, for both raw and processed products as guideposts to indicate that there may be operational or production problems deserving investigation."

Bernard made his comments in testimony delivered at a Senate Agriculture Committee hearing titled, 'How Should Our Food Safety System Address Microbial Contamination?' held recently in Washington, D.C.

Addressing USDA's 1996 Pathogen Reduction HACCP Rule, which established mandatory microbiological standards for Salmonella for raw meat, Bernard noted that "these standards are the first time a bright-line, pass/fail standard based on frequency of finding Salmonella were broadly applied to products that are not ready-to-eat. While NFPA believes that the goal of providing more focus on microbiological quality is laudable, such standards simply are not appropriate when used as a pass/fail regulatory tool. Such standards do not measure whether a product is safe, or whether the operation that produced the product is sanitary. Such microbiological measurements are useful tools as operational or production quality-control indicators, but are not reliable as a definitive regulatory measure."

Bernard stated that "NFPA feels that there are opportunities to utilize results of microbiological testing of raw products to achieve the desired result of improvement in the food supply with a HACCP system. The approach we suggest is one where results of microbiological testing are used to indicate when an in-depth investigation is warranted, rather than as a determination that a product or an establishment is non-conforming solely on the basis of test results."

"In this day of farm-to-table food safety, it has become increasingly obvious that food safety is a responsibility shared by all stake-holders," Bernard concluded. "And clearly, it is the responsibility of the food industry to provide foods that meet the safety expectations of our consumers. Industry expends a significant amount of resources to conduct testing and self-inspection to meet this responsibility. At the same time, however, industry efforts to assure safe food are most successful within an environment of fair, science-based laws and regulations that facilitate the meeting of this objective.