Regs, Rules and Remedies By William James
Dr. William James capped a 28-year career at USDA’s Food Safety & Inspection Service (FSIS) as the agency’s chief veterinarian. During his career in FSIS he worked in the offices of Field Operations, Policy, Science, and International Affairs. James supervised district offices, coordinated animal welfare enforcement throughout the country, directed ante-mortem and post-mortem inspection of livestock and poultry, implemented pathogen and residue sampling and had executive oversight of import and export issues for FSIS.

Unnecessary precautions

(The views and opinions expressed in this blog are strictly those of the author.)

Snuffy was the kids’ dog.  Grew up with them.  A beagle, so he was always hungry. 

Worst decision of my life was letting the kids make a house dog of him.  No food was safe around that ravenous animal.  Good thing he was short.  If you made the mistake of setting your plate or bowl where he could reach it, you picked it up empty. 

The kids grew up and moved out.  Eventually, Snuffy moved on, too.  Sixteen years is a long life for a dog.  At least, it seemed long to us.

Snuffy has been gone for two years now and we have no other pets, but we still can’t bring ourselves to set a plate or bowl on the floor by the couch or leave any remnants of food where they might be reached by an ever-hungry beagle.  They’re unnecessary precautions, but we can’t seem to let go of them.

Changing gears a bit, many of you remember the terrible news when the first case of Bovine Spongiform Encephalopathy (BSE) was diagnosed in the United States.  The news was released on December 23rd, 2003 and life for the beef industry in this country changed for the worse. 

In a matter of weeks, the Food Safety and Inspection Service (FSIS) issued an Emergency Final Rule establishing various tissues in cattle of particular ages as “specified risk materials,” or SRMs.  SRMs are recognized as potential sources of infectivity for BSE, and should be condemned in countries with BSE.  The rule was published in 2004.  Ten years ago. 

But the situation is different now.  Due to the diligence of government and industry both before and after the index case, BSE has never been able to gain a foothold in this country.  In May of last year, the World Organization for Animal Health (OIE) declared the U.S. to be at “negligible” risk for BSE.  “Negligible” risk is the OIE’s best classification for the disease.  It’s an important upgrade.

Our national beef nightmare is over, right?  Not entirely.

FSIS continues to require unnecessary precautions related to BSE.  The Agency announced in a Federal Register Notice on Jan. 13 its intention to renew information collection about SRM management by federally inspected establishments.  As you already know, SRM removal is required by beef plants.  Companies must also have written plans and create records regarding removal and disposal of SRMs.  FSIS has no plan to rescind the SRM regulations.

Although FSIS is hanging on to the SRM regulations, the OIE does not require these precautions to maintain the designation of “negligible” risk, or to trade in beef from “negligible” risk countries.  Also, the Animal and Plant Health Inspection Service published a progressive final rule last November bringing the United States in line with reasonable international trading norms according to OIE risk guidelines. 

It doesn’t help our export negotiations when we try to convince another country to accept U.S. beef according to international standards, but we don’t trust our own risk evaluation.  Importantly, there has never been a recorded case of the human form of BSE (variant Creutzfeldt-Jakob Disease) acquired in the United State. Review of past cases of Alzheimer’s Disease by the Centers for Disease Control and Prevention supports this assertion.

But FSIS can’t seem to let go of its precautions. 

The rule is costly for both processors and taxpayers.  It has no measurable public health benefit.  By definition, there is negligible risk.  It’s time for FSIS to stop acting like the James household and just move on.

I still miss that pesky dog.


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