from major changes in sampling and
lab methods that have never been
documented to be comparable to the
methods used in the original study
conducted immediately before the
start of HACCP.
Many Food Safety and Inspection
Service reports acknowledge that
HACCP Salmonella data cannot be
used as estimates of national prevalence or serotype trends, even as the
agency uses the HACCP data for exactly those purposes in other reports.
The ;ve most common serotypes
usually cause between 50 percent and
60 percent of human salmonellosis
in the U.S., but the Food Safety and
Inspection Service insists that it is
valid to be concerned about Kentucky,
the 33rd leading serotype in human
illness and the number-one serotype
in chicken. The inclusion of Kentucky
in the Salmonella prevalence rate for
chicken guarantees that the calculated
prevalence rate has no relationship
to the risk of human illness, despite
the use of Salmonella prevalence
numbers by the Food Safety and
Inspection Service.
Aesthetics and clerical details get
emphasis
Along with the recommendation
to adopt HACCP systems in meat
and poultry inspection, the National
Research Council also said that for inspection to be scienti;c, critical control points must be given “foremost
importance over other control points
related to aesthetic considerations
or those considered as violations of
regulations.” Nonetheless, under the
current inspection system, control of
visible fecal contamination before the
chiller is a required critical control
point for Salmonella even though
carcasses with visible contamination
have not been shown to have a greater
risk of being Salmonella-positive. So
the only required critical control point
that HACCP plans must contain is
based on aesthetic considerations.
In terms of technical violations of
regulations being less important than
actual risk, some plants are still being
given Noncompliance Reports when
employees put the date in the space
for initials and initials in the space for
the date in HACCP records.
Five false claims in the HACCP Rule
What about the technical analysis of risk to human health that
the National Research Council
could not ;nd in Food Safety and
Inspection Service materials in 1985?
Concerning the microbiology of
processing, the Pathogen Reduction:
HACCP Final Rule makes many spe-ci;c claims that are wrong:
; False claim 1: The processing
plant is the ;rst and main opportunity for fecal and pathogen
contamination, which is “largely
preventable.”
; False claim 2: 90 percent of contamination occurs in the plant
; False claim 3: 90 percent of the
cost of human illness results from
contamination in the plant
; False claim 4: E. coli = feces =
pathogens
; False claim 5: Variation in E. coli
counts and Salmonella prevalence
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