FSIS: Expansion of FSIS Shiga Toxin-Producing Escherichia coli (STEC) Testing to Additional Raw Beef Products (September 3, 2020)

Thank you for the opportunity to provide comments on the “Expansion of FSIS Shiga Toxin-producing Escherichia coli (STEC) Testing to Additional Raw Beef Products.” We appreciate the work that FSIS has completed on the reduction of STEC adulterants in meat and poultry products. Given several previous large-scale outbreaks due to nonO157:H7 STEC in ground beef, we welcome the opportunity to work with the agency on preventing contamination and protecting public health.

September 3, 2020 Docket Clerk U.S. Department of Agriculture Food Safety and Inspection Service 1400 Independence Ave, SW Mailstop 3758 Room 6065 Washington, DC 20250-3700 Re: Expansion of FSIS Shiga Toxin-Producing Escherichia coli (STEC) Testing to Additional Raw Beef Products Docket No. FSIS-2010-0023 Thank you for the opportunity to provide comments on the “Expansion of FSIS Shiga Toxin-producing Escherichia coli (STEC) Testing to Additional Raw Beef Products.” We appreciate the work that FSIS has completed on the reduction of STEC adulterants in meat and poultry products. Given several previous large-scale outbreaks due to non- O157:H7 STEC in ground beef, we welcome the opportunity to work with the agency on preventing contamination and protecting public health. About FMI As the food industry association, FMI works with and on behalf of the entire industry to advance a safer, healthier and more efficient consumer food supply chain. FMI brings together a wide range of members across the value chain — from retailers that sell to consumers, to producers that supply food and other products, as well as the wide variety of companies providing critical services — to amplify the collective work of the industry. www.FMI.org Overview FMI appreciates the work that FSIS has done to protect public health, educate consumers about food safety and to reduce the risk of microbial contamination on FSIS-2010-0023 September 3, 2020 Page 2 products under FSIS jurisdiction. We support expanded testing of beef to include other raw ground beef components as outlined in the notice in the Federal Register on June 4, 2020. Non-O157:H7 STEC have been a public health issue over the past few years with several major outbreaks as documented by FSIS in the notice. E. coli O157:H7 is not the only pathogen of concern in raw beef products. The industry and FSIS have made September 3, 2020 significant progress reducing the incidence of E. coli O157:H7 and we are optimistic that additional progress can be made to address all pathogens of concern. Docket Clerk U.S. Department of Agriculture The food retail and wholesale industries have strong food safety programs to source Food Safety and Inspection Service safe products, avoid contamination at the retail level and to protect the health and 1400 Independence Ave, SW safety of their customers. Retailers and wholesalers work with their suppliers to have Mailstop 3758 Room 6065 strong food safety management programs, comply with all regulatory requirements and Washington, DC 20250-3700 maintain strong communication channels to allow for fast responses when needed. Re: Expansion of FSIS Shiga Toxin-Producing Escherichia coli (STEC) Testing to Sampling should be early in supply chain to protect public health Additional Raw Beef Products Docket No. FSIS-2010-0023 We support the increased scope in testing for STEC for additional pathogens and in other additional ground beef components. We strongly encourage FSIS to evaluate the Thank you for the opportunity to provide comments on the “Expansion of FSIS Shiga appropriate point in the supply chain to sample for STEC. Sampling at retail at the point Toxin-producing Escherichia coli (STEC) Testing to Additional Raw Beef Products.” We of grinding is challenging because it is very likely that some product has already been appreciate the work that FSIS has completed on the reduction of STEC adulterants in sold to consumers at that point because it is from the same source material or lots from meat and poultry products. Given several previous large-scale outbreaks due to non- the supplier. Sampling earlier in the supply chain allows for product to be held and O157:H7 STEC in ground beef, we welcome the opportunity to work with the agency on recovered before any of the implicated product is sold to consumers. We encourage preventing contamination and protecting public health. sampling as close to the point of contamination as possible to quickly identify positive samples and to prevent further movement of product. About FMI FSIS already has a strong in-commerce inspection program that includes sampling and As the food industry association, FMI works with and on behalf of the entire industry to FSIS investigators frequently visit retail stores to evaluate compliance with applicable advance a safer, healthier and more efficient consumer food supply chain. FMI brings laws and regulations. When FSIS samples at retail, FMI encourages members to together a wide range of members across the value chain — from retailers that sell to segregate that product and hold or destroy the lot. If STEC sampling occurs at retail, we consumers, to producers that supply food and other products, as well as the wide would follow with the same recommendation to members. Holding a lot is much less variety of companies providing critical services — to amplify the collective work of the expensive than issuing a recall if that lot is positive for STEC or other pathogens. Most industry. www.FMI.org importantly, we want to prevent contamination and if contamination of pathogens occurs, we want to identify it and prevent it from entering commerce. Testing should be Overview used as a verification step as part of a complete food safety management program. 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Re: Expansion of FSIS Shiga Toxin-Producing Escherichia coli (STEC) Testing to Sampling should be early in supply chain to protect public health Additional Raw Beef Products Docket No. FSIS-2010-0023 We support the increased scope in testing for STEC for additional pathogens and in Hilary Thesmar, PhD, RD, CFS other additional ground beef components. We strongly encourage FSIS to evaluate the Thank you for the opportunity to provide comments on the “Expansion of FSIS Shiga Chief Food and Product Safety Officer and SVP Food Safety appropriate point in the supply chain to sample for STEC. Sampling at retail at the point Toxin-producing Escherichia coli (STEC) Testing to Additional Raw Beef Products.” We of grinding is challenging because it is very likely that some product has already been appreciate the work that FSIS has completed on the reduction of STEC adulterants in sold to consumers at that point because it is from the same source material or lots from meat and poultry products. Given several previous large-scale outbreaks due to non- the supplier. Sampling earlier in the supply chain allows for product to be held and O157:H7 STEC in ground beef, we welcome the opportunity to work with the agency on recovered before any of the implicated product is sold to consumers. We encourage preventing contamination and protecting public health. sampling as close to the point of contamination as possible to quickly identify positive samples and to prevent further movement of product. About FMI FSIS already has a strong in-commerce inspection program that includes sampling and As the food industry association, FMI works with and on behalf of the entire industry to FSIS investigators frequently visit retail stores to evaluate compliance with applicable advance a safer, healthier and more efficient consumer food supply chain. FMI brings laws and regulations. When FSIS samples at retail, FMI encourages members to together a wide range of members across the value chain — from retailers that sell to segregate that product and hold or destroy the lot. If STEC sampling occurs at retail, we consumers, to producers that supply food and other products, as well as the wide would follow with the same recommendation to members. Holding a lot is much less variety of companies providing critical services — to amplify the collective work of the expensive than issuing a recall if that lot is positive for STEC or other pathogens. Most industry. www.FMI.org importantly, we want to prevent contamination and if contamination of pathogens occurs, we want to identify it and prevent it from entering commerce. Testing should be Overview used as a verification step as part of a complete food safety management program. FMI appreciates the work that FSIS has done to protect public health, educate consumers about food safety and to reduce the risk of microbial contamination on