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 (NFPA) told a Senate Agriculture Committee hearing today.

"Microbiological standards are not a new concept, as they have been applied for decades in the processed food area," 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 a guidepost 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 on September 20 in Washington, D.C.

Addressing the U.S. Department of Agriculture'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 a useful tool as an operational or production quality control indicator, 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 within a HACCP system. The approach we suggest is one where results of microbiological testings 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."

Other points made by Bernard in his testimony included:
  • While it is widely accepted that the Hazard Analysis and Critical Control Points (HACCP) concept is the best system for assuring safety of foods, it is not a magic formula that will fix all food safety problems. HACCP can only be effective in controlling those hazards that pose a risk to consumers if adequate and appropriate control measures are applied. HACCP as a regulatory tool is still a work in progress. However, while some criticisms have been raised, NFPA continues to believe that HACCP offers the best approach to assure the safety of the food supply.


  • There must be a transition to an inspection force more attuned to hazards and their controls, and to the potential for certain actions to result in food safety problems. This will require specialized training, and the ability for inspectors to actually work together with industry.


  • NFPA continues to advocate better coordination between the Food and Drug Administration and the U.S. Department of Agriculture on food safety policy. Coordination and increased collaborative efforts by these agencies is essential to a uniform and effective inspection system.


  • The development of new ways to address hazards is our most important need. Time, money, and new, innovative ideas are clearly the chief barriers to the development and implementation of new technologies. To overcome these barriers - as well as to speed the regulatory approval of those technologies that have been fully developed, scientifically well-documented, and proven safe, such as irradiation - resources need to be allocated to provide the appropriate but expedited review of food safety enhancements. Congress must provide appropriate advocacy for technological innovation and effective oversight of government appropriations to assure that funds allocated for this purpose are being used effectively.
"In this day of farm-to-table food safety, it has become increasingly obvious that food safety is a responsibility shared by all stakeholders," Bernard said. "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."

NFPA is the voice of the $460 billion food processing industry on scientific and public policy issues involving food safety, nutrition, technical and regulatory matters and consumer affairs.

For more information on this issue, contact Timothy Willard, NFPA's Vice President of Communications, at (202) 637-8060, or visit NFPA's Website at www.nfpa-food.org.