| Comment Record|
Mr. Steven Roach ||
2002-08-19 12:37:30 |
Food Animal Concerns Trust |
Consumer Group |
| Comments for FDA General |
1. General Comments
The Comments of Food Animal Concerns Trust
On the Establishment of Program Priorities in the
Center for Food Safety and Applied Nutrition (CFSAN) for Fiscal Year (FY) 2003
August 18, 2002
Comments submitted by Steven Roach, Food Safety Program Manager
Docket Number 98N-0359
Food Animal Concerns Trust (FACT) is a non-profit organization that advocates better farming practices to improve the safety of meat, milk, and eggs. FACT's food safety work focuses on researching and promoting steps that can be taken by livestock producers to reduce the risk from foodborne diseases. FACT has a long history of working with the Food and Drug Administration on regulations aimed at reducing the risk from bovine spongiform encephalopathy and Salmonella enteritidis. FACT has also had direct experience in reducing foodborne pathogens through its management of farms participating in its Nest Eggs® program, a model egg farming system that includes Salmonella controls.
FACT would like to commend the Center for Food Safety and Applied Nutrition (CFSAN) for the steps it has taken to improve food safety for American consumers. The Centers for Disease Control and Prevention's (CDC) FoodNet data shows that the incidence of foodborne pathogens has decreased over the last five years and CFSAN can rightly take credit for its efforts during this period. While the reduction is good news, there is still much work to be done.
FACT is particularly concerned that the proposed egg safety rule for farm and retail (CFSAN 2002 Strategy Item 1.6.2) is not moving forward. This has been on the A list since 2000, and should have been implemented by now. The rule is designed to reduce the threat of disease caused by the pathogen Salmonella enteritidis (SE) from shell eggs. SE was the fourth most common bacterial foodborne pathogen reported to Foodnet in 2001. While there was a reduction in SE between 1996 and 1999, the SE incidence since 1999 has remained level. Currently there exists a mixture of state and industry based programs to control SE. A national rule is necessary so that all Americans can benefit from the proven control methods that we now know work.
FACT also believes that the program goals aimed at reducing the risk from transmissible spongiform encephalopathies (TSE's) should all be moved to the A priority list. In 2001, Bovine Spongiform Encephalopathy was detected in Japan, illustrating that the problem cannot be isolated to Europe. Given the large amounts of bone meal exported from Europe during the period when BSE was present, it is likely that BSE will soon appear in other countries outside of Europe. In 2001, the United States Department of Agriculture funded Harvard Risk Assessment found that minimizing consumption of the brain and spinal cord of cattle was an effective preventive measure to reduce the threat to human health from BSE. CFSAN should move quickly to develop a regulatory approach that implements this recommendation. Finally, there are new reports suggesting that consumption of wild game infected with Chronic Wasting Disease (CWD) may cause a TSE in people. The CDC is currently investigating 3 cases of neurological disease in men who consumed wild game in Wisconsin. Because of the horrible and always fatal nature of these diseases, CFSAN should act quickly to prohibit the use of elk or deer exposed to chronic wasting disease from CFSAN related products.
FACT appreciates this opportunity to provide input into the goal setting process of CFSAN. FACT encourages CFSAN to move forward quickly to publish and implement the proposed egg safety rule for farm and retail, and to develop new rules to reduce the risk from transmissible spongiform encephalopathies. By completing these important program goals, CFSAN will continue to improve the safety of food for American consumers. FACT looks forward to future opportunities to help CFSAN in this important work.