Meat&Poultry - July 2011 - 44

TEST-AND-HOLD

their customers about just-in-time orders,” he adds. “When there is a regulation, the complexity goes up, because FSIS could say, ‘This is the way everyone should do it.’ ” He notes inspection personnel already work with establishment management to get the samples. There were some i n it i a l problem s re garding FSIS sampling methods, he says, but over the years that has been greatly improved. “Rarely do I hear of problems regarding this Wenther issue,” he says. Wenther raises one method to avoid problems when a product is being held due to testing. “It depends on the product being tested. If FSIS is taking a ground beef sample for E. coli O157:H7 testing, the establishment could grind a smaller batch of ground beef, stop, clean up, document the sample information and the sanitation procedures, switch source material and produce another lot of product. This would mean less product would be held and production wasn’t hindered by taking the sample,” he says. W hi le he ag rees recal ls have spurred t he move to mandatory “test-and-hold” practices in the meat and poultry industry, he asserts some recalls that have taken place could not have been avoided simply by retaining control of product. Wenther criticizes one idea advanced a few years ago to make it easier for very small establishments to carry out “test-and-hold” successfully. That would involve one company asking another company – a competitor – to make the product for distribution while the first company’s product is undergoing FSIS sampling. “That’s kind of ridiculous,” he says. Another problem, he says, is withholding the mark of inspection and not having pre-shipment review until test results are returned could result in a company manager forget-

ting to sign off on pre-shipment after the test results come back. But there are some practices that would make testing and holding product easier and more successful for plants of all sizes, including very small and small ones. AMI’s Dopp says FSIS will permit product to move before test results come back from the agency, as long as product is being controlled by the fi rst establishment, and not yet turned over to a customer. This would include product being shipped in trucks on the road, moving from one location to another. “The product has to still be under the control of the original establishment, and not yet sold to another

“The mandatory test-and-hold regulation is the best way for industry to handle this situation, protecting both itself and consumers.”
customer for further processing or utilization,” he says. “We wanted to eliminate the circumstance where a plant knows it’s been sampled, but hasn’t gotten the result yet, which would result in a recall if the test was positive.” Dopp notes once or twice in past years, a product was being controlled by the establishment, but got shipped to the customer inadvertently. “That’s just a mistake and people will make mistakes,” he says. “But if you look at the USDA press releases describing recalls, you’ll see many of them indicating the company didn’t hold the product.” AAMP’s Wenther points to freezing tested, fi nished products, resulting in a longer shelf-life, or coming up with new systems to identify and track materials based on their suppli-

er or lot – these are some adjustments that could be made to help establishments control tested product. Plants could also take other steps to control tested product, including keeping tested product separated from other products, and working with FSIS inspectors to arrange advance notification (up to 30 days) when samples are taken. “We’ve found is when our members make changes, such as issuing specific guidelines for their operation or using tags to identify lots and shippers, they realize holding the product is a good business practice that can be accomplished,” Wenther says. A n FSIS spokesman says t he agency appreciates the concern some very small establishments might lose products or experience disruption in business activities. FSIS inspector notification to the plant of sampling activities ahead of time would help plants deal with this concern. The agency is also seeking additional suggestions in comments to the “testand-hold” notice.

The better alternative
Dopp says the mandatory test-andhold regulation is the best way for industry to handle this situation, protecting both itself and consumers. “This rule avoids really bad legislation, which would be a much worse problem to deal with,” he says. Wenther hopes most of his members have “test-and-hold” plans in place. But he believes the rigidity of the regulation will be a factor when it is implemented, making it harder for inspectors to avoid hurting a company schedule when they sample. “I’m sure there will be complications, but if the industry and the agency can work together, we will get through the complications,” he says. ■
Bernard Shire is a contributing editor based in Lancaster, Pa. Shire also works as a food safety consultant and writer for Shire & Associates LLC. We would like to hear from you – to comment on this story or to request reprints, contact us by email at meatpoultry@sosland.com.

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