Breaking Down the Beef Grinding Rule with Regulators

Food safety is often referred to as a "shared responsibility." When it comes to the safety of food within the supply chain, there are many stakeholders and each play a vital role in managing supply chain vulnerabilities. Food safety is a top priority for our industry and each stakeholder has a shared interest in protecting public health by ensuring the safety of the food supply.

Recently, FMI members hosted two store tours with government officials to demonstrate food retailers' processes for the grinding of beef and how the agency's proposed rule, Records to be Kept by Official Establishments and Retail Stores That Grind Raw Beef Products, will impact FMI members. If adopted, the proposed will require official establishments and retail stores that grind raw beef products maintain records identifying the source, supplier, and names of all materials used during preparation of products. This enhances the USDA Food Safety Inspection Service's ability to respond quickly to recalls and effectively trace back product to the source in the event of an investigation.

Maintaining records on meat ground at retail has remained both an issue of concern by regulators, as well as a challenge for some retailers, and recent food safety recalls and field inspection activities have raised the issue for more immediate action. According to FMI surveys, over three quarters of FMI members maintain records on the meat products ground at retail although the level of detail in the records varies greatly. Complete records result in more efficient recalls, which assist a retailer's ability to limit the scope and size of the recalled product.

In February 2013, FMI published a Best Practice Guide written and approved by FMI members. A sample recordkeeping form was also provided to members as a starting point for recordkeeping. In addition to recordkeeping, proper sanitation, employee training and hygiene, and control of product carry-over are all essential management tools in preventing product from becoming adulterated and facilitating investigations.

During the recent store tours, seven government officials from two Federal Agencies and three different departments–including representatives from the Office of Management and Budget (OMB), Office of Information and Regulatory Affairs (OIRA) and USDA Food Safety Inspection Service (FSIS), and USDA Office of Budget ad Program Analysis (OBPA)–participated.

Most of the government officials had never seen the process or practice of grinding beef at retail; they expressed and engaged us with questions throughout the store tours. Officials were able to go through various exercises, including using the USDA sample log, to garner better understanding of what happens behind the counter in retail stores. The two store tours were incredibly informative and an opportunity to demonstrate to OMB and USDA the practical impact of the proposed rule. The store tour effort represents an example of regulatory and industry efforts working together to share information and improve food safety.

As our industry begins to approach the court-ordered deadlines for the Food Safety Modernization Act (FSMA), several of which are due in 2015, actively engaging with regulatory officials will be key to successful implementation. Working with stakeholders is essential to developing policies that incorporate input from all interested parties to achieve the common goal of a safe food system–from farm to fork.

Hilary Thesmar, PhD, RD, is FMI vice president of food safety programs. Reach her at [email protected].