Current Controversies in Food Safety - APHL...Raw milk cheese & food safety Feb 2013 ‐FDA...
Transcript of Current Controversies in Food Safety - APHL...Raw milk cheese & food safety Feb 2013 ‐FDA...
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Current Controversies in Food Safety
Which side of the fence are you on?
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Culture Independent Diagnostics
Dr. Robyn Atkinson Dunn, Utah Dr. Vickie Baselski, UTHSC
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Are you familiar with the term Culture Independent Diagnostics (CIDT)?
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Are you aware of the threat to public health surveillance due to CIDTs?
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Should clinical laboratories maintain the capability to perform culture for
foodborne pathogens?
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Culture Independent Diagnostics
VS.
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Should clinical laboratories maintain the capability to perform culture for
foodborne pathogens?
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Should clinical laboratories maintain the capability to perform culture for foodborne pathogens?
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Raw Milk Testing
Audrey Pilkington, North Carolina Dan Rice, New York
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Is regulatory testing of raw milk for pathogens a good use of public health
resources?
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NC Dairy Law and Regulations
Do not allow sale of raw milk for human consumption
Allow raw milk sales for animal feed if labeled “NOT FOR HUMAN CONSUMPTION”
Adopted PMO for Grade A Milk Adopted USDA AMS Recommended
Requirements for Manufactured Milk
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Farmstead – A milk or milk product processing facility that uses only milk from its own animals in its products and has
no other source of milk.
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Farmsteads in NC
2012 – 31 farms 2013 – 47 farms ~75% Goat
~25% Cow A few sheep
Products Cheese – pasteurized & raw milk Butter – pasteurized milk Frozen Desserts – pasteurized
milk
Consumer base =1,000’sOn farm, retail,
restaurants, farmer’s markets and online sales
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Raw milk cheese & food safety
1950 – FDA 60‐Day Rule age cheese a minimum of 60 days > 30 natural cheeses that can be made legally
from raw milk in the US under this rule
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Raw milk cheese & food safety
Feb 2013 ‐ FDA published “Draft Risk Assessment of Listeriosis from Soft‐Ripened Cheese” Joint effort between USFDA and Health Canada Comment period closed 4/29/13 Outcome may impact the 60-Day Rule
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“The 60‐day aging rule is based on the theory that pathogens, if present, will die‐off to levels below the infectious dose during the aging process. However, the effectiveness of this system depends on the initial microbiological quality of the milk and other ingredients used, and the hygienic practices used during cheese processing.” (Donnelly,Catherine 1990. Concerns of microbial pathogens in association with dairy foods. J Dairy Science 73:1656‐61.).
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Support for NC Farmsteads
Educate then Regulate 2 POCs
Dairy Compliance Officer Field Inspector
Pre‐startup Inspections Facility and Process Inspections 4x/yr
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Support for NC Farmsteads
Milk Testing o Farmer pays shipping costs only
Supplies
o Insulated shipper o Sampling containerso Labels
• Unofficial Samples
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Sample Collection & Analysis
Raw Milk Somatic cell count ‐
DMSCC Bacterial count ‐ APC Drug residue ‐ Beta‐
Lactams Sediment + Pathogen Screen+ Aflatoxin M1
Frequency ~ monthly
Finished ProductPathogen Screen
Operations Water ColiformAPC
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2012
# samples tested
% violations
Lab testing cost/year
Raw Milk 125 20%
DMSCC [14]APC [10]
drug residue [1] Salmonella [1] ~ $25,000
Cheese * 31 7% E .coli [2] ~ $6,000
* Finished product collected during inspections or follow‐up to violative raw milk samples.
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Should regulatory agencies test for pathogens in raw milk used for the mfg of cheese? Yes
Cost of testing is low vs. cost of foodborne illness Large consumer base ‐ wide distribution of farmstead products Cheese consumer may not be aware the cheese they are purchasing is made from raw milk
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Should regulatory agencies test for pathogens in raw milk used for the mfg of cheese? Yes
60‐Day Rule may not be an adequate food safety control Pathogen testing…. is not a silver bullet one key component of the services provided in a
partnering, educational relationship between regulatory agency and farm
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Raw milk in NY State
• Sales of raw milk for human use are legal in NY only at the farm of production
• Farms must have a permit from NY State Dept. of Agriculture and Markets (NYSDAM)
• > 40 permitted farms• Customer base = 1,900 consumers statewide
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Raw milk in NY State
• NYSDAM inspect permitted farms monthly• Collects raw milk samples quarterly• Samples tested for foodborne pathogens• Positive samples initiate a recall, implicated product destroyed
• Point of sale have prominent sign warning consumers of risk
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Testing results
• < 2 % are pathogen positive• Most common pathogen is L. monocytogenes followed by Campylobacter coli and jejuni
• Raw milk implicated in less than 1 outbreak/year in NY State
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What happens when a sample is positive?
• Positive samples initiate a recall, implicated product destroyed, permit to sell suspended
• Weekly samples collected and tested until 2 negatives in a row – permit to sell reinstated
• Many recalls result in lawsuit by producer against NYSDAM
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Resources commitments• NYSDAM has one attorney who works on raw milk litigation full time
• ~ 180 samples/year tested, 10 % of total samples tested for pathogens consumer base = ~ 1,900
• Remaining 90 % of samples represent a consumer base > 18 Million
• Raw milk is tested for pathogens 10,000 X more intensively than other high risk foods
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Statement against testing• Raw milk consumers generally aware of the public health professions evidence‐based assertion that consuming raw milk is dangerous to one’s health – choose to ignore warnings
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Statement against testing• Testing raw milk 10,000 times more intensively than other high‐risk foods is hard to justify
• Limited laboratory surveillance resources should be dedicated to high‐risk foods consumed by the general population
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Discussion
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Is regulatory testing of raw milk for pathogens a good use of public health
resources?
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1. Yes2. No3. No opinion
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Is regulatory testing of raw milk for pathogens a good use of public health resources?
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