Statement of the American Meat Institute

(Attribute Statement to AMI Senior Vice President for Regulatory Affairs and General Counsel Mark Dopp)

The goal of any food safety program should be to protect the public health. Data from USDA’s Food Safety and Inspection Service (FSIS) show that industry efforts to reduce Listeria monocytogenes (L.m.) in ready-to-eat meat and poultry have contributed to significant reductions in L.m. on products. Based on data from the Centers for Disease Control and Prevention, illnesses associated with L.m. also are decreasing, which suggests that industry efforts are yielding tangible results. These are the kinds of results that are good for our customers and good for businesses.

Leading microbiologists say that because Listeria originates in the environment, testing programs should be designed to find the bacteria in the environment and should trigger aggressive actions by plants to eliminate it. Listeria can be harbored in areas as minute as a scratch on stainless steel equipment or in the threads of a screw. Industry uses environmental testing widely, aggressively and voluntarily to target and destroy L.m. in areas like these and everywhere. Although it may seem counter-intuitive to some, good environmental testing programs must be designed to find Listeria so that aggressive actions can be taken to remove it from the processing environment. Environmental testing programs that only result in negative tests may not be working. The question is - will the government punish a company whose testing program works the way microbiologists say it should?

In order to regulate L.m. effectively, the government must premise its regulatory efforts on the scientific fact that Listeria is present widely in the natural environment and that it is highly likely to be found in every food processing plant. Regulatory efforts should encourage industry to test the environment and should not punish plants that work hard to find and eliminate L.m. from the environment.

Regulatory efforts also must consider that all plants and all products are not alike. The design of plants, equipment and sanitation programs can affect the likelihood that Listeria will be found. Product formulations also can make products more or less likely to support Listeria growth.

Sustained industry efforts since the mid-1980s should be credited with reductions in the incidence of L.m. on ready-to-eat meat and poultry. New efforts - like new ways of designing equipment to enhance sanitation and new ingredients that inhibit Listeria -- promise to deliver additional food safety enhancements in the future. Regulations that punish plants for finding and correcting potential problems are short-sighted and inconsistent with science.

AMI represents the interests of packers and processors of beef, pork, lamb, veal and turkey products and their suppliers throughout North America. Together, AMI's members produce 95 percent of the beef, pork, lamb and veal products and 70 percent of the turkey products in the U.S. Headquartered in Washington, DC, the Institute provides legislative, regulatory, public relations, technical, scientific and educational services to the industry. Its affiliate, the AMI Foundation, is a separate 501(c)3 organization that conducts research, education and information projects for the industry.