I am frustrated that Consumer Reports and other companies will not distinguish us and other small producers who offer a premium troll caught canned tuna. Yes it costs more money and no it is not in every store in the US. Since our tuna is canned in the USA, it is going to cost more money to be produced and is produced under more strict processing standards.
Not all albacore in the can is the same either. We offer you young and fatty, low mercury, high omega 3, sustainably caught albacore tuna.
Our very professional crew is paid well. This of course adds to our cost of production.
Albacore tuna migrate out of our fishing zone into tropical water at age 3-5 approximately. This fact largely explains how it is that we are catching ONLY the young albacore (under 5 years old.)
This is one of the most sustainable fishing methods in the world, virtually no other species are caught using this method. If you purchase less expensive tuna from big producers, generally you are purchasing longline caught tuna. Longline fishing catches the older larger albacore (and significant other species) in tropical water. These albacore have been collecting mercury throughout their 15-20 year life and have built up mercury in their system.
We do test our tuna for mercury, our results are posted on our website tunatuna.com.
Not all albacore are the same. I fished albacore on the St. Jude for 15 years, throughout that time I observed that the albacore we catch are small (a good trip average is 15 lbs per fish.) Further testing has indicated that these fish have high omega 3 and selenium.
We understand and regret that not everyone can afford to buy canned tuna processed in the United States that is caught by fishermen who are paid fairly. But we want to create awareness that cheap tuna is a bad thing on many levels.
You can tell the difference between these pictures, ours is the canned tuna on the right. The fat from the tuna is glistening and
The meat is solid since the fish is cooked from raw in the can. You will notice that the muscle in the “other” can is seperated, this is because the fish is conventionally processed – pre cooked (whole) before filling the can. In this method the fish is steam cooked while round (to avoid the expense and loss of recovery implied by filleting.) The effect of this processing method on the flavor and content of the meat is unavoidable.
Our tuna is properly handled and canned in the United States. Thank you all for your support.
Joseph and Joyce Malley St. Jude tuna
When the Washington Post, members of Congress, and 35 other organizations [1] raised concerns about a proposed modernization of a food safety and inspection process, we needed to provide a scientific perspective to the issue. The U.S. Department of Agriculture’s Food Safety and Inspection Service (FSIS) proposed a regulation called the New Swine Inspection System (NSIS). The Washington Post article claimed the “Pork industry soon will have more power over meat inspections” and Congress has threated to withhold appropriations because of increased line speeds as a result of implementing the NSIS.
TheNational Association of Federal Veterinarians (NAFV) supports the proposed NSIS. NAFV’s members constitute the nation’s largest block of scientific and technical expertise in the area of food safety and slaughter inspection and have determined the new system will enable a more scientific basis for ensuring food safety for the public.
On Jan. 19, 2018, FSIS announced its continued effort to modernize inspection systems through science-based approaches to food safety. USDA has proposed to amend the federal meat inspection regulations to establish a new inspection system for market hog slaughter establishments called the New Swine Inspection System (NSIS), while also requiring additional pathogen sampling for all swine slaughter establishments [2].
The NSIS places more emphasis on the critical control points for contamination and uses microbiological testing in addition to visual inspection to ensure slaughter processes are producing safe foods. The new system does not relinquish any “power” to slaughter plants, FSIS will have all the same authorities to enforce food safety standards as before. The NSIS is a major step forward in improving the slaughter inspection systems of the U.S. to provide safe food to the public. Increased line speeds and the impact on plant employees will be monitored by the Department of Labor’s Occupational Safety and Health Administration (OSHA) which has that jurisdiction. Line speed are set and adjusted for optimal efficient food safety inspection and worker safety precautions. FSIS sets the cap based on industry standards and outcome of inspections.
On April 8 this year FSIS released a response to the article, condemning it for false reporting. Specifically, FSIS clarified that only federal inspectors perform meat inspections and will continue to conduct 100 percent ante-mortem inspections and 100 percent carcass-by-carcass inspection at post-mortem. The agency will make staff determinations on a case-by-case basis and will not be decreasing inspectors by 40 percent. Under the proposal, establishment employees sort market hogs before FSIS inspection, which is consistent with current policy for establishments under traditional inspection.
[1] https://www.farmprogress.com/usda/comment-new-swine-slaughter-inspection-system-through-april-2
About the author: Dr. Joe Annelli, DMV, is executive vice president for National Association of Federal Veterinarians (NAFV), following 32 years as a federal veterinarian in the USDA’s Animal and Plant Health Inspection Service. He worked in a variety of jobs including section VMO, national swine epidemiologist, staff veterinarian, senior staff veterinarian, chief staff veterinarian, director of emergency programs, and director of the One Health Coordination Center.
Annelli graduated from the Araneta University College of Veterinary Medicine in the Philippines and completed his senior year of clinical rotations at the University of Tennessee College of Veterinary Medicine. He was in private practice briefly in Knoxville, TN, and Brooklyn, NY. He completed a graduate program at the University of Minnesota’s College of Veterinary Medicine in swine medicine, veterinary epidemiology and public health.
The NAFV, founded in 1918, is recognized by the USDA as the representative organization for federally employed veterinarians and as an association of managers and supervisors.
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]]>Editor’s note: Letters to the Editor can be submitted via the Contact Us link on our website.
Dear Editor,
When the Washington Post published a story, “Pork industry soon will have more power over meat inspections,” FSIS proffered the “Oath of Office” in an attempt to place its employees, “civil servants with the noblest of missions,” on the moral high ground. Persons appointed within the civil or uniformed services take the “Oath of Office” [5 USC 3331]. FSIS would have you believe that it is an oath “to protect the American food supply.” Not true. It is an oath to “support and defend” and “bear true faith and allegiance to” the Constitution. FSIS does not “bear true faith and allegiance to” the Constitution!
Article I, Section 8 grants Congress the power “To regulate Commerce … among the several States …”. The power of Congress to regulate is without limit. The Federal Meat Inspection Act (FMIA) is a manifestation of that power.
Article II, Section 3 tasks the Executive to “take Care that the Laws be faithfully executed.” The FMIA tasks the Secretary of Agriculture with execution. He/she delegates to the Under Secretary, who delegates to the FSIS Administrator.
The 5th Amendment prohibits the deprivation of “liberty, or property, without due process of law” to protect persons from unreasonable rules and unfair proceedings made possible by the unlimited power of Congress. Enforcement actions are deprivations of liberty and/or property. Due process requires the Administrator to afford notice and a hearing before an impartial tribunal when taking an enforcement action.
- Notice must enable the recipient to determine what is proposed and what he must do to prevent the deprivation. [Goldberg v. Kelly, 397 U.S. 254, 271 (1970)]
- A hearing is required before an individual is deprived of a property or liberty interest. [Mathews v. Eldridge, 424 U.S. 319, 333 (1976)]
- The tribunal cannot have a direct, personal, substantial, pecuniary interest in a case. [Tumey v. Ohio, 273 U.S. 510 (1927)]
If the Administrator refuses or withdraws approval of marks, labels, and containers, or refuses to provide or withdraws inspection service, he/she elevates the action to the Secretary for proceedings under the Uniform Rules of Practice [7 CFR subtitle A, part 1, subpart H], which afford due process of law and “bear true faith and allegiance to” the Constitution.
If the Administrator takes a regulatory control action, withholding action, or suspension, he/she delegates authority [9 CFR 300.4(a)] to the FSIS, Office of Field Operations, Assistant Administrator, who delegates to a District Manager (DM), who tasks FSIS supervisors and inspectors (IPP) at the establishment level. Under the FSIS Rules of Practice [9 CFR 500], IPP afford notice, but DM reserve the right to implement a withholding action or impose a suspension without notice. The Administrator affords the option to appeal; but affords no hearing before an impartial tribunal. The Administrator may hold a suspension in abeyance in lieu of a request that the Secretary withdraw inspection service and allow the establishment to operate under conditions agreed to by the Administrator and the establishment.
FSIS Directive 13,000.3 instructs the DM and IPP, to respond to appeals within suggested timeframes, but response times may be extended at DM and IPP discretion. The directive instructs the DM and IPP, to communicate the appeal decision to the establishment but require no explanation when denying an appeal. The immediate supervisor of the FSIS employee taking, or upholding, the enforcement action decides the appeal outcome. Appeals denied by the Administrator can be appealed in Federal District Court [5 USC 701 et seq]. The filing fee is $400.
The concept of imminent danger does not apply. Neither the public health, nor food safety, are in peril. The mere necessity for quick action does not constitute a public emergency. The circumstances supporting FSIS enforcement actions occur within official establishments under direct IPP oversight. The FSIS Rules of Practice do not “bear true faith and allegiance to” the Constitution!
- When government officials with direct, personal, and/or substantial interests can deny valid appeals of unsupportable enforcement actions without reason; justice is denied.
- When citizens must pay $400 for access to an impartial tribunal; justice is denied.
- When suspension can force bankruptcy and loss of the right to a hearing [Munsell v. USDA, 509 F. 3d 572 (2007)]; justice is denied.
- When submission to government conditions is the cost of a suspension in abeyance; justice is denied.
FSIS weaponization of the law coerces those least able to defend their Constitutional rights and fight unconstitutional regulatory practices into submission to unelected FSIS bureaucrats. What can be done? Congress could prohibit suspension or withdrawal of inspection without a self-evident public health threat. The Secretary could place the FSIS appeal process under the USDA, National Appeals Division. The Administrator could reform the FSIS rules of practice and incorporate quality and procedural controls.
The Fifth Amendment protects Americans from being deprived of life, liberty, or property, without due process of law. I took the “Oath of Office” six times: four enlistments, joining FSIS, and commission as a US Army officer. When I retired from the Army, I retained my commission; meaning I maintain the oath. Needless to say, the oath resonates with me, viscerally. I write this to “support and defend” the Constitution. No statute, regulation, or USDA policy compels the FSIS Administrator to implement rules of practice that “bear true faith and allegiance to” the Constitution. That offends me. I hope it offends you too.
— Michael Fisher
Retired career FSIS employee
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]]>Editor’s note: We want to hear from our readers, and that’s you. Letters to the Editor can be submitted via the Contact Us link on our website.
Dear Editor,
2018 has been marked by high profile food recalls ranging from romaine lettuce and thousands of pounds of ground beef to Ritz Crackers and goldfish. Grocery shopping shouldn’t be a game of Russian Roulette where what you pick up for dinner might make you and your family sick.
Over the past 40 years, we’ve gotten a lot better at identifying foods that are contaminated, but that’s not enough. From tracing the cause of contamination, identifying the variety of products affected by the contamination, removing them from shelves, and notifying consumers who may have already purchased them; locating the food is just the first step.
One potential solution to these problems is blockchain, which many know as the technological backbone of cryptocurrencies like Bitcoin. Tech innovators are working on using blockchain technology to monitor supply chains in everything from retail and pharmaceuticals to health insurance and industrial emissions.
Essentially, blockchain is a decentralized cloud-based ledger that, as Frank Yiannas, vice president of food safety for Walmart, says, could become the “equivalent of FedEx tracking for food.” Each time there is a transaction in the food’s journey, information about it is added as a “block” to the online network ledger. Information from harvest crew, date, and time, to temperature, storage, and sanitization along each step of the path from farm to store can be easily and quickly uploaded.
This transaction information can be vital to containing the public health impacts of contamination. For example, in 2015 an E. Coli related flour recall was made a whopping 6 months after the initial outbreak of the disease was discovered. These delays risk serious health consequences and point to the need to streamline the process of agriculture supply chain transparency.
The obvious challenge in implementing blockchain technology in food safety is in accurately collecting and inputting the data into the ledger. Additionally, producers, who already backlash to food safety auditors may not buy into the process. However, increasing consumer demand for traceability may push the use of transformational technology like blockchain into the public eye. Updating our food safety policies to give producers and consumers the information they need to protect themselves will will demand new methods and technologies.
— Viveth Karthikeyan
]]>Editor’s note: We want to hear from our readers, and that’s you. Letters to the Editor can be submitted via the Contact Us link on our website.
Dear Editor,
Fecal contamination is very common in the butchering process of animals. During the process of disemboweling the chickens, the intestines may break or cut accidentally. Fecal material is spilled on and into the chickens. Fecal material is loaded with E. coli and Salmonella in chickens. The chickens are run into ice bath to cool and are allowed to gain 13 percent water weight gain from cooling process. The ice bath contains fecal material from normal slaughter process and exposes all the birds to contamination. Line speeds are exceeding fast and USDA inspectors do not touch birds to examine birds, but use mirrors to see the back side of birds.
Work has been done to reduce the Salmonella in live birds, but you still have to handle the chicken properly at home, and wash hands often, not cross contaminate and sanitize work areas.
Support for irradiation of meat is very poor, but is the only way you can get it 100 percent clean. I have not heard of lab grown chicken yet, but that may come soon.
Cattle are exposed to fecal contamination in some different ways. The crowded beef in waiting pens are exposed to fecal matter on the hides. The dried fecal material on hide will become airborne when the hide is pulled off the animal exposing all the carcasses to fecal dust.
Now before we panic, there is some good news. All of us are full of good E. coli which helps us to digest food. Beef is said to be tastier after being in cooler and the good bacteria growing on it than just after slaughter. Lucky for us that the 0157 strain of E. coli is uncommon. The problem is that in big plants the meat is processed and shipped in many different directions making recall difficult.
Bottom line is to take responsibility for sanitation at home and be open to the idea of irradiation.
Scott Vandell, registered sanitarian
Division of Health Protection, Public Health Services for RiverStone Health of Billings, MT
Editor’s note: We want to hear from our readers, and that’s you. Letters to the Editor can be submitted via the Contact Us link on our website.
I try to read about food safety threats and notify family and friends every time see one that is pertinent. Each time, it occurs to me that there is an “us vs. them” attitude between producers and inspection authorities. The “us vs. them” should be between us as humans and the threat, usually bacteria, aka bugs. Instead, it becomes a point-the-finger, blame-game competition.
In the case of the Kerry company, for instance, why not collectively”do the necessary operations to prevent continuation of the danger? That means the government agency would assist in the correction process, not just point out there is — or might be — a problem.
My life experience was in commercial construction. We had numerous safety inspections, audits and weekly meetings pointing out — what we already knew — that construction is a potentially dangerous profession. The only people who actually helped were those who presented viable solutions to a given problem. Sometimes it was training, usually the responsibility of respective unions, employers and knowledgeable, experienced, employees — not necessarily the inspector.
At one point, the threat of an OSHA inspection was considered a reason for our company to close the project rather than allow an inspector to impose unreasonable fines and even the threat of imprisonment for their perception of willful violations of the rules. The adversarial relationship was counter-productive.
On food safety there must be a concerted effort between FDA — or whoever is in charge of regulating a specific food — and businesses to end the threat, not to point fingers.
Just a thought from someone who is not really close to the problem, except I do eat food. In the Kerry plant, couldn’t it be closed for clean-up. like starting with live steam as in the old days?
And to promote an actual solution, why not a “super fund” to assist each unfortunate company that is cursed with these problems to clean and sanitize? That could help offset the expense of doing the right thing. Of course, I can see how this could be used by the unscrupulous to turn a profit just as so many well-intentioned ideas have in the past.
Bottom line: It is us humans vs. them bugs, not each other.
— Jim Dixon
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]]>Let’s be clear and stick to the facts when discussing line speeds in poultry plants. Parsing words and bending facts will have real victims: consumer and worker safety. There is no such thing as just increasing line speeds in the inspection area of a plant and not impacting the line speeds in the entire plant. FSIS was clear in acknowledging this when it proposed changing the way poultry would be inspected.
A line speed increase not only increases how many birds per minute are slaughtered and inspected, it results in more birds being processed per minute throughout the plant. And when it comes to worker safety, there is no doubt that the faster the line speeds the greater the risk of harm to workers. Let’s look back at the original rulemaking process.
In August of 2014, the USDA’s Food Safety and Inspection Service (FSIS) promulgated the final rule for the Modernization of the Poultry Slaughter Inspection System. The final rule, which created the New Poultry Inspections System (NPIS), went through almost two-and-a-half years of public notice and comment, during with the USDA received more than 250,000 public comments. According to FSIS, the issue they received the most comments on was the potential negative effect that increased line speeds might have on the health and safety of workers in poultry slaughter establishments.
The final poultry inspection rule promulgated by the FSIS did not contain a line speed increase. In fact, as part of the rulemaking, the agency flatly rejected any line speed increase in poultry plants. Instead, the FSIS decided to maintain the existing maximum line speed of 140 birds per minute. In making this decision, it should be clear that the USDA considered extensive comments on all sides: the poultry industry, worker advocates, consumer safety experts, and other affected stakeholders. In reaching this conclusion, the government specifically explained that maintaining the maximum line speed of 140 birds per minute would allow the agency to assess the impact of the various changes and new technologies adopted by establishments under the NPIS.
Most important to this debate, FSIS also specifically concluded that they would not reconsider this decision on maximum line speed rates until the NPIS had been fully implemented on a wide scale and the agency had gained a least a year of experience under the new system. According to FSIS, poultry plants are slowly opting into the new system, and as of yet there has not been wide scale implementation.
In its initial proposal, USDA clearly stated that any increase in the maximum line speed would not only affect the inspection process, but would result in more birds being processed per minute. That’s right, more birds being processed per minute. The USDA was clear that if current inspection line speeds were increased, workers in poultry plants would be processing more birds per minute.
It was clear that the speed governing inspection of newly slaughtered birds in poultry plants also affects the speed at which workers in both the slaughter and processing sides of the plants would be working.
The petition by the National Chicken Council requests that chicken plants be able to run their lines as fast as they would like. They are advocating for no line speed limits at all. This request is made despite the fact that even in the 20 chicken plants that are in an old pilot program (HIMP) that allows chicken plant line speeds up to 175 birds per minute, the average line speed is 131 birds per minute, well below the currently allowed 140 birds per minute.
There are many additional arguments beyond endangering workers and consumers on why the USDA must reject the NCC’s petition—including that it would undermine the rulemaking process, violate the Administrative Procedures Act, and would be inconsistent with the Department’s wavier regulations. But it’s important not to obfuscate the issue.
The author is a Senior Fellow at the non-partisan, not-for-profit National Employment Law Project. She previously served as the Chief of Staff and then Senior Policy Advisor at the Occupational Safety and Health Administration.
Deborah Berkowitz
Senior Fellow, National Employment Law Project
Previously Chief of Staff and Senior Policy Advisor, at the Occupational Safety and Health Administration
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]]>
On Jan. 19, the U.S. Department of Agriculture released a proposed rule that would lift current caps on line speeds in pork processing plants and reduce federal oversight in these facilities.
The proposed rule is strongly backed by the meatpacking industry, but the fact is that raising line speeds in pork processing plants will only make a bad situation worse. Workers who bring food to our tables deserve safety and dignity on the job, and consumers deserve and demand safe food.
If the USDA proposal goes into effect as written, the result will be a higher risk of food contamination and more amputations and other disabling injuries for animal slaughtering workers.
The USDA is proposing to allow pork producers to use their own staff, in place of federal inspectors, to look for fecal matter and other contaminants on the pork processing lines. This approach has already been tried, with alarming results. A report from the USDA’s Office of Inspector General found significant problems with food safety issues at pork processing plants that have piloted “self-inspection.”
Meatpacking workers currently experience a higher rate of occupational illnesses than workers in any other industry, 17 times higher than workers nationwide. The USDA proposal is part of an industry-backed plan to privatize safety inspections at U.S. pork processing plants, which currently slaughter an average of 1,100 hogs per hour.
The USDA should put this unwise proposal back on the shelf, and come back with a plan that provides rigorous, science-based protections for everyone who produces our food – and everyone who eats it.
Jessica Martinez
Co-Executive Director, National Council for Occupational Safety and Health
Celeste Monforton
Public health lecturer, Texas State University
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]]>Editor’s note: California State Veterinarian Annette Jones submitted this letter in response to a letter posted from a group of faculty and staff from the Johns Hopkins Center for a Livable Future at the Bloomberg School of Public Health regarding California legislation about antibiotic use in animals used for human food. The letter from the Johns Hopkins staff can be read by clicking here.
Dear Colleagues from Johns Hopkins Center for a Livable Future:
I appreciate that you wrote expressing your concerns about the implementation of California Senate Bill 27 (SB 27) via letter dated October 13, 2017. The only way to ensure that a collaborative process continues as we move toward the goal of mitigating the rate of development of antimicrobial resistance in order to protect public, animal, and environmental health, is to communicate concerns.
Your first concern that we are not collecting Veterinary Feed Directive (VFD) data is easy to address because we are going to collect that data. We have the authority to collect this data, there are strong data retention laws in place that preserve the data, and our strategic plan calls for the collection of VFD data. We have visited ALL facilities in California that submitted a letter of intent to FDA to manufacture or distribute medicated feeds using VFD’s and have ensured that they are retaining the needed data.
Due to the time sensitivity, we are currently focusing activities on enhancing compliance with antimicrobial use laws that will be effective in 2018, including ensuring the VFD’s are filled out properly so the baseline data collected is meaningful, but as we bring newly funded staff on board, we will be well prepared to collect and analyze VFD data, including historical data, for use in our initial 2019 report to the legislature. However, we do not feel this information alone is sufficient for evaluating the effects of stewardship best practices which are also being developed as we gain staff, so we are initiating much more in depth data gathering studies as well.
To your second point about “regular pattern” use of antimicrobials for preventative purposes, we have a different understanding of the situation. We agree that SB 27 clearly limits regular pattern use for prevention, but the issue is not that someone wants a “loophole.” Remember that animal owners and veterinarians also want to preserve the potency of antibiotics, perhaps more than most people since not only do they and their families need effective antibiotics, but they want to be able to keep their animals healthy well into the future.
The issue is that trained and licensed veterinarians want the autonomy to use their skills when practicing medicine within the framework of California law, so finding the best wording was challenging. That being said, we agree that the wording on our website did not exactly reflect SB 27. It was not intentional and we have been working on how to improve it ever since these concerns were pointed out.
To reduce confusion, we have now removed the items of concern from our website. Because the law itself is fairly explicit, to avoid confusion as we approach 2018, we will likely just use the exact wording from SB 27 in the future.
Again, while we may come at this issue from different backgrounds, I truly believe we share common goals as we implement SB 27, so we encourage you to stay engaged and continue this productive dialogue. Your letters are helpful and welcomed because they formalize your concerns, but also feel free to contact me directly at (916) 900-5000 or via email at [email protected].
Thank you for your continued support of effective implementation of SB 27. Sincerely,
Annette Jones, D.V.M.
California State Veterinarian and Director
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]]>Editor’s note: A group of faculty and staff from the Johns Hopkins Center for a Livable Future at the Bloomberg School of Public Health sent the below letter to several California officials this past week. It is reprinted here with the permission of the authors.
To: Dr. Annette Jones, State Veterinarian and Director, Animal Health and Food Safety Services California Department of Food and Agriculture
cc: Governor Jerry Brown
California Department of Food and Agriculture Secretary Karen Ross
State Sen. Jerry Hill
Disclaimer: The opinions expressed herein are our own and do not necessarily reflect the views of The Johns Hopkins University.
Re: Implementation of California Senate Bill 27
Dear Dr. Jones,
We are researchers at the Johns Hopkins Center for a Livable Future (CLF), an interdisciplinary academic center based within the Bloomberg School of Public Health in the Department of Environmental Health and Engineering. CLF engages in research, policy analysis, and education activities guided by an ecologic perspective that considers diet, food production, the environment, and public health to be interwoven elements of a complex system.
We believe it is imperative that antimicrobials be used responsibly in food animal production to help slow the development of antimicrobial resistance, which has emerged as a major threat to both human and animal health. We, therefore, supported the passage of California’s Senate Bill 27 (SB 27) in 2015. In particular, we applauded the provisions on data collection and limitations on the use of antibiotics for disease prevention.
Despite the initial promise of the law, early signs have arisen regarding its implementation that create concerns with regard to the original legislative intent. Given these concerns about California Department of Food and Agriculture’s (CDFA) implementation of SB 27, we respectfully ask the Department to pursue the following:
1. Data collection: Collection of Veterinary Feed Directives (VFDs) for the year 2017 should occur in order to create a baseline profile of medically important antimicrobial drug (MIAD) use prior to the implementation of SB 27; and
2. Address a potential “regular pattern” loophole: Assuming our interpretation of the Department’s statement (presented on the CDFA website and specified in the following text) is correct, the regulatory approach should be modified to disallow veterinarian justification for use of MIADs in a regular pattern for disease prevention. If our interpretation is incorrect, clarity should be provided to specify that such a loophole does not exist.
The following text describes our requests in more detail and specificity.
Data collection
In order to evaluate the impact and effectiveness of the law, it is critical to understand and quantitatively characterize antibiotic use before it goes into effect in January 2018. We are concerned that although SB 27 directs the collection of this baseline data, the California Department of Food and Agriculture’s efforts have thus far focused solely on assisting the industry in completing Veterinary Feed Directives (VFD). These efforts must be accompanied by the collection of VFDs as outlined by SB 27 if the law’s success in reducing antibiotic use in livestock is to be identified and measured.
Address a potential “regular pattern” loophole
In addition, we are concerned about the Department’s interpretation of SB 27’s provisions related to the use of medically important antimicrobial drugs (MIAD) in a “regular pattern.” According to the law, MIADs may not be used in a regular pattern unless deemed necessary by a veterinarian to treat a disease or infection, control the spread of disease or infection, or in relation to surgery or a medical procedure. While the law states that MIADs may be used prophylactically to prevent disease when prescribed by a veterinarian, it does not include disease prevention as an allowable indication for use in a regular pattern.1 The Department, however, presents a loophole in this prohibition by allowing the use of MIADs in a regular pattern when prescribed by a veterinarian:
… A medically important antimicrobial drug (MIAD) can be used to prevent disease in livestock if under the professional and clinical judgment of a veterinarian there is an increased risk of developing an infection, as long as the MIAD is not given in a “regular pattern”. A few examples of “regular pattern” use may include giving MIADs solely based on the animals’ age or weight, the calendar date, or a life stage event of the animal without further justification for treatment by a licensed veterinarian within a valid veterinarian-client-patient relationship.
Based on the Department’s statement, their examples of regular use are permissible as long as a qualified veterinarian provides justification. This loophole would allow MIADs to be used in a regular pattern for disease prevention, and in situations unrelated to disease or infection, conditions which are prohibited under SB 27. In practice, such a broad loophole would mean a MIAD could be prescribed and used at virtually any time in the animal’s life. This is inconsistent with the intent of the legislation, and would weaken SB 27’s ability to reduce antibiotic use in livestock.
Thank you for considering our requests. We welcome the opportunity to discuss this further and answer any questions you may have. Please contact us at 410-502-7578 or by emailing Bob Martin, Director of the Food System Policy Program, at [email protected].
Sincerely,
James D. Yager, PhD, Professor in Department of Environmental Health & Engineering, Edyth H. Schoenrich Professor Emeritus, and Interim Director of Center for A Livable Future at Johns Hopkins Bloomberg School of Public Health
Keeve E. Nachman, PhD, MHS, Assistant Professor in Departments of Environmental Health & Engineering, and Health Policy and Management at Johns Hopkins Bloomberg School of Public Health and Program Director, Food Production and Public Health Johns Hopkins Center for a Livable Future Johns Hopkins University
Robert Martin, Program Director for Food System Policy at Johns Hopkins Center for a Livable Future at Johns Hopkins University, and Senior Lecturer in Environmental Health & Engineering at Johns Hopkins Bloomberg School of Public Health
Carolyn Hricko, MPH, Research Program Manager for Food System Policy at Johns Hopkins Center for a Livable Future and Department of Environmental Health & Engineering Johns Hopkins University
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Dear Editor,
This is in reference to your article, “Raymond to Perdue: Top food safety candidate is in your backyard” published Jan. 27.
I am the executive vice president of the National Association of Federal Veterinarians. NAFV has members who are Public Health Veterinarians working within the Food Safety and Inspection Service (FSIS) supervising slaughter operations. NAFV is an advocate for member veterinarians in federal service. NAFV emphasizes professionalism and expertise in federal service and promotes continuing education, teamwork, and a standard of excellence. NAFV is the recognized representative organization for veterinarians employed by the federal government.
NAFV supports the comments of former undersecretary of food safety, Richard Raymond regarding the importance of having an educated and knowledgeable food safety expert as the undersecretary of food safety. The person in this position helps set the direction for the entire agency’s food safety strategy. It is also important to have additional educated and knowledgeable food safety experts throughout the FSIS; especially those in charge of plant inspections, field operations and policy development.
We believe that Michael Doyle (recommended by Dr. Raymond) has an excellent background in food safety and his knowledge would be valuable. However, we also have an excellent candidate we are nominating, retired Brigadier General John Poppe DVM, MPH, DACPVM, who also has years of experience effectively leading a staff of food safety inspectors.
Gen. Poppe, was deputy chief of staff public health, U.S. Army Medical Command and Chief, Veterinary Corps. In that position, he has 28 years’ experience in food safety and public health programs leading a large work force for Army Public Health.
Among his responsibilities as chief of the Veterinary Corps, he provided leadership for its mission of animal health and food protection, including food safety and defense, across seven continents. He also has a robust, multi disciplinary educational background, giving him a comprehensive understanding of interconnections among animal production, animal health and human health.
Gen. Poppe has a practical perspective and his food safety, public health experiences positions him well to lead innovative programs that ensure complete and seamless attention to food safety and security from production to retail. He is highly regarded by his veterinary peers, as well as other senior and subordinate military and civilian personnel. He is a recipient of numerous prestigious awards, including the Distinguished Service Medal and the American Veterinary Medical Association’s (AVMA) Public Service Award.
The NAFV is confident that Gen. Poppe will successfully carry out the duties of the under secretary for food safety.
Note on the letter writer: Michael J. Gilsdorf is a veterinarian and executive vice president of the National Association of Federal Veterinarians, based in Washington D.C. NAFV emphasizes professionalism and expertise in federal service and promotes continuing education, teamwork, and a standard of excellence.
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