FSIS Docket Clerk
Room 3806, South Agriculture Building
Food Safety and Inspection Service
U.S. Department of Agriculture
Washington, DC 20250
RE: Transportation and Storage Requirements for Potentially Hazardous Foods; Advance Notice of Proposed Rulemaking
The American Society for Microbiology (ASM) appreciates the opportunity to provide comments to the Food Safety and Inspection Service (FSIS) of the U.S. Department of Agriculture and to the Food and Drug Administration (FDA) on approaches the two agencies should employ to foster food safety improvements during the transportation and storage of potentially hazardous foods. The ASM is the largest life science society in the world with an active membership of over 42,000. ASM members include academic, industrial, clinical and governmental scientists, many of whom are involved in detecting, diagnosing and preventing foodborne disease.
Temperature Performance Standards
It is essential that potentially hazardous foods be properly cooled during transportation, storage and distribution in order to achieve food safety. Proper control should be maintained during transportation and storage from the food processing plant to the retail outlet or food service establishments. A temperature of 41 F or below is an ideal goal for a temperature performance standard. However, some flexibility should be provided to allow for reasonable deviations to occur. Temperature performance standards should be established to allow foods to be exposed to temperatures up to 45 F (or possibly 47 F depending on the food) for maximum specified periods of time based on published growth rates of Listeria monocytogenes and applicable to specific commodities.
Recording thermometers or other means of documenting time-temperature exposures are essential to verifying that potentially hazardous foods have been held within the established temperature performance standards. It is reasonable to expect large commercial purchasers of such foods to incorporate the temperature performance standards into their purchase specifications and to enforce them as part of their routine product acceptance procedures.
Regarding shipper recordkeeping, it is reasonable to establish recordkeeping requirements for conditions under which potentially hazardous foods are transported interstate to reduce the potential of cross contamination of food cargoes. It is also reasonable to require carriers of potentially hazardous foods that are shipped in bulk to provide food shippers with records that identify the last three cargoes for any conveyance being offered to the shipper for transporting food.
As an alternative to mandatory temperature performance standards, Hazard Analysis Critical Control Point (HACCP) systems that include appropriate temperature control points, which properly monitored and recorded, could be used for firms involved in the transportation and storage of potentially hazardous foods. If this option were pursued, the personnel involved in the implementation and the monitoring of the HACCP system would have to be knowledgeable about product vulnerabilities and be trained in HACCP principles.