Food Safety:

USDA's Role Under the National Residue Program Should Be Reevaluated

RCED-94-158: Published: Sep 26, 1994. Publicly Released: Sep 29, 1994.

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Pursuant to a congressional request, GAO reviewed the Department of Agriculture's (USDA) National Residue Program (NRP), focusing on whether: (1) the program can ensure that the nation's meat and poultry supply is free of potentially hazardous chemical residues; and (2) assistance from the Environmental Protection Agency (EPA) and the Food and Drug Administration (FDA) is adequate to support NRP needs.

GAO found that: (1) NRP testing is not comprehensive and the methodology used to select food samples is flawed; (2) the Food Safety and Inspection Service (FSIS) does not know the extent to which potentially harmful residues may exist in the meat and poultry supply; (3) NRP generates questionable results concerning potentially hazardous residues in meat and poultry; (4) FSIS does not always have complete information on chemical residues or the potential hazard such residues may present to consumers; (5) although FDA is principally responsible for investigating residue violations referred by FSIS, resource constraints and legislative restrictions limit its ability to take enforcement action against violators; (6) a risk-based approach to residue prevention, detection, and control may better ensure the safety of meat and poultry than the present approach, which relies on testing end products; (7) FSIS recognizes the value of changing its testing approach and has begun to design new testing systems; (8) FSIS resources could be more effectively used if FSIS delegates responsibility for establishing and operating quality assurance systems to the industry; and (9) FSIS could selectively monitor the effectiveness of industry programs and assist industry by developing information on compounds in use and test methods.

Matters for Congressional Consideration

  1. Status: Closed - Not Implemented

    Comments: Although the 104th Congress did not address this issue, USDA has indicated its intention to move to a HACCP-based system for residues. USDA adopted a HACCP system for microbial contamination and appears to be moving in this direction for residues. Therefore, congressional action is no longer applicable.

    Matter: To improve the prevention, detection, and control of chemical residues in the domestic meat and poultry supply and more efficiently use scarce regulatory resources, Congress may wish to consider requiring FSIS to establish scientific, risk-based Hazard Analysis and Critical Control Point systems with the industry for residue prevention, detection, and control.

  2. Status: Closed - Not Implemented

    Comments: FSIS intends to require industry to establish HACCP systems for residue detection, prevention, and control. As such, congressional action is no longer needed.

    Matter: To improve the prevention, detection, and control of chemical residues in the domestic meat and poultry supply and more efficiently use scarce regulatory resources, Congress may wish to consider having FSIS shift the primary responsibility for day-to-day residue prevention, detection, and control to the industry.

  3. Status: Closed - Not Implemented

    Comments: FSIS has moved in this direction. As such, congressional action is no longer needed.

    Matter: To improve the prevention, detection, and control of chemical residues in the domestic meat and poultry supply and more efficiently use scarce regulatory resources, Congress may wish to consider requiring FSIS to adopt a regulatory oversight role designed to ensure the effectiveness of the industry's efforts.

  4. Status: Closed - Not Implemented

    Comments: The 104th Congress has not held hearings on the need for additional authority for FSIS to access the industry's control program records. However, FSIS intends to have industry establish HACCP programs and says it will verify their effectiveness. FSIS will need to have records access in order to perform such verification. FSIS has not approached Congress for additional authority to access records.

    Matter: Congress may wish to consider whether additional authority should be provided to facilitate FSIS access to the industry's residue prevention, detection, and control program records and to enhance FSIS enforcement powers against violators.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: Although FSIS concurs with the recommendation, it has not committed itself to providing adequate resources to complete the CES list ranking in a timely manner. FSIS also states that completion of this task may be delayed by the need to develop new test methods.

    Recommendation: To strengthen NRP, the Secretary of Agriculture should direct the Administrator, FSIS, to provide the resources necessary to complete the ranking of the updated listing of NRP compounds within a reasonable time frame and ensure that high-priority needs are addressed first when plans for testing and test development are formulated for NRP.

    Agency Affected: Department of Agriculture

  2. Status: Closed - Implemented

    Comments: USDA issued a draft document entitled Residue Control in a HACCP Environment in 2000. Under HACCP (Hazard Analysis and Critical Control Point) meat and poultry establishments are required to identify and control physical, microbial, and chemical hazards that are reasonably likely to occur. USDA initiated discussions on this issue at the October-November meeting of the National Advisory Committee on Meat and Poultry Inspection. USDA believes the issue needs further consideration and should be part of the agencies HACCP II effort. USDA has no target completion date.

    Recommendation: To strengthen NRP, the Secretary of Agriculture should direct the Administrator, FSIS, to modify port-of-entry residue testing for imported meat and poultry to include residues that the domestic testing of the exporting nation has shown to have high violation rates, such as heavy metals, as well as the banned and unapproved compounds that the exporting nation identifies as being used domestically, or require that the exporting nation have programs to test specifically for such residues prior to shipment.

    Agency Affected: Department of Agriculture

  3. Status: Closed - Not Implemented

    Comments: FSIS acknowledges some of the limitations in its methodology, as GAO pointed out, but says that it must balance any bias that results against workload and scheduling limitations. Also, it does not agree that it is necessary to sample all species and compounds at the same rate for the program to yield statistically valid results.

    Recommendation: To strengthen NRP, the Secretary of Agriculture should direct the Administrator, FSIS, to strengthen the NRP methodology by ensuring that statistically valid random sampling procedures are adhered to when meat and poultry samples are selected for residue testing, the effects of climatic/geographic and seasonal factors on slaughter rates and compound use are considered for the species sampled, adequate sample sizes are used for all of the species and compounds tested, and the sampling rates used for each species/compound pair are taken into account when analyzing the results.

    Agency Affected: Department of Agriculture

  4. Status: Closed - Implemented

    Comments: FSIS agreed with this recommendation and has made major changes in its Domestic Residue Data Book for NRP to prevent misinterpretations of the data presented.

    Recommendation: The Secretary of Agriculture should ensure that NRP data are not reported as representative of the meat and poultry supply in general, or as indicative of a downward trend in the occurrence of potentially harmful chemical residues in meat and poultry.

    Agency Affected: Department of Agriculture

  5. Status: Closed - Implemented

    Comments: FDA concurred and intends to work with USDA on a case-by-case basis to determine if there is a need to establish regulatory levels for heavy metal residues, and will establish such levels.

    Recommendation: If regulatory limits for heavy metal residues are found to be needed, the Secretary of Health and Human Services should ensure that the Commissioner, FDA, establishes such limits.

    Agency Affected: Department of Health and Human Services

  6. Status: Closed - Implemented

    Comments: FSIS has reviewed the Compound Evaluation System's compound listing and eliminated 95 compounds that are no longer of scientific concern.

    Recommendation: To strengthen NRP, the Secretary of Agriculture should direct the Administrator, FSIS, to update the listing of compounds considered for NRP testing to ensure that resources are not expended on inconsequential compounds.

    Agency Affected: Department of Agriculture

 

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