Richardo Molins, Ph.D.—
HACCP Redefined!

Richardo Molins, Ph.D., is a Senior Program Officer for the Food and Nutrition Board of the National Academy of Sciences (NAS) in Washington, D.C. Having received his doctorate in Food Science from Iowa State University, Dr. Molins has worked in the area of food safety for more than 30 years. He is presently in charge of a high-profile, HACCP-related study commissioned by the U.S. Congress entitled “A Review of the Use of Scientific Criteria and Performance Standards for Safe Foods.”

FoodTechSource: How did the study get started? Was it something the NAS came up with the idea for?

Richardo Molins, Ph.D.: This originated in language that was appended to the Agriculture Appropriations Bill of 2000/01. The U.S. Senate instructed the USDA to commission a study by the US Academy of Sciences to look at the scientific basis of criteria used in food processing and production performance standards. But when we sat down to discuss this with the USDA, we told them we wanted to widen the scope of the study to include sectors of the food industry whose produce-related commodities are under the FDA’s jurisdiction—such as seafood and dairy. We thought it would be more in keeping with the style of the Academy to look at the whole issue and not restrict it to meat and poultry. So, we brought on the FDA as a sponsor.

FTS: How will the study be structured?

Molins: There will be be two subcommittees and one main committee, which will be an oversight committee responsible for the framework of the study. This main committee is composed of, among others, five members of the meat and poultry subcommittee and four members of the seafood, dairy products and produce-related subcommittee.

FTS: How will the study be carried out?

Molins: We are going to be looking at a series of questions posed to us by the USDA and FDA. According to the statement of task, our committee “will define the relationship between public health objectives and the Hazard Analysis and Critical Control Point (HACCP)-based approach to food safety. It will define the terms “performance standards” and “criteria,” as related to food products and processing, it will recommend guidelines for determining the type of data that should be used in developing food safety criteria, including microbiological performance standards, and oversee the development of two reports on the use of scientific-based criteria in relationship to performance standards in HACCP.”

“The definition of a critical control point is any step in the production of food where you can exercise control to reduce a hazard to an acceptable level, but nobody ever said what is acceptable. ”

FTS: Can you put that into practical terms?

Molins: The idea is to relate HACCP and performance standards to public health objectives in a more direct clear way.

FTS: You mean as to whether HACCP works?

Molins: No. It absolutely works. We have no doubt about that. But there is one issue HACCP does not address. The definition of a critical control point is any step or process in the production of food where you can exercise control to prevent, eliminate or reduce a hazard to an acceptable level....but nobody ever said what is acceptable. Acceptable to whom? On what basis? And I think that is a very important point to be looked at with this project. That is where the health objective comes in play. How do you relate HACCP to what you want to attain or achieve in your process control.

FTS: Isn’t the objective zero tolerance? Non-contamination?

Molins: Well, the ultimate objective of food safety is to prevent or reduce the number of foodborne diseases. So, the two subcommittees will be looking directly at performance standards criteria used for each commodity group. How were these generated? Where did the data come from? How was it applied? Are there better ways of doing things? Or are we in fact doing things right?

FTS: I’m not sure that I understand.

Molins: Zero tolerance is a performance standard. But the levels vary for each commodity group. In some cases you say zero, in other cases you say well you have to reduce 5 logs. It depends on the particular performance standard.

FTS: So, you will be evaluating those performance standards?

Molins: We would like the committee to concentrate on the most relevant performance standards. Because there are quite a few performance standards that can apply to more than one commodity group. We’re going to look at the Salmonella performance standards, for example, and look at its objective, and is the objective being attained. How was it set up? What data was used? How was the data gathered? We want to look at the circumstances for each one of the main types of performance standards.

“We’re going to look at the objectives of each performance standard—is the objective being attained? How was it set up? What data was used?”

FTS: Why not cover every single performance standard?

Molins: If you look all the different guidelines for standard operating procedures, each has a host of regulations that you could classify as performance standards. So there could be hundreds of little regulations on a lot of things—from sanitation to lighting of working areas—that somebody could say are performance standards. To examine each would pose a monumental task. So, we have asked the USDA and the FDA to clarify, to tell us where they would like us to concentrate our efforts so that the study will respond to the concerns of Congress.

FTS: Which hopefully are the concerns of public health.

Molins: Right.

FTS: How was each committee member selected?

Molins: We looked at what kind of expertise we needed at the committee and sub-committee level, and we accepted nominations from a variety of organizations, trade associations and consumer groups, and from the USDA and FDA. We used our network of contacts in the food science arena, and academia. During the selection process we weighed a variety of factors—in particular industry experience, because we wanted people from academia who knew the operations of food processing plants.

FTS: Is it a balanced panel?

Molins: At our first meeting last week we decided the group we had selected lacked some balance in the area of public health and on the regulatory process, so we are probably going to invite several individuals from those areas to join us. Then I think we are going to be in very good shape because we have some strong expertise in academia.

FTS: Why did Congress request this study?

Molins: This is just my opinion, but it followed closely with the problems that had occurred between the USDA and Supreme Beef. The issue got a lot of press coverage and people probably felt something had to be done.

FTS: Will you be looking at issues like the use of irradiation or high-pressure sterilization? Are you getting that specific?

Molins: I don’t believe so. Because you are talking now about management options: how best to decontaminate an item. That’s not really the mandate of the committee.

FTS: What do you hope the study will accomplish?

Molins: We hope the committee will be able to present to the USDA and the FDA with a very comprehensive and clear evaluation of where we are in terms of the criteria applied to food processing, including microbiological performance standards, and give recommendations.

“We hope to present a comprehensive evaluation of where we are in terms of the criteria applied to food processing, including microbiological performance standards”

FTS: When do you expect the study to be finished?

Molins: The report will need to be completed by the end of November 2002. It’s an awful lot of work. Between now and August we meet four times. Then by the end of August the study needs to be put together so we have enough time to submit the findings to a rigorous external review by the National Research Council.

FTS: Can it be done?

Molins: I am very optimistic. We have a very good group of people. And based on our first meeting we have a very enthusiastic group of people. So it looks good.