HPP High Pressure Pasteurization

  • Mandating (or lack thereof) HPP.  USDA’s FSIS (Food Safety & Inspection Service) Directive 6120.1 on HPP inspection verification responsibilities has caused false rumors that HPP will become mandated. This documents wording implies that HPP requirement when, in fact, the document is simply stating the rules of a HACCP plan IF HPP were used by a company, not because it is mandatory. (26)  Since 2009 FDA has worked with the FSIS and FIC (Food Industry Counsel) to enforce HACCP plans (Hazard Analysis Critical Control Point) on food companies (canned food excluded) because the FDA does not have the authority to enforce specific pathogen stop-gap measures.  The 2016 USDA’s FSIS HACCP enforcement program is designed to ensure food safety and quality control by requiring raw food companies, for human and pet consumption, to maintain a detailed tracking log of manufacturing and testing procedures. It does enforce specific stop gap methods such as HPP, irradiation or cooking. Legally, according to the FSIS authority HACCP, itself, is considered a “stop gap method,” as are irradiation, HPP, cooking and “other methods” that are “not yet researched” (like fermentation) if their efficacy can be proven. (25) K&L Gates Docket No FDA-2010-D-0378; Draft Compliance Policy Guide Sec. 690.800, Salmonella in Animal Feed (75 Fed. Reg. 45,130 (August 2, 2010) Zero Tolerance Pathogens

E.coli is highly responsive to HPP, however since 2007 there has only been ONE recall of pet food for e.coli (dry food), making it a moot point for pet food regulation. (17) Campylobacter – There is minimal reference to HPP’s ability to regulate Campylobacter. However, NO cases of campylobacter have ever been associated with pet food recall. (18) Listeria monocytogenes has been observed to have a higher survival rate in cooked and HPP meat than in raw meats. (Simpson and Gilmour 1997) (1) NO Listeria outbreaks have ever been caused by pet products. (15) Salmonella – In September of 2015 Dr. William James, a 28 year Chief Veterinarian of FSIS in charge of pathogen and residue sampling published a document showing his disappointment in FSIS’s ability to decrease Salmonella in food products since 2000 despite changes in policy.  He states that FSIS will not change their regulatory strategy for Salmonella, despite its failures. (13) Since 2006 there have been 60 outbreaks caused by Salmonella, TWO of which were caused by COOKED, DRY PET FOOD (none from raw). (16) https://herospets.com/the-science-behind-high-pressure-pasteurization-hpp/

Recommending against commercially available raw (rather than co-op and grocery) decreases FDA credibility because FDA is tasked with monitoring safety of these products yet they publicly state that they are unsafe to use

L. monocytes is submissive to other bacteria.  Hpp does not kill it but the presence of other bacteria prevent its proliferationhttps://www.fda.gov/food/guidanceregulation/guidancedocumentsregulatoryinformation/salmonella/ucm295271.htm In this document, we use the phrase “adequately reduce” to mean reducing the presence of Salmonella spp. to an extent sufficient to prevent illness. The extent of reduction

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