Dear Chair Mizuno and Health Committee Members,
My firm Healthy Earth LLC-Tasty Safety is a Hawaii based food safety consulting service. I graduated from the Culinary Institute of America (Hyde Park, NY) and completed my Food Safety Science (including HACCP & Micro) at Texas A&M University (College Station, Texas). I also have 27-years of decorated service with the U.S. Department of Agriculture Food Safety and Inspection Service (USDA-FSIS). My positions ranged from Slaughter Inspector to Supervisory Consumer Safety Officer and Frontline Supervisor as well as a Regional Import Field Supervisor (RIFS) for the Office Of International Affairs. My experience includes inspections of a wide range of facilities and products as a red meat slaughter inspector, poultry slaughter inspector, Halal slaughter inspector, processing products inspector, and import inspector.
Background
The negative aspects of Hawaii’s milk that is re-pasteurized is far reaching. As a USDA-FSIS Retired Consumer Safety Officer (SCSO), we are focused on the following five groups of people called YODIM’s that must be protected.
- Young
- Old
- Diseased
- Immune deficient
- Malnourished
Federal protocol mandates that all the groups above are treated equally. The theory is, if you protect those five groups or classes, then every person either side of those groups are protected as well. Simple concept with far reaching affects.
The University of Hawaii study on this re-processing of milk supports this Bill. The scientists have spoken and the case made with regards to the elevated bacterial levels in re-pasteurization of milk. This would apply to all YODIM’s that consume this milk.
Over a decade ago, Hawaii Legislative Issued Resolution HCR 72 to research these issues and safe handling of imported products into Hawaii. Unfortunately, there was no action moving this issue forward at the legislative level.
Supportable Position and Other Information:
- One important overarching point to be made is that “product must be protected at all times”. Yet while the pasteurized milk ordinance (PMO) sets rules in place, these are the minimum requirements. Hawaii deserves nothing but the safest milk. There are many factors in producing safe milk. HB 1663 clearly supports milk safety.
- The next important overarching point is that “once a process is in control, it should remain in control”. Therefore, if a critical control point (CCP) and critical limit (CL) are for product temperature, once it meets the CCP/CL it should remain in compliance. Not shelf stable (SS) milk product, time, temperature and sanitation (including removing bio-films) are what food safety focuses on with regards to Micro-Hazards. Going up and down or in and out of compliance for food can be dangerous. It’s the Yoyo affect. I do not have the data set to form a conclusion if milk is currently arriving above 41 degrees. HB 1663 clearly supports milk safety be eliminating unnecessary risks pertaining to the transportation of Hawaii’s food imports.
- The Hawaii DOH does have a regulation that is enforced here for <41 degrees F. for holding not SS product. There should be no exceptions for “not shelf stable product”. Can Peter Oshiro’s DOH Crew enforce this regulation the moment the product is in Hawaii, because of the Hawaii DOH food handling permit? DOH enforces this even in federal USDA-FSIS plants because a Hawaii DOH food handling permit is issued in addition to the the federal grant of inspection. I am not in possession of any cold chain management (CCM) records. HB 1663 clearly supports milk safety.
- Pasteurization only decreases the microbial load. The question becomes what microbial load was present to begin with and what Log reduction will the milk end up with? Generally speaking, based on my research, two-degrees F. a day is the approximate temperature loss for an unrefrigerated 6000-gal bulk milk tank. Therefore, a five-day journey to Hawaii would yield an approximate net loss of 10 Degrees F. and a 10-day journey would yield an approximate net loss of 20 Degrees F. for milk temperature.
Conclusion
The safe handling of milk and food outlined in HB 1663 is completely supported by my firm. This is certainly a step towards improving milk safety and protecting the public in all of the Hawaiian Islands.