Game Meat: A Complex Food Safety and Animal Health Issue
By Patrice N. Klein, MS, VMD, DACPV, DACVPM
When people talk about eating meat, the images that typically come to mind are beef, turkey, chicken, pork or lamb. These meats and products that contain them are widely available throughout the country and are favorites of many families. However, there is a category of meats from non-domesticated animals—game meats—that also can be found in markets and restaurants throughout the United States. Although they represent only a small portion of the U.S. market their popularity is growing. This article identifies many common game meat species and discusses some of the food safety and regulatory issues associated with game meats, including the legality of importing certain species of meats from other countries.
The Nature of the Beast
Game meats are from non-domesticated, free-ranging and farm-raised wild animals and birds that either are legally hunted for personal consumption or reared, slaughtered, and commercially sold for food. Common North American game species include bear, bison, antelope, caribou, deer, elk, moose, reindeer, wild boar, snake, alligator, rabbit, squirrel, beaver, and birds (pheasant, grouse, quail, wild turkey, wild geese and ducks). Venison is a specific term commonly used today to describe game meat from deer but historically the word, derived from the Latin “venatio” (to hunt), was used to define meat eaten from many hunted game animals or “beasts of chase” and included elk, other cervids, and wild boar. Although individuals have hunted and eaten these species for years for personal consumption, animals killed in the wild that are processed to enter the U.S. commercial food supply must comply with applicable state and federal food safety regulations. Having such regulations helps protect the public because the health history of a hunted animal is unknown.
The Growth of the Industry
The farmed game animal industry is diverse and has seen unprecedented growth since the 1970s. Its rapid growth in recent years is largely due to consumer demand for low-fat products and interest in alternative food products. In 2003, the North American Elk Breeders Association’s estimated that there were about 110,000 elk on 2,300 U.S. farms valued at more than $150 million, representing an increase of 20,000 farmed elk since 1997. The National Deer Farmer’s Association reported an increase in farmed deer from 44,000 in 1992 to 126,000 in 1996 with an estimated value of $80 million. In 2003, there were approximately 550,000 deer on 11,000 U.S. farms with an estimated value of $1 billion. The American bison industry is reported to be growing by 30% a year with more than 250,000 farmed bison in 1997 compared to 30,000 bison in 1972. The National Bison Association reported that there were more than 1,100 American bison farms by 1999. The commercial rabbit industry estimates that 1.5–2.0 million rabbits are marketed for meat annually, retailing for $3.00–$6.00 per pound. Total rabbit meat exported from the U.S. in 2001 was valued at $160,000, while rabbit meat imported to the U.S. was valued at $1.5 million, reflecting an increase in consumer demand.
The growth of these game meat industries highlights the importance of having regulations addressing disease control, interstate movement of animals, animal identification, slaughter inspection, and food processing practices which are similar to the regulations for traditional livestock production. However, the industry may be regulated either by the state agriculture department, the state wildlife agency, the state public health department, or by shared responsibilities between the state agencies, causing a lack of consistent regulations among states. For example, most states regard bison as livestock and subject them to the same disease control regulations as cattle but only some states require bovine tuberculosis (TB) testing of farmed cervids. Also state agriculture departments generally have regulations or policies for importation into the state of game animals and their products but may not continue to regulate these products once they are in intra-state commerce. However, the federal agencies have regulations for inter-state commerce designed to ensure the health and welfare of these animals, as well as the safety of the food products derived from them.
There are four federal agencies that protect human and animal health, food safety, and wildlife conservation through their respective regulatory authorities of domestic and imported game meat. They are the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS), the U.S. Fish and Wildlife Service (USFWS), the Centers for Disease Control and Prevention (CDC), and the U.S. Food and Drug Administration (FDA). APHIS has jurisdiction under the Animal Health Protection Act and animal quarantine laws, such as those listed in Title 9 in the Code of Federal Regulations (9 CFR 94), to inspect, detain, quarantine, seize and destroy animals, meat, and meat products in interstate commerce or those being imported into the U.S. that pose a risk of introducing a pest or foreign animal disease such as foot and mouth disease (FMD) or avian influenza to U.S. domestic livestock and poultry.
USFWS has regulatory authority under the Endangered Species Act (ESA), the Lacey Act and the Wild Bird Conservation Act to prohibit the importation of wild animals and any wildlife products that may be injurious to native wildlife (by introduction of foreign disease, for example), that violate federal, state, or local wildlife laws, and that threaten species conservation. Additionally, within the U.S., they enforce the Convention on International Trade of Endangered Species (CITES), an international treaty based on sustainable use and management of wildlife to prevent the decline of wild animal populations.
CDC has authority under the Public Health Service Act (PHSA) to prohibit the importation of animals and animal products and to regulate foreign quarantine to prevent introduction of communicable diseases that threaten public health. Currently, CDC bans the importation of all non-human primates (NHP), African rodents, civets, and Asian birds and products from these animals to protect the public against ebola, simian immunodeficiency virus (SIV), monkeypox, severe acute respiratory syndrome (SARS), and avian influenza.
FDA is responsible for protecting consumers against impure, unsafe, and fraudulently labeled food covered under the Federal Food, Drug, and Cosmetic Act (FD&C Act). This includes products not covered by the USDA’s Poultry Products Inspection Act (PPIA) and Federal Meat Inspection Act (FMIA). Meat from game animals and birds are not covered by those acts and are regulated by FDA under the FD&C Act. Game meat produced domestically, as well as shipped from other countries, must meet the same safety standards applied to all foods domestically produced and offered for entry into U.S. interstate commerce. Additionally, if offered for sale as a consumer commodity, they must also meet the requirements of the Fair Packaging and Labeling Act (FPLA). Domestic and international food shipments found not to comply with the provisions of the FD&C Act must be brought into compliance, destroyed, or if from other countries, may be re-exported. FDA also has authority under the PHSA to prohibit interstate commerce of animals and animal products to prevent transmission of communicable diseases affecting human health.
An example of FDA’s enforcement efforts is a surveillance alert issued for imported rabbit meat in 1988, (later updated in 1993), that warned about the possibility of frozen rabbit meat contaminated with Salmonella entering the U.S. Imported shipments tested and found to be Salmonella-contaminated were detained for either destruction or re-exportation, and the importers placed on detention until the product met import requirements. Decomposition, pesticide residue, and contamination by filth including microbial contamination are product adulterations that are continuously monitored by the FDA in all of its regulated products.
Smuggled Bush Meat Trade: An Emerging Problem
“Bush meat” is a term for game meat from wild animals that are hunted and slaughtered for personal consumption traditionally in the bush of Africa and elsewhere in the world. Although this term was originally associated with the great apes and monkeys it also includes hippopotami, water buffalo, elephants, giraffe, zebra, wild hoofstock, caracals, jackels, reptiles, birds, and rodents. Many of these animals are threatened or endangered species protected by international wildlife laws and treaties such as CITES, and may make any commercial harvest and trade as food illegal and a violation of the treaty. Consumption of meat from these animals also may pose a public health risk because the health of these hunted animals is unknown and many species may harbor diseases that could infect people.
Unfortunately, the amount of illegal, smuggled bush meat entering commerce has increased markedly in recent years coincident with the increased demand for farmed game meats. The burgeoning smuggled bush meat trade may reflect the increase in intercontinental immigration of diverse cultures wishing to have continued access to traditional foods from their home countries and/or the local consumer’s growing interest in experiencing novel exotic foods. Historically, the consumption of bush meat was primarily confined to the poorer, rural communities in Africa, Asia, the Middle East, and South America that hunted local wildlife for personal consumption as an inexpensive source of protein in their diets. Now, however, consumption is substantially increasing in Europe and the U.S. Much of this meat, which is being sold in street markets and ethnic restaurants, is illegally smuggled into countries such as the U.S. Sometimes it is hidden in passenger’s suitcases and sometimes in commercial cargo shipments that are intentionally mislabeled. This practice is disconcerting as there are potentially serious health consequences associated with the consumption of these products. According to the USFWS, USDA Plant Protection and Quarantine and the Department of Homeland Security-Customs Border Patrol, the amount of bush meat entering the U.S. each year is unknown, however, these agencies estimate that they may be intercepting only a fraction of what is being illegally imported. Similarly, the Department of Food and Rural Affairs (DEFRA) in the United Kingdom (U.K.) estimates that nearly 12,000 tons of smuggled bush meat enters the U.K. annually. DEFRA believes that some of this meat may be contaminated with FMD virus which would pose disease risks to U.K. livestock. According to reports from the Zoological Society of London and the Bush Meat Crisis Task Force, as much as five million tons of bush meat is extracted from the vast Congo basin and Central African Republic each year putting many wild animal populations at risk of extinction.
Public Health Concerns
While most game meats are produced from healthy animals, some game meats have raised public health concerns because the meat may harbor infectious agents that are not destroyed by smoking, salting, or brining preparations, and could cause human disease.
Additionally, there are some public health concerns about chronic wasting disease (CWD), a transmissible spongiform encephalopathy (TSE), or prion disease, which has been identified in both wild and farm-raised mule deer, white-tailed deer, and Rocky Mountain elk. While consumption of beef contaminated with bovine spongiform encephalopathy (BSE) is thought to be responsible for the variant form of Creutzfelt-Jakob disease (vCJD) in people, consumption of CWD contaminated cervid meats is not known to cause disease in people or domestic livestock. Nonetheless, research is ongoing to determine if interspecies transmission of the CWD agent to humans and domestic livestock is possible. As with other TSEs (BSE, scrapie) in domestic farm animals, these prion agents are thought primarily to be transmitted within species either naturally or through questionable farm feeding practices.
Smuggled bush meat likely presents the greatest public health risk. Among the diseases that may be transmitted to humans from bush meat are those caused by viral agents of ebola, HIV/SIV, monkeypox, herpes B, Rift Valley fever, and rabies; bacterial agents of tuberculosis (Mycobacterium bovis, M. tuberculosis), anthrax, salmonellosis, shigellosis, brucellosis; and parasitic agents of trichinellosis, and toxoplas-mosis.
Making Sure Product is Safe
Given the legal requirements and various public health issues, the question arises: What can commercial farmers, processors, importers, and retailers of game meats do to ensure that their products are safe and for sale in the U.S. market place? The first thing they should do is familiarize themselves with the pertinent regulations from the four agencies listed earlier in this article. As with any other food intended for human consumption in the U.S., game animals should be raised in accordance with good husbandry practices and then processed and packed in accordance with good manufacturing practices. This includes proper feeding, appropriate living conditions and adequate veterinary attention so as to ensure that the animal is healthy when slaughtered and not harboring a disease that could be spread to humans or other animals. Meats which are packaged also must adhere to the relevant labeling requirements. Processors, manufacturers using processed game meats, importers and suppliers all should ask questions of their suppliers so they can be assured that the products they are receiving come from reputable sources operating within the provisions of the law.
FDA’s mission is to ensure the safety of the products it regulates, whether they are traditional foods like milk, grain products, and eggs, or the more esoteric game meats and game meat products. FDA takes very seriously the risks to public health of illegally imported foods like bush meat harvested from wild animal populations that may harbor dangerous zoonotic diseases. Similarly, FDA and CDC are looking carefully at the potential public health risks that may be associated with CWD-contaminated meat and have recommended refraining from consuming meat and other products from CWD-positive deer and elk until more information is available to understand how CWD is transmitted within the same species of deer or elk and if it could be transmitted to people.
The FDA will be working to identify manufacturers and processors involved in the importation and interstate commerce of game meats and game meat products in an effort to establish inspection plans to evaluate on-farm and slaughter facility sanitation practices. FDA will continue to work with other federal agencies to develop better guidelines and procedures to facilitate interagency cooperation to prevent illegal bush meat from entering the U.S.
Patrice N. Klein, MS, VMD, DACPV, DACVPM, is a Senior Staff Regulatory Veterinarian in the Office of Plant and Dairy Foods’ Division of Dairy and Egg Safety within the Center for Food Safety and Applied Nutrition. She has more than 20 years of experience in the field of wildlife veterinary medicine and disease and has worked for FDA for three years. She is responsible for providing scientific expertise in regulatory policy development for foodborne and zoonotic diseases.
Categories: Food Types: Meat/Poultry; Regulatory: FDA