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R-CALF Says Small Plants Need a Break

The Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America, known as R-CALF USA, wants the U.S. Department of Agriculture’s Hazard Analysis and Critical Control Point abandoned or revamped with an alternative meat inspection protocol.

The Billings, MT-based beef producer organization formally requested the action in a letter to USDA Secretary Tom Vilsack this week.  R-CALF USA says recently mandated increased microbial testing is not focused on large slaughter plants, but rather small downstream processors.

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”…We are pleased the FSIS is admitting that substantial amounts of hazardous meat currently is shipped into commerce, in spite of the fact that the largest slaughter plants have now operated under HACCP for 12 years,” the letter states. “We are dismayed, however, that the agency’s increased validation demands are being focused primarily against the processing plants further downstream, the vast majority of which totally depend on meat purchased from upstream, source-slaughter providers.


“…FSIS-style HACCP has resulted in ongoing outbreaks and recurring recalls, which the agency uses as justification for increased microbial testing because HACCP plants ship such a high volume of hazardous raw meat and poultry into commerce bearing the official USDA Mark of Inspection,” the letter also states. 


Central to R-CALF USA’s food safety beliefs is that corrective actions must be implemented at the source-slaughtering plant (origin) of contaminated meat, rather than at destination plants, which essentially are powerless over the sanitation conditions at their source-slaughter providers.

R-CALF says it is greatly concerned the agency’s increased focus will not only create budgetary concerns that will remove the majority of small plants from federal and state inspection, but also will simultaneously insulate the true source of contaminated meat from adequate agency oversight, virtually guaranteeing ongoing shipment of hazardous meat into commerce. 



”The fact that FSIS strongly recommends the testing of incoming product constitutes an agency admission that the large source-slaughter plants continue to ship large amounts of contaminated/adulterated meat into commerce, (and) R-CALF USA believes the solution to this problem is to detect such meat at the slaughter plant of origin and require corrective actions at the source, not at the destination,” the letter states.


Current FSIS guidance will necessitate that plants essentially validate, via testing, not only HACCP plans, and all Pre-Requisite plans, but also a multitude of specialty products, which are the unique niche products that attract consumers to products emanating from small facilities.  In stark contrast, large slaughter plants primarily produce carcasses, trimmings, and boxed beef, necessitating only three areas to validate, at most. Small plants, which have substantially less sales revenue and that are dependent on the manufacture and distribution of specialty items, will be burdened with enormous increases in microbial testing expenditures, which their revenues cannot sustain.

The American Association of Meat Processors estimates the initial cost for the increased testing of ready-to-eat products by smaller plants at $12,000 per product line, and $3,600 per product line in future years.


R-CALF USA is concerned that small, inspected plants, which are vital to livestock producers across America, will quickly disappear, eliminating essential services needed by small, local producers. At the same time President Obama and the U.S. Department of Agriculture (USDA) are advocating the “Know your Farmer, Know your Food” program, this agency mandate to increase microbial sampling will further separate consumers from producers because it will result in a lack of processing facilities required to process locally grown livestock. This policy will effectively undercut the stated goals of USDA and will result in an increased dependence on imported meat.

 

“R-CALF USA is concerned that while the agency’s mandate for increased microbial testing is focused as close to the consumer as possible (at the downstream plants), such testing is also focused as far away as possible from the source-slaughter plants, which are the origins of enteric bacteria,” said R-CALF USA HACCP Committee Chair John Munsell.

“By FSIS admission, the largest plants constitute only 7 percent of all federally inspected plants, but produce 90 percent of our meat. We suggest that 90 percent or more of agency mandated microbial testing must be focused at the source, not the destination of meat products.”

 

R-CALF USA would be more willing to endorse this agency mandate for increased microbial testing if such testing would result in safer food. However, since the true origin of contamination with enteric pathogens continues to remain off the agency’s enforcement radar, increased testing costs would produce no benefits for public health, while effectively eviscerating America of its small plants. 



”Lastly, R-CALF USA is greatly concerned that FSIS firmly believes our current HACCP system is so ineffective that the agency perceives that greatly increased microbial testing must be implemented for validation purposes, and agency demands for increased testing are symptomatic of an underlying danger, namely the ineffectiveness of FSIS-style HACCP,” the letter states. “R-CALF USA respectfully recommends a thorough overhaul of the agency’s current HACCP methodology.”

© Food Safety News
  • Doc Mudd

    R-CALF has been on the smart side of a few issues in the past…this is not one of those times.
    .
    This time R-CALF is all hat and no head. Confusing HAACP (a preventive approach) with microbial testing (a monitoring tool – “testing”, get it?). Obviously, microbial testing is most efficiently “focused as close to the consumer as possible” to monitor for instances of “down stream” contamination – to detect a failed HAACP anywhere up the chain. Positive microbial findings will be traced back to their source, thus the emphasis upon traceability (does R-CALF oppose that too??).
    .
    Either the drug store cowboys and hobby ranchers have seized control of R-CALF, or you good ol’ boys have stayed out in the cold too long and frostbit sumpin’ you oughtn’t of.

  • jmunsell

    Doc:
    I wrote the R-Calf letter, so you can challenge me directly.
    I ran a meat plant for 34 years, all under USDA inspection.
    For your information, R-Calf was an early endorser of the concept of Traceback to the Source. Why? (1) USDA adroitly avoids tracebacks to the origin, but intentionally sends all liability downstream to the further processing plants. (2) USDA intentionally insulates the large source slaughter plants from accountability. (3) Ongoing outbreaks and recurring recalls are virtually guaranteed, because FSIS does NOT require the source of enteric pathogens (E.coli & Salmonella) to implement corrective actions. Indeed, only the destination facilities are required to implement corrective actions, but NOT the slaughterhouse of origin of enteric bacteria. (4) These ugly outbreaks and recalls diminish consumer confidence in beef, and demand, adversely impacting livestock prices. Yes, prices are increasing now, not because of demand, but because our herd inventory is the lowest it’s been in 60 years.
    You are right: Pillsbury-style HACCP truly utilized a preventative approach. Pillsbury authored a Cadillac of a HACCP system. USDA-Style HACCP is a far cry from Pillsbury-style HACCP. USDA rolled out a jalopy, and stamped it with the HACCP label, while it is nothing but a HACCP Hoax.
    Doc, where do you live? I’d love to give you a PowerPoint presentation which provides a detailed historical account of the two types of HACCP. I gave it this morning to a group of Montana meat processors, who had their eyes opened for the first time, as will happen to you. I’m not criticizing you as being uninformed. Instead, you are probably like the vast majority of owners of inspected meat plants who do not know the lurid history of how USDA successfully concocted their HACCP ruse. We are living a lie.
    You are precisely correct that Pillsbury-style HACCP did NOT rely on microbial testing! Why? Because products made under a Pillsbury-style HACCP protocol have been exposed to a kill step, and are consistently wholesome. In stark contrast, USDA-style HACCP has been mandated on ALL plants, the vast majority of which create raw meat & poultry, which do NOT have a kill step. As a result, we’ve experienced this ugly plethora of ongoing outbreaks and recalls. Since the USDA HACCP Hoax has resulted in these outbreaks and recalls, the only way we can stanch these adverse events it to greatly increase testing to determine the SOURCE of contamination, and then require corrective actions at the SOURCE. USDA disagrees, and wants to mandate that downstream DESTINATION facilities greatly increase their expensive microbial testing, of MEAT PURCHASED FROM SOURCE SLAUGHTER PROVIDERS. If you read the agency’s justification for increased testing at downline destination further processing plants, you will notice that the agency makes several references to, and I quote: “…..a food safety hazard occurring in the raw materials that the establishment typically receives”. “……to reduce the level of pathogens associated with the raw materials received at the establishment”. The agency justification also refers to the need for downstream further processing plants to not only test finished products, but also initial testing of incoming products. USDA is fully cognizant that the SOURCE slaughter plants continue to ship pathogen-laden meat into commerce. The agency’s solution for this sordid scenario is for the downstream plants to (a) detect invisible pathogens in incoming meat, and (b) remove the pathogens. Interesting, because neither the source slaughter plant or USDA were able to either detect or remove the pathogens at the origin.
    Seriously Doc, let’s get together, and discuss this in detail. Call me at 406-234-1877, or 406-853-1878 Cell, and let’s attempt to meet in person for a few hours. I’ve given this HACCP PowerPoint to numerous groups now, all of whom are dumbfounded, none of whom have been able to rebut my statements. Frankly, USDA-style HACCP is not based in science as disengenuously claimed. Well, I would agree it does have a basis in political science, or in science fiction.
    Bottom Line: the truth shall set you free, including you free from the lies used by USDA on which they built its HACCP House of Cards, which is crumbling.
    Lastly, you referred to “down stream” contamination. For the first 31 years I owned my plant, I had no idea what “enteric” bacteria are. By definition, enteric bacteria emanate from within animals’ intestines, and by extension are found on manure-covered hides. E.coli & Salmonella are enteric bacteria. Enteric bacteria enter the food chain via sloppy (and inadvertant) kill floor dressing procedures. The vast majority of inspected meat plants do NOT slaughter, but purchase all their meat from source slaughter providers. Local meat markets (Safeway, Costco, WalMart, etc) as well as restaurants have no intestines or manure-covered hides on their premises, and purchase all their meat from source supplier slaughter establishments. If meat contaminated with enteric bacteria is detected on their [downstream] premises, they did not introduce the bacteria, but have been victimized by unwittingly purchasing meat which was previously contaminated with invisible bacteria. Why perform microbial testing at the destination, which USDA’s new mandate for Validation testing mandates? Why let the horses out of the barn, and then place all focus on attempting to find the horses out in commerce at the destination facilities? Testing at the slaughterhouse of origin would quickly reveal where the contamination is occurring, thereby enabling the implementation of corrective actions to prevent recurrences at the appropriate SOURCE location. The very fact that testing is necessary publicly reveals that USDA-style HACCP is NOT working! The fact that this scenario exists a full 12 years after the largest kill plants implemented HACCP, and although HACCP should now be fully mature, reveals that USDA-style HACCP should either be disbanded, or greatly revised.
    The revision that USDA prefers is to place even greater liability against the DESTINATION plants, further insulating the source plants. This not only delays the inevitable changes necessary at the source slaughter plants, but virtually guarantees additional outbreaks and recalls. I don’t think this is what you or I desire.
    Let’s talk!
    John Munsell

  • John Munsell

    Doc:
    I wrote the R-Calf letter, so you can challenge me directly.
    I ran a meat plant for 34 years, all under USDA inspection.
    For your information, R-Calf was an early endorser of the concept of Traceback to the Source. Why? (1) USDA adroitly avoids tracebacks to the origin, but intentionally sends all liability downstream to the further processing plants. (2) USDA intentionally insulates the large source slaughter plants from accountability. (3) Ongoing outbreaks and recurring recalls are virtually guaranteed, because FSIS does NOT require the source of enteric pathogens (E.coli & Salmonella) to implement corrective actions. Indeed, only the destination facilities are required to implement corrective actions, but NOT the slaughterhouse of origin of enteric bacteria. (4) These ugly outbreaks and recalls diminish consumer confidence in beef, and demand, adversely impacting livestock prices. Yes, prices are increasing now, not because of demand, but because our herd inventory is the lowest it’s been in 60 years.
    You are right: Pillsbury-style HACCP truly utilized a preventative approach. Pillsbury authored a Cadillac of a HACCP system. USDA-Style HACCP is a far cry from Pillsbury-style HACCP. USDA rolled out a jalopy, and stamped it with the HACCP label, while it is nothing but a HACCP Hoax.
    Doc, where do you live? I’d love to give you a PowerPoint presentation which provides a detailed historical account of the two types of HACCP. I gave it this morning to a group of Montana meat processors, who had their eyes opened for the first time, as will happen to you. I’m not criticizing you as being uninformed. Instead, you are probably like the vast majority of owners of inspected meat plants who do not know the lurid history of how USDA successfully concocted their HACCP ruse. We are living a lie.
    You are precisely correct that Pillsbury-style HACCP did NOT rely on microbial testing! Why? Because products made under a Pillsbury-style HACCP protocol have been exposed to a kill step, and are consistently wholesome. In stark contrast, USDA-style HACCP has been mandated on ALL plants, the vast majority of which create raw meat & poultry, which do NOT have a kill step. As a result, we’ve experienced this ugly plethora of ongoing outbreaks and recalls. Since the USDA HACCP Hoax has resulted in these outbreaks and recalls, the only way we can stanch these adverse events it to greatly increase testing to determine the SOURCE of contamination, and then require corrective actions at the SOURCE. USDA disagrees, and wants to mandate that downstream DESTINATION facilities greatly increase their expensive microbial testing, of MEAT PURCHASED FROM SOURCE SLAUGHTER PROVIDERS. If you read the agency’s justification for increased testing at downline destination further processing plants, you will notice that the agency makes several references to, and I quote: “…..a food safety hazard occurring in the raw materials that the establishment typically receives”. “……to reduce the level of pathogens associated with the raw materials received at the establishment”. The agency justification also refers to the need for downstream further processing plants to not only test finished products, but also initial testing of incoming products. USDA is fully cognizant that the SOURCE slaughter plants continue to ship pathogen-laden meat into commerce. The agency’s solution for this sordid scenario is for the downstream plants to (a) detect invisible pathogens in incoming meat, and (b) remove the pathogens. Interesting, because neither the source slaughter plant or USDA were able to either detect or remove the pathogens at the origin.
    Seriously Doc, let’s get together, and discuss this in detail. Call me at 406-234-1877, or 406-853-1878 Cell, and let’s attempt to meet in person for a few hours. I’ve given this HACCP PowerPoint to numerous groups now, all of whom are dumbfounded, none of whom have been able to rebut my statements. Frankly, USDA-style HACCP is not based in science as disengenuously claimed. Well, I would agree it does have a basis in political science, or in science fiction.
    Bottom Line: the truth shall set you free, including you free from the lies used by USDA on which they built its HACCP House of Cards, which is crumbling.
    Lastly, you referred to “down stream” contamination. For the first 31 years I owned my plant, I had no idea what “enteric” bacteria are. By definition, enteric bacteria emanate from within animals’ intestines, and by extension are found on manure-covered hides. E.coli & Salmonella are enteric bacteria. Enteric bacteria enter the food chain via sloppy (and inadvertant) kill floor dressing procedures. The vast majority of inspected meat plants do NOT slaughter, but purchase all their meat from source slaughter providers. Local meat markets (Safeway, Costco, WalMart, etc) as well as restaurants have no intestines or manure-covered hides on their premises, and purchase all their meat from source supplier slaughter establishments. If meat contaminated with enteric bacteria is detected on their [downstream] premises, they did not introduce the bacteria, but have been victimized by unwittingly purchasing meat which was previously contaminated with invisible bacteria. Why perform microbial testing at the destination, which USDA’s new mandate for Validation testing mandates? Why let the horses out of the barn, and then place all focus on attempting to find the horses out in commerce at the destination facilities? Testing at the slaughterhouse of origin would quickly reveal where the contamination is occurring, thereby enabling the implementation of corrective actions to prevent recurrences at the appropriate SOURCE location. The very fact that testing is necessary publicly reveals that USDA-style HACCP is NOT working! The fact that this scenario exists a full 12 years after the largest kill plants implemented HACCP, and although HACCP should now be fully mature, reveals that USDA-style HACCP should either be disbanded, or greatly revised.
    The revision that USDA prefers is to place even greater liability against the DESTINATION plants, further insulating the source plants. This not only delays the inevitable changes necessary at the source slaughter plants, but virtually guarantees additional outbreaks and recalls. I don’t think this is what you or I desire.
    Let’s talk!
    John Munsell

  • Doc Mudd

    One does not have to be a rancher or a meat cutter of 34 years to recognize the rich aroma of bullshit, John. Merely piling it high and deep, over and over and over does nothing to inform the discussion – a discussion on behalf of some 300 million Americans who, since we all eat, each has a vested interest in the documented safety of the food we purchase and consume. Even you seem to acknowledge that food safety assurance, surveillance and accountability are flawed and need to be brought up to modern standards.
    .
    Well, maybe not the accountability part, eh John? Contrary to your glib assertion that “R-Calf was an early endorser of the concept of Traceback to the Source”, in fact R-CALF celebrates as one of its finest achievements the complete shouting down of a modern, technologically competent system of traceability in the proposed National Animal Identification System (NAIS). R-CALF’s stance is that effective traceback using modern techniques like NAIS is undesirable; they prefer to merely maintain and consider ‘good enough’ an antiquated livestock disease control strategy for one solitary disease, bovine brucellosis (a pathogen, by the way, that plays practically no role in food safety as it pertains to beef).
    .
    Hmmm, do I detect a familiar aroma wafting in on the breeze? R-CALF’s arguments against NAIS and traceability are two-fold: 1) The system might be expensive and bothersome to institute, so R-CALF members are unwilling to make the effort to protect America’s livestock industry and their own paying customers in the bargain and 2) The system might prove to be truly effective at diagnosing and tracing a public health problem back to its source…it would make producers of all types and sizes personally accountable for cleaning up or paying up. That, in R-CALF’s opinion would amount to an invasion of privacy, a loss of personal freedom…well, uh, freedom among producers and merchandizers of livestock products to handle, any damned way they please, the food that will be sold to paying customers; paying customers for whom R-CALF visibly affords not one iota of concern. R-CALF’s ‘discussion’ is intended not to inform or protect the consuming public but rather, by permeating the atmosphere with endless objections and redundant platitudes, to wear down the advancement of public health to the trivial pecuniary advantage of R-CALF members.
    .
    And that successful R-CALF strategy is now extended to obfuscating the discussion of dedicated food safety measures, specifically HAACP and microbial testing. The air hangs a bit heavier still as R-CALF objects to sensible and responsible food safety protocols for the industry…if R-CALF producers must participate as part of the solution, that is.
    .
    Oddly, John, you accurately acknowledge that HAACP is only as good as the resources and effort one invests in the practice…and it can be very good! You cite Pillsbury as a success story (I haven’t heard that Pillsbury was bankrupted or even had their bottom line damaged by their success with HAACP). So, you point out that HAACP is effective when properly managed but then proceed to a blanket condemnation of HAACP as unworkable and ineffective. Perhaps what you meant to convey is that the people developing and implementing HAACP can circumvent its intent by themselves being uncooperative and ineffective? Isn’t it a ‘people thing’ rather than a fatally flawed concept? And, if that’s the case, might R-CALF not identify some means of becoming part of the solution instead of insisting that we change nothing, do nothing?
    .
    I will address a couple of your specific concerns. As for your angst over upstream fecal contamination and HAACP writing at a downstream establishment with no “kill step”, apart from assuring that employees can and do wash their hands thoroughly after relieving themselves, what more is there to write about…or to worry about in authoring and executing a successful HAACP? I would advise you not lose any sleep over it.
    .
    Your anxiety over testing for “invisible pathogens” and your reluctance to do it seem out of synch with the fundamental idea of food safety. Invisibility in no way lessens the pathogenicity of microbial organisms and, indeed, invisibility is a dispersal strategy that pathogens have been perfecting for tens of thousands of years. The only practical method so far is microbial testing to detect the little buggers. Sure, it’s slow and costs some money but it’s pretty effective when done conscienciously.
    .
    When performed at the end of the process chain, closest to the consumer, testing actually can prevent the sick “horses” (per your analogy) escaping from the barn…and onto my plate and yours. What’s more, if we have effective traceability we will quickly know with precision just whose sick horses we now have quarantined out there in the barn, won’t we? That means that the consumer will be protected and the miscreants tracked down and summarily dealt with. If the contamination/adulteration occurred upstream from your establishment, then you have no worries except some inconvenience to safeguard your paying customers and preserve your market. I should think your customers would be grateful to you for your vigilence on their behalf.
    .
    I would therefore advise that you write the finest possible HAACP for your own downstream facility and implement it with the enthusiastic cooperation of your entire staff (a la Pillsbury). Let the upstream establishments worry about writing and implementing their own HAACP. Your overwrought bashing of USDA and anonymous “source slaughter plants” will not improve their penmanship even one little bit. Stick to your own knitting, let them fumble with theirs. With effective testing at the end of the chain and traceability all along the chain, a slob or scofflaw at any level in the chain will soon enough be brought to account, and will either clean up, pay up or give up. And gradually our food safety becomes manageable and relatively assured.
    .
    Finally, I must remark about your obvious generalized disdain for USDA and commercial slaughter facilities. From an earlier article, we all realize that you have an axe or two to grind, stemming from some regulatory fracus that you were involved in with USDA. This is America and you are, of course, welcome to your opinion but your unfounded insinuation that USDA is perpetrating hoaxes and conspiring with anonymous private entities to systematically destroy us, well…that exudes a strong stench of the aforementioned bovine byproduct. It undercuts your credibility to the extent that I am not particularly interested in sitting through your slide show, well rehearsed and entertaining as it may be. Not to be disrespectful, John, but I can easily imagine that many of your guests have, indeed, gone away “dumfounded”, as you describe it. I’ve already experienced that sensation – “Food, Inc.” got to me ahead of you. I am now on heightened alert for tin foil hat conspiracy theorists.