Rep. DeLauro is worried about worker safety because of increased line speeds??? The inspectors won't even have to touch the birds now. If anything, this will be safer because they won't have to repetitively touch the birds. The hardest thing now will be staying awake! Of course the industry (Tyson, Pilgrims)) is praising this new system. They're getting what they wanted all along and can run faster. Production is all they care about anyways.

I don't have a problem with it. I think it will be more efficient. A lot of the regs are/were obsolete. I just feel bad for the inspectors that will have to relocate.

These changes "may" be beneficial to food safety, a claim which will only be proven by future microbial analyses. FSIS should provide us a detailed explanation of exactly what responsibilities their inspectors will now have, that is, to precisely delineate what duties these off-line inspectors will have. Why do I say this?

If the off-line inspectors focus primarily on reviewing company-generated paperwork, much of which has no connection to food safety, this is a feint. Such subterfuge currently occurs at meat plants, a horrendous waste of taxpayer dollars. FSIS needs to clearly define the company records which will now receive increased scrutiny. Furthermore, will agency microbial sampling of chicken carcasses and ground chicken increase in frequency? This needs to be clearly identified.

A common complaint against the agency's version of HACCP is that the agency firmly believes that if an establishment fills tneir files to overflowing with a plethora of daily paperwork, that the abundance of paperwork will automatically produce safer food. Let me give you but one example.

FSIS requires that downstream, further processing plants obtain from their source slaughter providers annual "Letters of Certification" and "Guarantees". Letters of certification describe the variety of protocol existing in the suppliers' HACCP Plan, SSOP's, GMP's, 3rd party validations, intervention steps, CCP's, sampling criteria (N-60, Test & Hold, diversion of Presumptive Positive product, definition of lots), etc etc etc. These certifications also include statements that no meat plant is able to guarantee pathogen-free raw materials. These certifications are typically available on the source plants' websites, available to the public. Interestingly, if a supplier's HACCP and related systems are deficient, FSIS should have already detected that & demanded changes. Small, downstream plants which detect potential deficiencies in their suppliers' plans have absolutely no authority to demand changes at the source plants, and keep their mouths shut rather than risk being delisted as a future customer.

Letters of guarantee merely state that the slaughter plants' products are not adulterated within the meaning of the Federal Food, Drug and Cosmetic Act. Please note that the guarantees do NOT mention shipment of meat which is adulterated as per FSIS requirements, which means zero tolerance. Huge distinction.

Therefore, letters of certification and guarantees are NOT guarantees of product wholesomeness or safety. But, FSIS requires that all downstream plants have updated certifications and guarantees, inferring that the presence of such paperwork essentially prevents the further processing plant from ever purchasing unsafe meat, and the absence of such paperwork in files greatly increases the chances of the downstream plant purchasing previously-contaminated meat.

This is but one more example of the underlying beguiling foundational premises of FSIS-style HACCP, which is that paperwork (& agency review of it) will automatically produce safer meat & poultry. Now, if the inspectors' increased off-line work consists of reviewing meaningful data, such as results of company-conducted microbial sampling, and increased agency microbial sampling, then yes indeed, this new agency proposal could improve food safety.

We must realize that if FSIS continues to place more emphasis on a paper chase (as is currently the case), rather than a pathogen chase, this new agency proposal is but smoke & mirrors.

FSIS tenaciously argues that if meat plants would only place more paragraphs into their HACCP Plans, create more daily forms (typically divorced from food safety), and have more bells and whistles in their SSOP's, GMP's, etc, that safer food will automatically result, because more paperwork is being generated.

Let's see precisely what FSIS envisions its inspectors to do under this new system which primarily focuses on inspectors working off-line.

John Munsell

"Under current policy, FSIS is now reponsible for examining all poultry carcasses for blemishes or visual damage before the birds are futher processed?"

I work in a poulty processing facility and I know that FSIS examines each bird, hands-on, for mutilation, contamination, and pathology.

One major disease is IP (imflammatory process)-a little understood disease that usually occurs under the skin but often becomes systemic. It is very hard to detect without hands-on inspection. It usually manifests itself as a yellow exudate under the skin and in the soft tissues of the bird. It contains a mixture of harmful bacteria, often Strep,Staph, E. Coli and others.

Another major disease is airsacculitis. It is a respiratory disease that often becomes systemic. It manifest itself as a snot-looking viscous exudate that often covers the viscera and inside of the bird. It is almost impossible to detect without an examination of the viscera and a hands-on examination of the inside body cavity of the carcass.

The current inspection system requires FSIS inspectors to examine each viscera and each bird. The inspectors examine 35 birds per minute. If the contamination/mutilation/pathology is to such a degree that the birds cannot be examined and disposed of properly, the IIC (Inspector in Charge) has the authority to slow the line down to allow proper examination and disposition of the defective birds.

With the new inspection system, an inspector merely looks at the birds as they pass by at 180 birds/minute. There is no hands-on examination for mutilation, contamination, and pathology.

Aw come on Mike, you are a throw back to the old organoleptic inspection which depended on the senses (sight, touch, smell) which FSIS has dismissed as an archaic, "poke & sniff" system. USDA's new "science based" meat inspection system is science based, not longer requiring organoleptic inspection for mutilation, contamination and pathology. In the mid-90's, USDA promised our industry that its role under HACCP would be "Hands Off", and that the agency would no longer police the industry, but we could police themselves. Being "Hands Off" means just that: keep their blasted hands off our poultry carcasses! And FSIS doesn't want to police us anymore, which means we should be able to do all this "Hands On" organoleptic stuff ourselves.

At 180 birds per minute, the inspector could merely look at 3 birds per second to comply with the requirement they inspect every bird. As the agency says, "Let HACCP Work!"

Lastly, who cares if pathogen-laced poultry get into commerce? After all, the entity primarily responsible for food safety is the consumer, whose future sickness will be fully caused by his/her improper cooking protocol. Yup, let HACCP work!

John Munsell

Well Mr. Munsell, the more I see out of you the more I like you. Hope you and your equals will stay after it.

Truth Hurts Don't It.
Be carefull you don't take their Bonuses for pleases the industry and forgeting the consumers.

It really is interesting to see how far the USDA has come from its inception. I can't even imagine what would happen if we didn't have the regulatory agencies that we do now.