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Why USDA is Extending Public Comment on Its Proposal to Modernize Poultry Slaughter

ABC’s Jim Avila, the man who so adroitly ended the expected shelf life of lean, finely textured beef when failed TV chef Jamie Oliver and an award-winning but factually flawed ‘expose’ by the New York Times didn’t make much of a dent, took a swing at the USDA’s proposal to modernize poultry slaughter on a Wednesday evening news report last week.  The next day at 6:55 p.m., Dr. Elizabeth Hagen, USDA Under Secretary for Food Safety, announced a slight adjustment of the modernization time table.

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“Today, USDA announced an extension to the public comment period for a proposed rule that would modernize the poultry slaughter inspection system,” she wrote. “This new plan would provide us with the opportunity to protect consumers from unsafe food more effectively. We recognize that this proposal would represent a significant change from the current system and has sparked a debate on how poultry is inspected. We also value the different opinions being expressed about the proposal and have extended the public comment period to ensure all sides are presented in this debate.”

The Government Accountability Project (GAP) was one of the first organizations to express serious doubts about the HACCP Inspection Models Program (HIMP) which had been flying comfortably under most watchdog radar, probably overshadowed by the never-ending “pink slime” controversy.  GAP grabbed three USDA inspector whistleblower inspectors and their affidavits expressed these concerns:

– At non-HIMP plants, line speeds for bird inspection are set at 72-90 birds per minute (bpm) with multiple federal inspectors monitoring the line, so that each inspector is in charge of overseeing approximately 30-36 bpm. At HIMP plants, however, this line speed increases to 165-200+ bpm with only one federal inspector monitoring the production line for infected/tainted product. This means that one federal inspector is going to be responsible for safeguarding over 10,000 birds per hour. These rates are so fast, that inspectors simply cannot look at every bird.

– Under HIMP plans, federal inspectors are replaced with plant workers who are powerless to speak out against their employers, and are responsible for removing adulterated product. The inspector whistleblowers have witnessed that these sorters are “rebuked by supervisors” when they try to slow down the line for food safety concerns.

– Under traditional inspection methods, inspectors can see all sides (and the inside) of the bird. But inspectors at HIMP plants can only see the backside of the bird – not the front (where the breast meat is) that may clearly show tumors or scabs. Nor can HIMP inspectors see the inside of the bird, where fecal matter and other disease causing abnormalities are found.

– In each Inspector’s case, the placement of the “Critical Control Point (CCP)” – the main purpose of which is to identify and catch potential food safety problems – under the HIMP plan was moved to a point further down the conveyor line, after a key “Inspection Station.” This has the effect of taking away the inspectors’ ability to see noncompliances or issue Noncompliance Reports (NRs), documentation showing a plant CCP’s failure to prevent important regulatory violations. Multiple NRs can lead to increased enforcement action against the plant.

GAP said each of the three inspectors clearly conveyed in their affidavit that a nationwide implementation of the HIMP plan makes it more likely that unsafe products will reach consumers.

Let me insert a point/counterpoint here. The days of ‘poke-and-sniff’ inspection are thankfully long gone and those on-line inspectors are the last vestige of that practice. You can’t see or smell Campylobacter or Salmonella.  Visual inspection for pathogen detection is a pointless pursuit.

On the other hand, it’s easy for an inspector to spot quality control problems like fecal contamination, bruising and feathers.  But not at 160+ birds per minute, especially when half the bird is not in line-of-sight?  Blink and you’ve missed half a dozen birds.

Dr. Hagen wants federal inspectors “to focus on food safety tasks, such as ensuring sanitation standards are being met and verifying testing and antimicrobial process controls.” She suggests a major shift in their responsibilities.  Let plant employees look for feathers and other visual contamination; the feds should spend their time making sure poultry processing facilities are taking the appropriate steps to control food safety hazards.

  

Her very valid point: FSIS inspectors would no longer be partly responsible for quality assurance which is a “protect the brand’ effort that properly belongs to the poultry processors; they would become more responsible for food safety, the real reason they’re in the plant, anyway.

The USDA is now trying to make a change suggested by the HIMP pilot program started in 1999. Twenty carefully selected broiler plants served as “trial plants” for this long term test. Results showed lower rates of Salmonella and USDA officials concluded that quality assurance tasks, such as checking for bruises and blemishes, don’t provide adequate food safety protection.

It’s a program that earned the enthusiastic backing of USDA Food Safety and Inspection Service Administrator Al Almanza, who wrote about it on April 13 in the Huffington Post.

He wrote, “If we’re going to have a debate on the merits of this proposal, I welcome it. But we need to use the same facts in this important discussion. It is not an honest debate when some people are saying that line speeds are going from 35 birds per minute (bpm) to 175. That is simply not the case. Right now, under our current regulations, line speeds are capped at 140 bpm. Additionally, the 20 broiler plants under a pilot program started in 1999, known as the HACCP Inspection Models Program (HIMP), are allowed to go up to 175 bpm. In other words, we have more than a decade of experience slaughter running at 175 bpm, the proposed maximum line speed in the rule. And the data is clear that in these plants, the poultry produced has lower rates of Salmonella, a pathogen that sickens more than 1 million people in the U.S. every year. These plants also maintain superior performance on removing the visual and quality defects that don’t make people sick. Those are the facts, based on the data.”

The proposal has earned the unqualified backing of the National Chicken Council and the National Turkey Federation as it should.  It takes the handcuffs off production and saves the poultry industry millions annually.  With those changes, however, come some serious public relations concerns.

The folks who are against the idea will suggest that faster line speeds will create more food safety problems and will be the first to scream “I told you so” when the first recall happens.  It won’t matter that line speed might not be the cause.  

And a recall will happen.  Shortly after the massive 1997 Hudson Beef recall, I attended a National Meat Association conference where Michael Mina, one of Almanza’s predecessors at FSIS said, “There are two kinds of businesses in the meat industry; those that have had a recall and those that will have a recall.”

And I would add to Mina’s wisdom some perfectly tim
ed comments made last week by Food Safety Summit Keynote speaker Oscar Garrison, Division Director, Consumer Protection, Georgia Dept. of Agriculture and President of the Association of Food & Drug Officials (AFDO).  He divided food plants into three groups –

A. Top performers, they know how to do things right and have considerable resources to make sure their products are as safe as possible.  Federal or state inspection rarely finds a problem and probably can’t contribute anything to their efforts.

B. Good performers, they want to do things right but don’t have the access to the skills and technology of an “A” company.  Federal and states agencies can help them with advice on best practices.  Problems are still rare but are more likely to occur.

C. The bad actors (less than 2%, according to Garrison), doing the right thing is not a top priority.  Given a choice, they’ll often make the wrong one.  Close monitoring is a requirement.

Those 20 plants chosen 13 years ago for the USDA pilot program?  Were they all ‘A’ plants or a more statistically correct grouping of A”s, B’s and C’s?  Were they forewarned and forearmed about inspections so that they might ramp up their food safety procedures to insure a good report card?  And about those FSIS inspectors who have been tagged as ‘whistle-blowers?’ Sure, they’re guilty of trying to protect jobs – the new proposal would eliminate 75% of them, saving the government millions in tax dollars – but let’s not let that completely taint their opinion.  They’ve been the front line guys on this food safety battle from the beginning and their concerns must be given a fair hearing.

It’s a good thing that the decision to move forward with the HIMP plan has been delayed while the feds collect more comments. The fallout created by the inevitable recall if the plan is perceived as being pushed through without due diligence would be devastating to the poultry industry.  It would make the recent ‘pink slime’ issue seem like a warm up bout prior to the main event.

PS: Someone remarked that this HIMP-inspired self-inspection was like letting the fox guard the henhouse.  Never was there a more appropriate simile.  Not saying that poultry plants would intentionally game the system, but at the first hint of a problem, public opinion would quickly go there, gleefully spurred on by certain special interest groups.

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Chuck Jolley is president of Jolley & Associates, a marketing and public relations firm that concentrates on the food industry. 

© Food Safety News
  • Chuck, I’ve said it before, but it merits repeating. FSIS has done an uncomplete job explaining how decreased inspection will improve food safety. As you state above, Dr. Elisabeth Hagen says that “feds should spend their time making sure poultry processing facilities are taking the appropriate steps to control food safety hazards”. Dr. Hagen also stated “”They [FSIS inspectors] would become more responsible for food safety, the real reason they’re in the plant anyway”. As you mention above, Dr. Hagen also stated “This new plant would provide us the opportunity to protect consumers from unsafe food more effectively”. I know & admire Dr. Hagen & Al Almanza, and respect them both, so I want to believe the agency’s claims on advanced HIMP.
    What is missing thus far is a concise FSIS explanation of exactly HOW consumer food safety will benefit from advanced HIMP, coupled with a dramatic decrease in inspectors’ numbers. Will the agency implement a substantial increase in agency-conducted microbial samples of carcasses in the cooler? In other words, exactly HOW does FSIS intend to prove that poultry plants are improving the safety of poultry products? Does the agency actually intend to remove inspectors off the line, and primarily have them merely audit company-generated paperflow? I would ascribe zero credibility to such a tactic.
    Chuck, my perception is that FSIS has to date NOT fully elucidated exactly how advanced HIMP will improve food safety in poultry products. I admit that FSIS just might have an erudite protocol under wraps; the wrappings must come off. And until they do, this proposal must be placed on the rear burner.
    No one can deny that increased chain speeds CAN increase the incidence of contaminated meat. However, a professionally-managed plant can very well devise new cutting-edge antimicrobial interventions to actually improve food safety, while simultaneously increasing speeds. To do so however, plants must PROVE (i.e. “validate”) their claims to food safety success. Likewise, FSIS must explain in advance how it will validate the claim that decreased inspection will improve food safety in poultry plants.
    An additional 30 days will provide FSIS officials more than adequate time to provide such details.
    John Munsell

  • Chuck, I’ve said it before, but it merits repeating. FSIS has done an uncomplete job explaining how decreased inspection will improve food safety. As you state above, Dr. Elisabeth Hagen says that “feds should spend their time making sure poultry processing facilities are taking the appropriate steps to control food safety hazards”. Dr. Hagen also stated “”They [FSIS inspectors] would become more responsible for food safety, the real reason they’re in the plant anyway”. As you mention above, Dr. Hagen also stated “This new plant would provide us the opportunity to protect consumers from unsafe food more effectively”. I know & admire Dr. Hagen & Al Almanza, and respect them both, so I want to believe the agency’s claims on advanced HIMP.
    What is missing thus far is a concise FSIS explanation of exactly HOW consumer food safety will benefit from advanced HIMP, coupled with a dramatic decrease in inspectors’ numbers. Will the agency implement a substantial increase in agency-conducted microbial samples of carcasses in the cooler? In other words, exactly HOW does FSIS intend to prove that poultry plants are improving the safety of poultry products? Does the agency actually intend to remove inspectors off the line, and primarily have them merely audit company-generated paperflow? I would ascribe zero credibility to such a tactic.
    Chuck, my perception is that FSIS has to date NOT fully elucidated exactly how advanced HIMP will improve food safety in poultry products. I admit that FSIS just might have an erudite protocol under wraps; the wrappings must come off. And until they do, this proposal must be placed on the rear burner.
    No one can deny that increased chain speeds CAN increase the incidence of contaminated meat. However, a professionally-managed plant can very well devise new cutting-edge antimicrobial interventions to actually improve food safety, while simultaneously increasing speeds. To do so however, plants must PROVE (i.e. “validate”) their claims to food safety success. Likewise, FSIS must explain in advance how it will validate the claim that decreased inspection will improve food safety in poultry plants.
    An additional 30 days will provide FSIS officials more than adequate time to provide such details.
    John Munsell

  • husna aijaz

    The microbial load of pathogenic bacteria like Salmonella can increase after slaughter and further during the defeathering process. In Grad School, I worked on a proposal on Kosher and Halal meats and found salting the meat (upon slaughter) an effective remedy to reduce the bacterial load as done on Kosher meats. Additionally, feed withdrawal is not an effective remediation measure (a couple of hours before slaughter)as increases the chances of pathogenic bacteria.
    If FSIS have to hire inspectors to evaluate the birds at a higher speed (175 bpm), then the adoption of the above methods may drastically reduce the microbial load and in turn contribute to increased Food Safety standards. I would strongly recommend hiring inspectors with a Food Science background and provide them with further training in meat inspections.

  • Emily

    It is true that there needs to be some sort of change in the system but both of the above posts reveal that this is not the right change. The workers would have less time to inspect birds for fecal matter and other dangerous material – and the people looking for the hazards would primarily be company employees, not government inspectors. These are not trained specialists, but regular workers whose jobs are in a vulnerable position and who might not necessarily recognize problems with the chickens. In addition, the intense speeds make it less likely that the trained inspectors will be able to accurately check the chickens. While the businesses themselves might have the resources to check for microbial problems, it is an instance of “letting the fox guard the henhouse.”
    It is also important that the increased speeds will be more hazardous to workers. The production employees work in refrigerated environments and currently have one of the highest injury and illness rates in the country due to their use of dangerous cutting equipment, the cold conditions, and the repetitive nature of their jobs. Their injuries would likely increase as production line speeds increase.