In my last editorial, I outlined the origin and pitfalls of FSIS’ proposal to extend the decade-old HACCP Inspection Models Project (HIMP) pilot program into plants nationwide.
The debate on HIMP has a variety of perspectives. The discussion may twist and turn, but for those who work in the business, it’s always about line speed. Even with massive poultry recalls, foodborne illness outbreaks, and compromises in worker safety, FSIS intends to allow further increases in line speeds. The 175 birds-per-minute proposed line speed more than doubles the current standard of 70 birds per minute under Streamlined Inspection System regulations.
I entered the FSIS inspection workforce in 1986, shortly after the introduction of the Streamlined Inspection System in poultry inspection. I also worked in beef slaughter inspection where the line speed had recently increased. It was readily apparent to me that high line speeds increase inspector error, increase the impact of contamination through process problems, and contribute to worker injury for those working the processing lines.
FSIS intends to allow plants to essentially double their line speed with respect to the current regulated rate of inspection. To understand the negative impact of this serious breakdown in regulatory influence, one should look at the run up to where we are today.
When I came on board with FSIS, plants were allowed to “reprocess” carcasses contaminated with feces and digestive tract contents. Prior to that, plants had to prevent contamination by fecal material. Evisceration processes under Streamlined Inspection routinely operated at significant rates of contamination. Contamination rates of 20 or 30 percent and higher were not uncommon.
I immediately learned that the remedy for high rates of contamination was to decrease the line speed. This would sometimes happen through FSIS control of the line speed, and, at other times, occurred due to plant processes not being able to keep up with widespread contamination and disease conditions. Plants were allowed to recondition contaminated carcasses at an off-line location by rinsing the contamination off with chlorinated water.
It was an almost daily event for the off-line reprocessing station to become overwhelmed with a high volume of FSIS-retained carcasses. This would often trigger line-speed reductions or complete halting of the slaughter process for the reprocessing work to “catch up.”
The high rates of contamination were typically related to a combination of causes. First, poultry growers would sometimes delay the withdrawal of feed from live chickens to sustain a desired live weight. This was done to maximize the financial return on the weight of their flocks. Second, mechanized processing would sometimes not be able to “properly synchronize” with carcasses during the evisceration process, causing digestive tract contents to be damaged, and a resulting contamination of carcasses. Third, plant workers, who were unable to sustain their manipulation of carcasses at sustained and tedious line speeds, would damage the digestive tract tissue, causing contamination of carcasses.
The sustained processing errors that contaminate carcasses cause on-line inspectors to become fixated and overwhelmed with errors so that individual inspection decisions become less accurate, further impeding the process of passing carcasses that are free of disease conditions and/or contamination. Remember, this commonly happens at the current line speeds.
Under HIMP, plant employees would suffer the same mental and physical impairments, exacerbated by further increases in line speed. Unlike FSIS inspectors, plant “sorters” in the HIMP pilot plants are under pressure from their production supervisors to do whatever it takes to maintain the maximum rate of production.
To address this matter of continuous contamination of carcasses, FSIS directed inspectors to pass contaminated carcasses and allow an “online reprocessing” step to neutralize pathogenic bacterial contamination. In other words, fecal contamination is spread and theoretically sanitized in the anti-microbial intervention process.
These systems introduce a rinse with an anti-microbial treatment such as Tri-Sodium Phosphate or Acidified Sodium Chlorite. The result is sustained line speeds and more profitable production yields. Judging by recent findings by Consumer Reports of high levels of Salmonella contamination at the consumer level, this profit comes at a cost to consumers who are sometimes sickened by poultry products.
The Hazard Analysis Critical Control Points law, in the form of Federal Regulation 9 CFR 417.6 (e) states that a plant’s HACCP plan is determined to be inadequate if, “Adulterated product is produced or shipped.” While FSIS, the industry, and consumer groups wrangle as to whether Salmonella should or should not be considered an “adulterant,” the findings by Consumer Reports demonstrates that poultry at the consumer level is contaminated with pathogenic bacteria. And it’s not just Salmonella. Campylobacter, Klebsiella pneumoniae, and Staphylococcus aureus were found in poultry identified in the aforementioned Consumer Reports article.
It is my opinion that historic increases in line speed have had a significant negative impact on the FSIS inspection process. It is also my assertion that the HIMP will significantly worsen problems of consumer and plant worker safety. There comes a time to introduce pragmatism into the discussion of the point where profitability and safety cross.
While I fully accept the reality of the industry’s need to cut costs and make processing more profitable, it must be balanced within the scope of consumer safety and product viability. Drastic increases in line speeds will enhance neither. This is the reality that any practical discussion of government inspection modification must accept.© Food Safety News