A healthy progression of events is occurring in the world of food safety. There are specific issues being debated over the Modernization of Poultry Slaughter proposal. The scientific community is zeroing in on specific strains of pathogens. Media and consumer groups are focusing on antibiotic resistance. Industry and labor groups are talking about ergonomic safety. Different approaches to solving food safety issues are networking to instigate positive change. This is progress, but there is much more work to be done.
Some believe the current system is the only way of adequately inspecting meat and poultry. They believe that only through unbiased and consumer-oriented government control of line conditions can inspection be effective. That has some merit, and I’ll explain why.
Line inspectors are able to apply control in real time on non-compliant processing conditions. They are in a position to prevent chronic processing problems from going unchecked for extended periods of time. Even with on-line reprocessing systems, inspectors still have the ability to control line speed in response to high error rates that impede thorough inspection of carcasses.
Some in the industry have called line inspection a “chokepoint” on production. That expression is not entirely incorrect. Some entity, no matter who manages it, must have the latitude to exert effective correction of processing problems. The assumption that plant-employed “sorters” will have the autonomy of FSIS line inspectors is naïve.
There is an alternative – a system of real-time regulatory activity that addresses statistically and scientifically diagnosed problems in an authentic and effective manner.
As I discussed in a previous article, The HACCP Inspection Models Project Has More Problems Than Solutions, the Science Based Inspection System (SBIS), proposed in 1997 by the National Joint Council of Food Inspection Locals, was significantly weakened by FSIS management and became the HACCP Based Models Project (HIMP).
The SBIS proposal had a paradigm shift that merited discussion. One was the idea that the plant could place as many sorters as they deemed necessary to accomplish effective maintenance of compliant line conditions. The FSIS inspectors are placed in fixed and unvaried positions. SBIS afforded the opportunity for varying sorting activities designed by individual plants and production scenarios. This is essential.
SBIS also maintained Finished Product Standards as set forth in 9 CFR 381.76. No changes to Pre-chill, Post-chill, or Zero Tolerance for Fecal Contamination testing. Off-line verification activities would be performed, without fail, by one of two offline FSIS inspectors. The second offline FSIS inspector would be free to move about the plant and perform operational sanitation, humane slaughter surveillance, completion of documentation, and other activities that may vary due to changes in facility and processing situations.
The SBIS proposal was based on the inspection configuration used in New Line Speed (NELS) inspection. This was done for practical reasons, including the plant’s quality-control function. NELS was a logical prelude to HACCP. The plant’s quality-control program, through regular testing of specific processing problems, could detect and correct processing problems more efficiently that waiting for a loss of control. Specific issues such as a machine, a protocol, or a human resource concern could be adjusted to maintain optimal processing efficiency. Corrective actions occur specifically and in real time instead of waiting for post-chill carcass E. coli and salmonella testing results to be known.
The SBIS proposal gave up one of three inspectors per NELS line, running 91 birds per minute, in exchange for improvements in working conditions, compensated training, and benefits in the form of a job upgrade for inspectors performing more complicated duties. FSIS would be able, over time, to reduce the on-line inspection resource by 20 to 30 percent. Plant employees would benefit from on-the-job training using improved FSIS standards of performance.
It was expected that FSIS would change the law for carcass-by-carcass inspection. That hasn’t happened. The resulting litigation and adjustments placed one of the two off-line inspectors into a fixed position at the end of the line. The line speeds of HIMP models plants run as much as twice that, which was outlined in the Science Based Inspection System proposal. This is a critical design flaw. The final inspection position is nothing more than an artifice to satisfy the current law. A human at the end of the line to monitor almost three carcasses per second is ludicrous. It is a nonsensical placement of an inspector to do the impossible and restricts the optimal use of resources. The law must be changed.
I can hear the ballyhoo about this hard truth, but the principles that were outlined in SBIS are sound. It is true that technology has moved emphasis away from that which can be detected by organoleptic inspection toward scientifically and statistically sound methods of government oversight.
But FSIS warped the SBIS proposal. Pathological conditions, some containing pathogenic bacteria such as Klebsiella pneumonia, were declassified as non-food safety issues. Line speeds went from 70 and 91 to unlimited rates. Statistical sampling rates under 9 CFR 381.76 were altered by the increased line speeds.
The cooperation that existed during the formation of alternative inspection configurations was poisoned. The situation is unfortunate, and everyone is suffering from the cost of the resulting impasse.
The reality remains that FSIS staffing is constantly stretched beyond its ability to perform necessary verification activities while back-filling vacant post-mortem inspection positions. This is not an acceptable situation. The notion of keeping things at “status quo” is simply not going to prevail. The demand for technological advances, fiscal constraint, and adaptation to changing processing situations will not allow for the static model to remain. It is time to start over and fix this 13-year-old HIMP project that is not getting off the ground.
HIMP has yet to perform at a level that improves current inspection effectiveness. FSIS’ own report, “Evaluation of HACCP Inspection Models Project (HIMP) August 2011,” page 26, shows that Salmonella Percent Positive Rates are higher in HIMP plants as measured against “Non-HIMP comparison establishments.”
During my career, I was involved in productive discussions on critical issues that improved negative situations within FSIS and industry. The Milbank Foundation meetings on workplace safety are an example of above-board cooperation yielding constructive results. These are the types of discussions that need to be happening now. They are not easy, but for those who have the ability to apply critical thinking and honesty, the process can have profound results.
FSIS, the industry, and all other concerns must take a realistic approach to reducing the pathogen risks. All stakeholders have to step up and cooperate. What is happening now is not likely to accomplish anything more than a blame game that benefits no one. It will not benefit the consumer, the industry, or the line workers (both government and private), nor will it advance science.
It is time we put all the cards on the table and engage in honest dialogue.© Food Safety News