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The Hard Truth About Authentic Modernization of Poultry Inspection


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
  • John Munsell

    Alvin, your article is thought provoking, and I appreciate your candor. Initially, I perceived you would have a viable conclusion, but when I read your final sentence, I see DEATH written all over it. You really expect FSIS to put all its cards on the table & engage in honest dialogue? You are an idealist. Once FSIS authors an initiative, changing it to reflect common sense & reality is typically Mission Impossible. And your comment about having an inspector at the end of the line to inspect 3 birds per second being ludicrous and nonsensical is spot on. Hope you have some more articles! John Munsell

  • chickenadvocate

    What strikes me most about this commentary is that the birds themselves are completely invisible. What we have here is a total torture chamber for chickens and turkeys and what we also have is the total absence of pity, ethics or empathy for these poor birds and maybe even gratification that we can make them suffer so. This constitutes a diseased heart and pathology much worse than any physical infection can ever be – although in the case of coliform poultry-product poisoning, the two are linked. Will the day ever come when we wake up and feel the guilt and say, guess, what? We’ve done enough slaughtering. Let’s move on. Karen Davis, PhD, President of United Poultry Concerns, promoting respect and compassion for chickens and other domestic fowl and animal-free food.

    • John Munsell

      Karen, your comments have convicted me! I will never again eat a carrot. Think of the pain, anxiety and torture experienced by carrots as we forcibly extricate them from the only home they’ve ever known, to be forever separated from their brethren. To add insult to injury, if they only knew that I would subsequently skin them alive, and fry them in butter derived from a living cow. And you thought Hitler was cruel? John Munsell

      • Emily73

        Oh for pete’s sake, your comment is completely ridiculous. You obviously haven’t done any research on this topic. Animals who are treated inhumanely are more likely to harbor pathogenic bacteria that can be passed along to the people who eat them. Grow up.

        • John Munsell

          Regardless of how animals are treated, they carry pathogens. So do carrots and veggies. Chicken advocate’s primary focus is avoidance of consuming meat, which is her privilege. She uses charges of animal “torture chambers” and guilt to encourage us to no longer eat meat. We need to accept the fact that animal slaughter isn’t pretty, even when employing the best humane treatment available. Messy, blood on the floor, visible viscera, fragrance, etc. If you can’t accept these facts of life, grow up! John Munsell

          • chickenadvocate

            Dear friend, doesn’t it strike you that there are REASONS to urge people to stop eating animal products, all the more so since we do not need to eat animals in order to obtain the nutrients we need to be healthy? (As for the coliform pathogens found on spinach, tomatoes, melons, etc., these derive mainly from animal-based fertilizer and animal farm runoff. Salmonella, E. coli, Campylobacter, and Listeria are INTESTINAL bacteria. They are evacuated in feces. They do not grow on plants.)

            You note that animal slaughter “isn’t pretty” and give a quick glimpse of some of its inherent ugliness and filth. Considering that this “fact of life” is neither necessary nor inevitable, do you not understand why a person would choose a vegan diet over an ugly, cruel, unhealthy, needless meal of misery? When we factor in the documented environmental damage of animal agriculture, the food poisoning whose microbes remaining in the body can lead to arthritis and other diseases later in life, not just due to “old age,” and the fact that poultry products have been shown repeatedly to be the number one cause of food-borne poisoning in the kitchen, those of us who quit eating animal products have evidence-based arguments on our side versus your mere assertions and preference for the status quo.

            Having lived through the Civil Rights era in America and the amazing transformation in American public opinion on behalf of Gay Rights and Marriage, and even remembering that cigarette smoke was EVERYWHERE in the 1950s when I was growing up, and now it is virtually nowhere in any public place, home or office, I will say that without going so far as optimism, I work for and believe in ethical progress, not only because it’s right but because I have seen ethical progress happen in other areas of life and I believe there is something good and sensible in people, deeper than the incrustations of conformity, custom and convention, that could eventually bode well for chickens and other victims if we just keep working at it.

            Karen Davis, PhD, is the author of Prisoned Chickens, Poisoned Eggs: An Inside Look at the Modern Poultry Industry (1996; 2009).

  • John Munsell

    Alvin, I have to apologize to you. I took chickenadvocate’s bait. Although your article discussed probable failures within HIMP to improve food safety, chickenadvocate has changed the focus to torture chambers, empathy for poor birds, guilt, and now the transformation of American opinion on gay rights & marriage (the foundation of HIMP, you know). Her initial response had absurdities, so I fought fire with fire. I should have totally ignored her irrelevant remarks. Hopefully both she and FSN management will read this comment, & allow her to author an article in FSN, giving her an opportunity to explain how homosexuals and vegans constitute “ethical progress” (her terminology), and explain their relationship to your concerns about HIMP’s misgivings. Ehtical progress? Hmmmmmmmm. John Munsell