Ever hear the one about how the well‐dressed accomplice caused a scene at the front door of the bank, while the masked robbers snuck in through the back and made off with the loot? Let that be a lesson to us: when we all train our eyes in one direction, we may miss the real danger lurking behind.

As USDA appears to be ramping up a pre‐release publicity campaign on the new poultry inspection system, the agency is struggling with the commotion at the front door, where the food inspector’s union is firmly opposed to changes that could make the slaughter inspection business even more dangerous for employees. The agency continues to try to highlight the cost savings to companies and to the government, without acknowledging the harm that could be done to workers and consumers. But there is another equally troubling element in the proposal: that there is no requirement for plants to test for the pathogenic organisms that are nearly omnipresent in raw poultry.

When USDA proposed its poultry inspection overhaul in 2011, unions were right to be concerned. The agency’s changes are both serious and sweeping: in addition to dispensing with much of the existing testing protocols, they propose to reduce inspectors and increase speed on the slaughter lines, and to shift responsibilities in the sorting room from inspectors to plant employees without requiring training, among others. Many of those changes would make a dangerous business even more so, and would do it without waiting for the findings of even a single long‐range study from the Occupational Safety and Health Administration about how it would affect slaughterhouse workers.

This is no small affront, given that these workers serve as the first line of defense for ensuring that safe food reaches consumers (just as farm workers do for produce). But it is not just workers who should be concerned about the possible rules—anyone who eats poultry should be concerned about the proposal on public health grounds.

The Obama Administration’s idea of “modernizing” poultry inspection is to permit each regulated company to decide what it wants to test for and how frequently. If you liked the results of letting banks regulate themselves, you may like the results of having big poultry companies controlling efforts to prevent contamination of meat and poultry. The tests and results would vary by company, making meaningful comparison impossible and limiting USDA’s ability to assess its program’s effectiveness or conduct strategic planning and reduce threats.

These threats aren’t theoretical either. Hundreds of outbreaks and thousands of illness each year are linked to poultry, many from dangerous bugs like Salmonella and Campylobacter. CSPI’s recent report, Risky Meat, showed chicken and turkey on the top two tiers of a risk pyramid that ranked not just foodborne illness, but severe foodborne illness. That means the illnesses linked to poultry aren’t just inconvenient—they are far more likely to require hospitalization than many of the other meats we commonly eat. By the way, do you think USDA will stop at poultry or is this the future of beef and pork inspection too?

In 2011, Congress passed an important law to improve the safety of foods that FDA regulates (foods other than meat and poultry). It’s high time that Congress updated the Poultry Inspection Act, which was passed more than 40 years ago, and makes USDA more prevention‐oriented as well.

But rather than making wholesale change through rulemaking—and doing so in a sly manner that makes consumer advocates immediately wary that they have been disenfranchised—wouldn’t it be better to gather all stakeholders together to begin the difficult, necessary process of making meat and poultry safer? For an administration that lauds transparency, it is shocking for USDA to propose dramatic changes to poultry inspection without even the benefit of a single public hearing.

If the goal of the project is truly to maximize public health, the agency should institute each change separately, spacing them out and gathering data at each new phase. It is not only common sense, but good science to assess each new change individually in representative slaughterhouses to determine if it has a measurable effect—positive or negative— on the frequency of contaminated birds.

If the experience of passing a new food safety law for FDA taught us anything, it is that consumers, industry, and regulators can work together to further the goals of public health. Similar consensus was reached in the mid‐1990s, when then‐Secretary Dan Glickman convened all stakeholders in a series of public meetings to map out a modern program for preventive controls in meat and poultry products.

When all parties trust that they share a common goal—to prevent illness—alliances like these can move mountains of public health policy in the right direction.

When consumer and worker advocates speak out so strongly against a proposal like the one put forth by USDA to overhaul poultry, it should give everyone pause. Rather than speeding up the process and dashing for the getaway car, the agency should slow down and heed the alarms of its stakeholders.

While some of Hershberger’s supporters have wanted to see the trial turned into a debate over raw milk, the judge in the case, Guy Reynolds, reaffirmed the narrow focus on regulation when he ruled during a pretrial hearing Tuesday that issues related to raw milk can’t be introduced by either the prosecution or defense.

The technical legalities of the case, however, fail to convey the case’s national political importance. Other cases similar to Hershberger’s have sprouted around the country, from Maine to California, where owners of small farms are selling meat, raw dairy products, and other staples directly to consumers in search of wholesome food. The controversy, and attendant legal problems, stem from the fact that the farmers are increasingly selling their food via private contracts, outside the regulatory system of state and local licenses and inspections that govern public food sales.

Federal and state regulators have responded by seeking legal sanctions against farmers in Maine, Pennsylvania, Minnesota, and California, as well as in Wisconsin. These sanctions include injunctions, fines, and even possible prison time. Food sold by unlicensed and uninspected food is potentially dangerous, say the regulators, since it can carry pathogens like Salmonella, Campylobacter, and E.coli O157:H7, leading to mild or even serious illness.

While these cases are testing the limits of food regulation, they raise deeper and more fundamental questions. Why would hard-working, normally law-abiding farmers be teaming with educated urban and suburban consumers to flaunt licensing and permitting regulations and statutes that have held sway for decades? Why would parents, who want only the best for their children, be seeking out food that regulators say could be dangerous?

Indeed, if you talk to individuals who belong to Hershberger’s food club, many of them from the Madison, WI, area, they talk about food choices and health rather than permits and licenses. Jenny DeLoney, a Madison, WI, mother of three young children., says she buys food from Hershberger because she wants food from animals that are treated humanely, allowed to roam on the pasture. “I really want food that is full of nutrients and the animals to be happy and content.”

Jennifer Bell, a Madison mother of two children, has been buying eggs, beef, honey, and raw milk from Hershberger for the last three years. “I’ve seen a lot of improvements in my digestive system” during that time, she says. Her son’s stomachaches have disappeared as well. She believes Hershberger’s farm-raised food is more wholesome and nutritious than mass-produced food in the supermarkets, and that her and her family’s health improvements are testimony to that reality.

Another member, Joy Martinson of Mt. Horeb, says the fact that her health has improved has reinforced her sense that she should have a choice in her food:  “I am an informed consumer and I choose to obtain healthy food directly from the farmer without government intervention.”

Hershberger himself talks about “the fundamental right of farmers and consumers to engage in peaceful, private, mutually consenting agreements for food.”

These individuals are clearly interpreting “health” and “safety” differently than the regulators. The consumers have seen such things as videos of downer cows being prodded into slaughterhouses and chickens so crammed into coops they can barely breathe. They have seen the statistics showing that eight percent of children today have allergies and nine percent have asthma. To these individuals, safety is much more than the single-minded focus regulators place on pathogens.  To many of them, who are parents, safety means not only food free of pathogens, but food free of pesticides, antibiotic residues, genetically modified (GMO) ingredients, and excessive processing.

Some consumers are going further than claiming contract rights—they are pushing their towns and cities to legitimize private farmer-consumer arrangements. In Maine, residents of nine coastal towns have convinced town meetings to pass so-called “food sovereignty” ordinances that legalize unregulated food sales; towns in other states, including Massachusetts and Vermont, have passed similar ordinances.

The new legal offensive hasn’t gone over well with regulators. Maine’s Department of Agriculture filed suit against a two-cow farmer, Dan Brown, in one of the food-sovereignty towns, Blue Hill, seeking fines and, in effect, to invalidate the ordinances. A state judge in late April sided with the state, issuing an injunction barring Brown from continuing his unregulated food sales, and in effect invalidating the Blue Hill ordinance.  Brown is planning an appeal.

At its heart, this is a struggle over a steady erosion of confidence in the integrity of our industrial food system, which has been hit by disturbing disclosures seemingly on a weekly basis. Members of Congress and the U.S. Centers for Disease Control have in recent weeks escalated warnings about the growing danger of antibiotic-resistant pathogens emerging from farm animals, which consume about 80 per cent of all antibiotics in the U.S. The Atlantic reported last summer that medical specialists are seeing a spike in women with urinary tract infections caused by antibiotic-resistant bacteria, likely transmitted by chicken meat.  Voters in a number of states have mobilized to push for laws requiring labeling of foods for the presence of GMO ingredients.

Eroding confidence in the food system is no small matter. It threatens large corporations in serious ways if long-established food brands come under prolonged and severe public questioning. It threatens economic performance if foods deemed “safe” become scarcer, and thus more expensive. And it is potentially explosive politically if too many people lose confidence in the competence and expertise of the food regulators, and encourages folks to seek private solutions.

The battle seems almost certain to intensify, as more farmers like Hershberger hook up with consumers for private food sales and regulators hunker down to deter the end run around existing regulatory protocols. No matter what the jury’s decision in this case, we will hopefully see the emergence of a new broader view and discussion about the meaning of food safety.

It’s these little twists and turns that make me love the “Farm Bill.”   Since USDA supposedly got the job in 2008, it has not inspected a single farm-raised U.S. catfish.  (To her credit, Dr. Elisabeth Hagen, USDA under secretary for food safety,  has promised Congress she’d have a final rule out by the end of this fiscal year, which would bring about the catfish inspections if they stayed at the Food Safety and Inspection Service (FSIS) and not transferred to FDA.)

But it has been one of those long, drawn out Washington D.C. stories.  While the food safety community has mostly stood behind the domestic catfish industry on this one, we’ve had to feel just a little whacky as no one at USDA or elsewhere in the executive branch of government much liked where this was going.   They always seemed to imply that Boeing might lose a multi-billion airplane order just because we want to make the world safe for catfish Po’ Boys.

While never happening, USDA catfish inspection did become a poster-child of government waste with the likes of John McCain charging that it was costing taxpayers $20 million.   I never understood where that one came from as USDA only had a handful of staff work on the issue for about year.

But now if these Farm Bill committee votes are any indication, the job of not inspecting catfish will go back to FDA, where it will continue not inspecting more than 99 percent of imported catfish each year as it does with all the other foreign seafood coming ashore in the USA.

The fact that FDA inspects less than 1 percent of imported seafood, added to a high percentage of food fraud that appears to be happening at the docks, does not make one feel warm and fuzzy about the safety of fish in general. Recent studies say 33 percent of imported fish is mislabeled as one species when it really is another.

But this is topic the Farm Bill crowd does not seem to want to get into.  The public is asleep on the issue.  Nobody has given fish species mislabeling a catchy name like “pink slime” and so far no “horse fish” has been found.  So even though there is a bill in the hopper to do something about it, the Farm Bill crowd can ignore the problem.

After all, they are there to divvy up the money we borrow, not get into messy details about the near total lack of seafood safety.  (By the way, do the Chinese still show up for our T-Bill auctions?)

So, catfish non-inspection is going to return to FDA.  Its inspection of foreign seafood is like a man trying to drink from a fire hose, it cannot keep up with the rapid increase in foreign fish coming across U.S. docks.

In 2012, there were 70 Import Refusal Actions against imported tilapia, the white fish species brought in to undercut U.S. farm-raised catfish. Among the reasons: Salmonella (33); illegal drug residues (13); filthy (12) Salmonella and drugs (8), and unsanitary (4).

The illegal drug residue included findings of cancer-causing nitrofurans in Vietnamese pangasius. Imported Chinese-sourced channel catfish led last year’s refusals.

“How can Americans protect themselves from tainted imported seafood when restaurants do not identify the county of origin of seafood they serve?” Catfish Farmers of America asked in commenting on the 2010 import refusals.

The Jackson, MS-based group represents catfish farms mostly located in Alabama, Arkansas, Georgia, Louisiana, and Mississippi. It says USDA inspection of catfish is a food safety issue. Such leading consumer and food safety groups as The Consumer Federation of America, Food and Water Watch, and STOP Foodborne Illness have backed it in that position.

In Washington, D.C., however, money is the only consideration. And, in that world the Catfish Farmers of America are depicted as merely looking for protectionism in a world of free trade. How can we hold whatever comes in from Vietnam or China to the same inspection standards as we have for U.S farm-raised catfish?

U.S. farm-raised catfish does have a few advantages. They are raised in fresh water ponds and fed high protein pellets that float on top of the water. They’ve been found to be an excellent source of protein, not fed any antibiotics or hormones or iodine.

USDA was never wild about taking on catfish, mainly because it would divert resources from meat and poultry inspection. The U.S. Government Accountability Office jumped on the issue, raising concerns about duplication with catfish going to USDA but the other fish being left back at FDA.

It’s hardly the only area of duplication between the two major food safety agencies. USDA grades eggs, but whether they are contaminated is up to FDA. Cheese and meat pizzas get into different regulatory lines.

Dr. Richard Raymond, the former USDA under secretary for food safety, says the duplication problem could be solved if Congress would just allow FDA and the Food Safety and Inspection Service (FSIS) to do something trading of responsibilities.

But that would make too much sense. Sending catfish back to FDA so more than 99 percent will not be inspected there is just the sort of solution Congress comes up with.   This could bounce back and forth for years.

Maybe, to protect its brand what U.S. catfish farmers should do is for for labeling in the home states.   The genetically engineered food crowd has already warmed up state lawmakers to the concept of state labeling. Alaska has already done it for salmon.

If there was a little American flag planted in my catfish Po’ Boy, then I’d know it was U.S. farm raised, under a HACCP plan, inspected, and tested.   I’d like that a lot.

In response to such tactics, I have authored a new report for Center for Food Safety that exposes the well-funded organizations and highly-sophisticated public relations strategies increasingly deployed to defend the food industry.

Best Public Relations Money Can Buy: A Guide to Food Industry Front Groups describes how Big Food and Big Ag hide behind friendly-sounding organizations such as: the U.S. Farmers and Ranchers Alliance, the Center for Consumer Freedom, and the Alliance to Feed the Future. The idea is to fool the media, policymakers, and general public into trusting these sources, despite their corporate-funded PR agenda.

With growing concern over the negative impacts of our highly industrialized and overly processed food system, the food industry has a serious public relations problem on its hands. Instead of cleaning up its act, corporate lobbyists are trying to control the public discourse. As a result, industry spin is becoming more prevalent and aggressive.

For example, the same group cited above – the International Food Information Council – in addition to publishing industry friendly reports, also infiltrates professional conferences such as the annual meeting of the Academy of Nutrition and Dietetics, the nation’s trade association for registered dieticians.

In 2011, IFIC moderated a panel at this event called, “How Risky is Our Food? Clarifying the Controversies of Chemical Risks,” in which the take-away message was not to worry about pesticides, and anybody who tells you otherwise is scaremongering and non-scientifically valid. At the 2012 conference last fall, IFIC was back again, with representatives on four separate panels, including dispelling any concerns about food additives.

In addition to IFIC, other front groups that have been around for some time include the notorious industry attack dog, Center for Consumer Freedom, which began in the 1990s with funding from tobacco giant Philip Morris.

In the recent controversy in New York City over limiting the size of sugary beverages, CCF took out full-page ads in major newspapers showing Mayor Michael Bloomberg dressed as a woman with the tagline, “New Yorkers need a Mayor, not a Nanny.” Name-calling and scaremongering are very effective tactics for distracting away from the issue at hand: a serious public health problem.

Big Soda also invented an entirely new front group to do its bidding called “New Yorkers for Beverage Choices,” which pretended to represent individuals, but in fact was funded by the American Beverage Association, the Washington DC-based lobbying arm of the soft drink industry. It’s a brilliant strategy when you realize that creating a group named “Coke and Pepsi Opposing Public Health in New York” just wouldn’t fly.

By relying on a front group such as the Center for Consumer Freedom to do its dirty work, well-known companies like Coca-Cola and PepsiCo are able to keep their noses clean, and their valuable brand reputations intact.

This report is extremely timely because now more than ever new front groups are forming so quickly that it can be hard to keep up. And with deliberately confusing names such as Alliance to Feed the Future, Center for Food Integrity, and Global Harvest, it can be challenging to tell the good guys from the bad. I often have to remind people not to confuse the industry front group Center for Food Integrity with either the Center for Food Safety or the Food Integrity Campaign. Front groups position themselves cleverly to try and confuse media outlets, which too often just assume the information is coming from a reliable source.

The new report answers such questions as, “What is the Different Between Trade Groups and Front Groups?” (mostly that trade groups lobby, while front groups rely more on PR), “What are Common Front Group Tactics?” (scaremongering and buying science, for example) and “How Can We Fight Front Groups?” Most importantly, the report contains numerous examples of front groups, including recently formed groups created in response to heightened criticism and awareness, along with scientific “institutes” invented by such food giants such as Coca-Coca, Nestlé, and General Mills.

Junk food companies, the biotech industry, and big agribusiness are all on the defense because the nation is waking up to the myriad problems our industrialized food system has created, from public health epidemics to environmental disasters to horrific exploitation of humans and animals alike. It’s a testament to the food movement’s success that industry is responding with such sophisticated and well-funded public relations efforts.

But we can’t allow these disingenuous and deceptive tactics to undermine our good work. It’s imperative that reporters, policymakers, and the general public do their homework to learn exactly who is behind these industry front groups and not fall for their biased propaganda and public relations stunts. You can start by reading and sharing this report, which you can download HERE.

This article was originally published by the Center for Food Safety Blog March 14, 2013. 

So it’s only fair that I note that GMO labeling forces are celebrating a victory of sorts. The Vermont House of Representatives on May 10, 2013 became the first legislative body in America to pass a GM food labeling bill. The historic vote was 99-to-42 on H-112, requiring the labeling of all genetically engineered food in the state.

I say it’s a victory of sorts because the GMO bill is not getting a vote in the Vermont Senate this year. If H-112 gets a Senate vote in 2014, it still does not become law until at least two other states adopt similar measures.  Still, milestones are milestones. The national “Just Label It” campaign and Consumers Union, the lobbying arm of Consumer Reports, both put out press statements applauding the action by the Vermont House.

Alaska earlier this year did enact a law requiring the labeling of GE fish, which is designed to give extraordinary protection to the state’s prized salmon stocks. Washington State voters will likely also be hearing plenty about the threat of bulked-up GE salmon this fall.

In perhaps its smartest move since the Prop 37 defeat, the GM food labeling campaign did an initiative to the Legislature in Washington, which required less money spent on acquiring petition signatures and is ending up on November ballots because lawmakers opted to take no action against it.

They could have amended it, or put up their own alternative against it, but by taking no action the Initiative 522 campaign starts out on top much the way Prop 37 did in California. I guess this means that the GMO labeling issue just keeps on giving.

Before I go further, let me state for the record that I like to see the “wiring diagrams” for any and all food available to all of us. In the past, I’ve suggested we should all be supporting the contest for developing a Star Trek-style Tricorder that we could use to satisfy our curiosity.

What I haven’t been able to get all that excited about is just labeling GM food with some simple line like; “This product has been modified by genetic engineering.” If that fulfills the “right to know” mandate, I for one would be very disappointed.

If the scientific consensus is that GM foods carry no more risk to human health or the environment that their non-GMO counterparts, is this line on the label really going to mean that much? On the other hand, if, as I suspect, it’s another meaningless throw-away line on our already crowded food labels, why does the food industry care so much? (Or at least to the tune of the $45 million it spent opposing Prop 37 in California.)

The food industry’s problem is that it cannot see over the horizon. My guess is that the GM label would become another indicator, not unlike the organic label, that consumers would use to process their decisions. Sure, some might stop buying anything with a GM label, but how many? If the hops used in my favorite beer were genetically modified, I doubt if I’d care.

What consumers really want to know is more. If they find their favorite cereal is made with wheat genetically modified to grow during droughts, they probably will be happy to know without changing their purchase decision.

In other words, the food industry should pour on more information, not less. It should make transparency its friend and cease playing defense to a motley collection of activists. Consumers are hungry for more information. We in media love campaigns that never end, but the public would really like to see somebody do something useful with food information for a change.

“The BRC, and now the recent SQF Code for Product Sampling, Inspection and Analysis, were no small part of our decision to pursue this strenuous process,” says Kent Oostra, CEO and Laboratory Director for Exact Scientific Services, a chemistry and microbiological testing and compliance lab working with food, nutraceutical, environmental and agriculture clients.

For instance, SQF Code, Edition 7, 2.5.6 mandates that, “Where external laboratories are utilized to conduct input or product analysis, the laboratories shall be accredited to ISO 17025 or an equivalent national standard.”

In addition, the U.S. Food and Drug Administration will be requiring labs to be accredited to ISO or an equivalent standard if they do detained samples, pending approval.

Nutraceutical companies also enter into the ISO discussion in that ISO 17025 certification meets such requirements as CFR 111 FDA for food and dietary supplement manufacturers.

Unexpected benefits: internal auditor and customer assurance — at a global level

Himself a farmer, Oostra knows the practical implications of these regulations – and how they can impact the bottom line of his clients. So he wanted to do it right on behalf of making life a little easier for his clients, and in being able to share his experience with others along the way.

Fortunately, Oostra discovered a silver lining along the way. “We uncovered a number of surprising benefits for our clients through ISO certification,” he says. “Our clients are telling us that ISO provides peace of mind during internal audits, as well as assurances for their customers.”

According to Barleans Organic Oils’ Director of Quality Assurance, Mike Kaminski, an Exact client, ISO accreditation “helps us when we have internal audits and they ask us if our lab has certifications. The ISO speaks volumes and helps us a lot.”

Client Enfield Farms agrees. According to Quality Assurance Manager Laura Macaulay, “ISO is gaining in importance in our audits. A third-party lab negates the potential for conflict of interest, and an ISO certified lab negates any concerns for testing procedures.”

Enfield’s Macaulay points out another benefit, “Our customer base is a huge reason to have third-party ISO certification. Customers are everything in the food industry.”

And since ISO is an internationally recognized accreditation by ILAC, ISO accredited laboratory results receive a form of international recognition which allows their data to be more readily accepted.

A client working in offices across the globe points out key benefits from internationally recognized accreditation: “We don’t need to get products double tested in different markets to accommodate regional requirements. ISO accreditation also means that we can be assured Exact Scientific’s processes are audited and certified under strict guidelines, which supports our SQF auditing requirements.”

This stringent mandate for precise and accurate testing ends up minimizing risk, helps reduce or eliminate the need for retesting, and builds confidence for customers through thorough evaluation of products by an independent and competent testing laboratory. “All of this reduces costs, improves acceptance, and positively impacts the bottom line,” says Oostra.

Indeed, ISO 17025 looks at a laboratory’s ability to produce precise and accurate tests. ISO evaluates the technical competence of the staff, validity of test methods, traceability of the testing, quality assurance of data and the testing environment, and suitability, calibration and maintenance of test equipment. And to ensure continued compliance, accredited laboratories are audited on a yearly basis to check that they are maintaining their technical expertise.

It was worth it

The work has also paid off by providing benefits to Exact itself. “Besides now being one of the few testing laboratories in Washington State, and a relative few nation-wide that is ISO 17025 certified,” Oostra says, “Exact has also became one of few, if not the only, ISO lab in Washington State that is accredited to gluten, proximates, rancidity, and fatty acid profile testing, and that meets USP methods needed by supplement companies.”

Looking back on the process, Oostra says it wasn’t easy, but it was worth it in several practical ways: “It has helped streamline our work, organize our flow and serve our clients better, wherever they are located in the world” In the big picture,” Oostra says, “ISO Certification has given one more opportunity of providing our clients and employees with a higher standard of service. In fact, it has been such a benefit, we apply it to all aspects of our own business each and every day.”

One of the many roles of public health is to protect consumers from threats like foodborne outbreaks. Much of this hinges on quickly getting out clear messages to the public that provide simple steps to help stem the spread of disease. This is something public health professionals have been doing for over a hundred years, but a recent outbreak of Salmonella Heidelberg got us wondering, “Are we doing enough to keep the public safe? Are we too slow? And, how can we improve?”

That’s not to say there weren’t triumphs in this outbreak, but like most responses we had a moment of self-reflection when the crisis was over and we were able to take a step back and consider our methods. What we found was a need for stronger policies and faster messaging to the public.

The Outbreak

Between June 2012 and January 2013 epidemiologists with Oregon Public Health, along with the Washington State Department of Health, CDC, and the US Department of Agriculture independent of each other, began noting increases in the number of Salmonella infections. Thanks to surveillance systems like CDC’s Pulsenet and National Retail Monitoring System (NARMS), epidemiologists were able to narrow down the specific genetic make-up of the Salmonella in question (Salmonella Heidelberg) and link it to raw or undercooked Foster Farms brand chicken.

The Pros and Cons

For decision-making and public information, we did several things right. Including:

1. Communicating with the company responsible for the tainted chicken, which helped provide critical information needed to confirm the source.
2. Developing simple messages that explained the outbreak and how individuals could prevent Salmonella were developed. These messages followed the Crisis & Emergency Risk Communication  framework, which encourages the use of transparent messaging that provides the public with meaningful actions to protect themselves from harm.
3. Growing a strong partnership between our epidemiologists, leadership, and risk communication officer over the course of the investigation provided a basis for mutual trust and respect. This rapport led to faster message development.
4. Finally, by following Incident Command System principles, we were able to better coordinate communication activities across the several agencies involved.

Although we were successful in getting the message out, there were several factors that we felt slowed this outbreak response down:

1. Despite having several state and federal agencies collecting clues, we weren’t doing it together, which meant more time was spent on the backend to get everyone on the same page.
2. Not all staff had been trained on the laws and policies related to release of information, which was needed for rapid decision-making during the outbreak.
3. Oregon Public Health (as we suspect is the case with many state health departments) has no risk communication policy, which meant not everyone was on the same page about how and when we would share information and release information to our partners and the public.
4. Political happenings unrelated to the outbreak ended up blocking the release of important health messages by two days — another all-too-common experience for many risk communicators.

How Can We Improve?

Given these pros and cons, we still think much can be done to improve decision-making and risk communication during an outbreak. The federal Food Safety and Modernization Act of 2011 was an important step toward improving the safety of our nation’s food supply. However, our experience responding to Salmonella Heidelberg outbreak in Oregon also suggests that additional state and federal policies are needed not only to prevent outbreaks, but also to help public health authorities implement best practices in risk communications and public health responses when outbreaks do occur.

No state health department funded with federal dollars — CDC or otherwise — should be without a well-developed risk communications plan that can be operationalized at a moment’s notice. Similarly, states should be held accountable to ensure information about emerging outbreaks is shared between epidemiologists, other partners, and response staff, and to identify the triggers for public warning and messaging about health risks. Depending on the risk, even a one day delay in response could mean more sick people, and in turn more health care and social costs.

Dr. Kathleen Vidoloff is the Emergency Risk Communication Officer for Oregon Public Health Division where she oversees the development, implementation and evaluation of risk communication activities.  She is also an Adjunct Professor of risk communication at the University of Oregon. Dr. Vidoloff previously worked as a contractor at the U.S. Centers for Disease Control and Prevention evaluating emergency risk communication strategy for international and domestic emergency responses.

Dr. Jean O’Connor was Oregon’s Deputy Public Health Director and the Principal Investigator for Oregon’s public health preparedness and infrastructure improvement funding awards from 2011 to 2013.  She has more than 15 years of experience with CDC, state public health agencies, and non-profit organizations,  including work on numerous responses to domestic and international public health events.  She is also an Adjunct Associate Professor at Emory University’s Rollins School of Public Health where she teaches law and policy.

Disclaimer: This blog post does not represent the official views of the Oregon Public Health Division or the Oregon Health Authority

Editor’s Note: This article originally appeared on CDC’s Public Health Matters Blog May 1, 2013.

Dr. Raymond challenged some of the points raised by Tom Philpott on April 24, 2013 in a story authored for Mother Jones entitled, “USDA Ruffles Feathers with New Poultry Inspection Policy.” I would like to address some of Dr. Raymond’s assertions.

First, he takes exception with Mr. Philpott’s observation that the maximum line speeds in chicken slaughter plants under the proposed privatized inspection model will run 25 percent faster than the current maximum for plants that receive conventional inspection. That is absolutely correct. The current maximum line speed in plants that receive conventional inspection is 140 birds per minute. There are 4 USDA inspectors assigned to that slaughter line – each inspecting a maximum of 35 birds per minute. The proposed rule sets the maximum line speed at 175 birds per minute – 25 percent higher – with only one USDA inspector left on the line. I thought that Mr. Philpott was being much too conservative in what could happen under the proposed model. Under the new system, the remaining USDA slaughter inspector on the slaughter line could face a 400 percent line speed increase.

For some strange reason, Dr. Raymond challenges USDA’s own estimates that the new inspection model would save the Department $90 million over a three year period. The headline of the Department’s January 20, 2012 news release published when Secretary Tom Vilsack announced his intent to propose a rule that would privatize poultry inspection stated:

USDA Seeks to Modernize Poultry Inspection in the United States

Inspection would focus on areas most critical to ensuring food safety, save taxpayers more than $90 million over three years and lower production costs by more than $256 million annually (1)

Straight from the horse’s mouth. And it cannot get any plainer than that. Dr. Raymond tries to confuse the issue about pay upgrades for certain inspector positions, but the bottom line is that the budget for the Food Safety and Inspection Service (FSIS) will shrink by implementing this new inspection model because upwards of 800 inspector and supervisory inspector positions will be eliminated. Department officials have made media statements saying they believe most if not all of the reductions can be achieved through attrition, but that is not a guarantee (2).

As a consumer, I care about those so-called “quality defects” that Dr. Raymond and the advocates of the proposed new system seem to dismiss. Besides feathers, those “quality defects” that will be turned over to company-paid employees to inspect under the new system include: fecal contamination; digestive content (ingesta); improper evisceration where organs, such as intestines, are still in the carcass; and disease conditions, such as septicemia and toxemia. According to the proposed rule, the company-paid “inspectors” do not have to be trained to assume these duties, while USDA inspectors are trained to work on poultry slaughter lines.

A year ago, Food & Water Watch was contacted by a consumer in Georgia who had bought a package of chicken that he intended to barbeque for his family on Mother’s Day. When he opened up the package, he found that some of the chicken breasts had some hard yellow substances on them. He sent us photos of the packaging and of the suspect chicken breasts. It turned out that those yellow substances were of partially digested chicken feed or ingesta. That product should never have been allowed into commerce. The package wrapper had the USDA-inspected label on it with the establishment number P-177. P-177 happens to be the Pilgrim’s Pride plant in Gainesville, Georgia. That plant also happens to be one of the 20 HIMP broiler plants that Dr. Raymond is so proud of, where the privatized inspection model is being piloted by USDA. You can take a look at the photo of the ingesta on that chicken on our website and an analysis of the inspection data from some of the HIMP plants we did that revealed that not only feathers were missed by the company employees, but a whole host of other “defects” such as visible fecal contamination (3).

I showed the photos that we had received from that consumer to Congressman Jack Kingston of Georgia who at the time was the Chairman of the House Agriculture Appropriations Subcommittee and the main congressional advocate for privatized poultry inspection, and to the current USDA Under Secretary for Food Safety Elisabeth Hagen and FSIS Administrator Alfred Almanza. I explained what the photos represented and I told all of them that when I go to KFC to order fried chicken, the cashier always asks: “Do you want original recipe or crispy?” Not, “Do you want original recipe or CRUNCHY?” Yes, Dr. Raymond, I want my taxpayer dollars to go to government inspectors to keep the food I feed my family safe and wholesome.

Dr. Raymond also dismisses the discussion that has taken place on the issue of worker safety as it relates to the privatized inspection model. This concern is not new. The Government Accountability Office issued a lengthy report in January 2005 entitled, “Safety in Meat and Poultry Industry, While Improving, Could Be Further Strengthened” (4). Among the recommendations included in that report was for the National Institute of Occupational Safety and Health (NIOSH) conduct a study of the impact of line speed on worker safety and health. I would like to take Dr. Raymond down Memory Lane to his “Salmonella Initiative Program” that he announced in February 2006 while he was under secretary. That program was designed to give the poultry industry certain incentives in exchange for increased Salmonella testing. One of the incentives was to allow up to five plants to increase their line speeds to increase production. As Dr. Raymond will recall, some members of the Safe Food Coalition, including Food & Water Watch, expressed concern with the impact that increased line speeds could have on food safety and worker safety. We alerted members of Congress about what was being proposed and in the FY 2009 Omnibus Appropriations Act (P.L. 111-8), the following language was included:

The Department is currently reviewing several proposals to increase maximum line speeds at chicken slaughter facilities. FSIS is directed to make any analysis conducted by the agency on increasing maximum line speeds, and the effects such changes might have on food and employee safety, available to the Committees within 30 days.

The Department slow-walked the analysis and the results have never been made public.

One modification made to Dr. Raymond’s Salmonella Initiative Program in July 2011 was to require any plant that sought a line speed waiver to agree to have NIOSH conduct a study on the impact of line speed on worker safety. One plant has come forward – the Pilgrim’s Pride in Sumter, South Carolina. But NIOSH has already informed FSIS that it will take 3 ½ years to complete its study. Whether the findings from that one plant can be generalized to the entire poultry industry as a whole is another issue.

In advocating for the privatized inspection model, Congressman Jack Kingston stated that one of the savings that FSIS can realize is reduced workers compensation claims from inspection personnel “as the repetitive stress injuries associated with sorting carcasses are reduced” (5).

Interestingly, a key FSIS management official made that same assertion to members of the Safe Food Coalition during a briefing session on the proposed rule in March 2012. When I pointed out that the new inspection model was shifting additional costs of worker injuries to the private sector and that was not included as part of the agency’s economic analysis accompanying the proposed rule, the management official responded that I could include that point in my written comments to proposed rule. So, Food & Water Watch did. But to this day, I have not heard anyone from USDA express any real concern about the working conditions in these plants.

Frankly, I am so disappointed that Dr. Raymond thinks that the worker safety issue should not be on the table for discussion in the context of the proposed rule. When Mike Johanns, Dr. Raymond’s old boss, served as Nebraska’s governor, he realized that workers were being denied their rights in the meatpacking industry in that state. Governor Johanns signed an executive order entitled “The Meatpacking Worker Bill of Rights,” that enumerated basic rights that workers in those plants should have including the right to organize into a union and a right to a safe workplace along with the right to file complaints related to health and safety issues without fear of reprisal (6). There is intimidation in the meatpacking industry across the country. Workers are afraid to come forward for a variety of reasons. I strongly suggest, Dr. Raymond, that you read the Southern Poverty Law Center’s report entitled, “Unsafe at These Speeds: Alabama’s Poultry Industry and its Disposable Workers.” It will teach you why worker safety needs to be discussed in conjunction with the proposed rule and how it is related to food safety (7).

As a food safety advocate, I am interested in reducing foodborne illness. Unfortunately, the proposed rule is not going to accomplish that. All it is going to do is deregulate inspection. As some of us have continually pointed out, Salmonella and Campylobacter are not going to be reduced unless there are enforceable performance standards. That means going to Congress and proposing legislation to get that authority. Dr. Raymond did not do that when he was under secretary and I have not discerned any desire by the current administration to do it either. So, we keep playing around with all sorts of gimmicks that probably will not work because they nibble at the edges of the problem.

I would like to point out several other facts that Dr. Raymond carefully avoided in his piece.

First, on page 26 of the FSIS document entitled, “Evaluation of HACCP Inspection Models Project (HIMP)”, there is a chart that shows that for the latest data provided, the Salmonella rates of poultry slaughtered in HIMP plants were higher than the rates in comparably sized plants that received conventional inspection (8).

Second, as a result of Dr. Raymond’s Salmonella Initiative Program, each month FSIS posts on its website a listing of poultry plants that fail the government’s Salmonella testing. The latest Salmonella verification testing results show that two HIMP broiler plants – the Tyson plant in Clarksville, Arkansas and the Golden Rod Broilers plant in Cullman, Alabama – failed the government’s testing (9). They represent 10 percent of the HIMP broiler plants. What is going to happen to these two plants? Are they being kicked out of HIMP? Will they be allowed to use the new inspection model if the final rule is implemented? Those are questions that need to be answered by FSIS before they move forward with this new inspection model.

Third, FSIS concedes that there is no way to determine whether the new inspection model will contribute to an increase or a reduction or maintenance of the status quo for the incidence of Campylobacter (10).

If we are really interested in reducing foodborne illness, FSIS needs the regulatory authority to enforce its pathogen reduction standards.

Lastly, I would like to address Dr. Raymond’s allegations regarding the inspectors union and my association with it. Dr. Raymond has spent the better part of the last five years whining about the National Joint Council of Food Inspection Unions literally all across the world. The union is doing what it is supposed to do – representing its members. The FSIS inspectors are some of the most dedicated public employees I have ever met. They love their jobs protecting consumers in spite of the tough working conditions they endure and in spite of the roadblocks thrown in their way by their managers. It is not uncommon to find inspectors who have worked for FSIS for over twenty years. The leadership of the union is made up of volunteers – they are not paid to be officers of the union. They remain working inspectors. But Dr. Raymond expends too much energy maligning them. For what reason? Because inspectors have a right to a voice in their working conditions? Why can’t you accept that? And, in a recent post on Food Safety News, he has decided to cast aspersions about me. I expect Dr. Raymond to apologize to me and to retract his insinuation. The main reason that I communicate directly with USDA inspectors is due to the fact they speak the unvarnished truth about the enforcement of food safety laws and regulations, or lack thereof, which I do not seem to get when I deal with their bosses in Washington.

What Dr. Raymond should be doing is taking responsibility for the development of the Public Health Information System (PHIS) that occurred under his watch and has turned into an $82 million boondoggle that does not work. If we want to save the government money, maybe we should start there. He should also own up to the fact that FSIS secretly granted Canada equivalency status for a HIMP-style inspection model in beef slaughter during his tenure (11). One of the Canadian beef slaughter plants using that privatized inspection system is XL Foods, which just experienced the largest meat recall in Canadian history that left 18 Canadian consumers ill from eating beef contaminated with E.coli 0157:H7 (12). HIMP does not work.

—

(1)  United States Department of Agriculture.  “USDA Seeks to Modernize Poultry Inspection in the United States,” news release, January 20, 2012.

(2)  “USDA to Alter Visual Poultry Inspection,” MeatPoultry.com, January 20, 2012 (see http://www.meatpoultry.com/News/News%20Home/Regulatory/2012/1/USDA%20to%20eliminate%20visual%20poultry%20inspection.aspx)

(3)  See http://www.foodandwaterwatch.org/food/foodsafety/privatized-poultry-inspection-usdas-pilot-project-results/

(4)  U.S. Government Accountability Office.  “Safety in Meat and Poultry Industry, While Improving, Could Be Further Strengthened,” January 12, 2005, GAO-05-96.

(5)  U.S. House of Representatives. Hearing before the Subcommittee on Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations, March 15, 2011, p. 60.

(6)  Nebraska Department of Labor.  “The Meatpacking Worker Bill of Rights.”  (see http://www.dol.nebraska.gov/center.cfm?PRICAT=2&SUBCAT=5K&ACTION=bor)

(7)  Southern Poverty Law Center.  “Unsafe at These Speeds:  Alabama’s Poultry Industry and its Disposable Workers,” March 2013 (see http://www.splcenter.org/sites/default/files/downloads/publication/Unsafe_at_These_Speeds_web.pdf)

(8)  United States Department of Agriculture.  Food Safety and inspection Service.  “Evaluation of HAACP Inspection Models Project, August 2011, p. 26.

(9)  United States Department of Agriculture.  Food Safety and inspection Service.  “FSIS Pathogen Reduction/Hazard Analysis Critical Control Points (PR/HACCP) Salmonella Set Results for Individual Establishments (current as of April 1, 2013):  Category 3 Young Chicken (Broiler) Establishments” (see http://www.fsis.usda.gov/PDF/Category_3_Broilers.pdf)

(10)  United States Department of Agriculture.  Food Safety and Inspection Service.  “FSIS Risk Assessment for Guiding Public Health-Based Poultry Slaughter Inspection,” November 2011,  p. 10.

(11)  Letter from Sally White, Director of International Equivalence Staff, Office of International Affairs, USDA Food Safety and Inspection Service to Dr. William Anderson, Director of Food of Animal Origin, Canadian Food Inspection Agency granting equivalency status to the High Line Speed Inspection System in beef slaughter, March 2, 2006.

(12)  See http://www.phac-aspc.gc.ca/fs-sa/phn-asp/ecoli-1012-eng.php

There have been dramatic changes in the transgenic composition of GE corn and soybeans over the last five years, coupled with a substantial increase in reliance on pesticides and Bt toxins. Compared to the first five years of commercial use (1996-2000), today’s GE corn and soybeans in the U.S. require:

• About twice as much herbicide per acre, with glyphosate/Roundup accounting for essentially all the growth;
• In corn, two to six Bt toxins to deal with European corn borer and the corn rootworm complex;
• Delayed release, systemic seed treatments including at least two insecticides and two fungicides, one of which is a nicotinyl implicated in honey bee Colony Collapse Disorder;
• A return to corn soil insecticide use as a component of Bt-gene, resistance-management programs (eroding a portion of the reduction in insecticide use brought about by Bt corn);
• Significant and historically unprecedented increases in fungicide use on corn (11 percent of crop acres were treated in latest USDA pesticide use survey [2010], no more than 1 percent was treated previously); and
• Approval and commercial planting in the U.S. of the first GE crop that will be consumed in significant quantities by humans in a largely unprocessed form – Bt and RR sweetcorn.

The move to stacked varieties expressing multiple traits, coupled with the above changes in the intensity of chemical use required to bring GE crops to harvest, raises new questions about new routes of exposure and about cumulative levels of exposure to GE proteins, potential allergens and pesticides, especially via drinking water, certain foods made from corn or soybeans, and, for infants, breast milk, cow’s milk, soymilk, and formula. It also raises new testing challenges arising from the likely presence of multiple transgenes, DNA fragments, promoters, regulatory sequences and chemicals from pesticides (active ingredients, metabolites, surfactants, adjuvants, etc).

These changes pose serious risk assessment challenges that are, for the most part, being ignored by the industry and regulatory authorities. New information is essential to convince regulators that they must invest substantially more public resources in the independent testing of GE crop safety. The two core goals for a new testing initiative should be to (a) resolve lingering uncertainty over the safety of the GE traits currently on the market, and (b) develop advanced testing methods and protocols for application in the testing of future GE food traits.

At a minimum, the following steps should be taken to explore key questions about today’s GE crops:

1. Quantification of the levels of pesticides and their metabolites/breakdown products associated with GE crops in key foods and human fluids (blood and urine), encompassing initially glyphosate, AMPA, nicotinyl seed treatments and Bt proteins. Top priority foods to test include whole wheat grain and flour, whole wheat bread, and soy-derived ingredients and foods. Essential liquids to test include cow’s milk, breast milk, soymilk and infant formula.

2. Development of methods to accurately quantify GE protein exposure levels in tissues and organs of concern in evaluating human health risks. The research would also be designed to track the breakdown products formed as GE proteins move through the digestive system. Methods would be developed to identify the form of novel proteins or other phytochemicals from GE foods, as well as the quantities passing from the GI tract into the bloodstream, from the blood to the kidneys and liver, and in the case of pregnant women, across the blood-brain barrier.

3. Methods must be developed to assess the impacts on fetal development following pre-natal exposure to GE proteins via maternal blood flows. Focus should be on epigenetic patterns of gene expression and the frequency of auto-immune diseases including food allergies, asthma and behavioral problems.

4. In light of novel combinations of exposures, including combinations of glyphosate, AMPA, a nicotinyl insecticide and Bt proteins, short-term cell assays should be used to test for toxic potential of each of these singly and in various combinations. The results can be used to target subsequent, long-term testing.

5. An appropriate, government agency or international organization should fund long-term toxicology and cancer feeding studies in at least two species of laboratory animals on a cross-section of the major traits now in GE varieties. Trials should cover the most widely planted Bt endotoxins alone, the EPSPS gene conferring resistance to glyphosate alone and these two traits in combination. At the conclusion of a first round of testing, the research team should issue recommendations for the design and conduct of future cancer feeding trials applied to GE food traits and render judgments regarding the need for additional testing.

Then there are times when government, industry and consumers are not on the same page. Hells bells – they are not even in the same chapter of the same book. That’s where we stand today when it comes to changing poultry inspection in the United States.

And this has been going on for way too long. There are fewer and fewer meat inspectors working in the nation’s beef plants who can even remember the old “poke and sniff” days before the Jack-in-the-Box outbreak of deadly E. coli O157:H7. In beef plants for most of the past two decades, job #1 has been pathogen reduction and control.

But there was no mention of pathogen reduction and control in the 1957 Poultry Inspection Act, and it pretty much defines the world of poultry inspections today. Nothing has changed in 56 years.

Oh, except of course poultry contamination has run amuck with nasty bacteria like Campylobacter and Salmonella. You have to be damn careful of cross-contamination and cook the sh*t out of it.

To think that there might be a day when poultry processing brings something, maybe a drug resistant Salmonella, under control seems like so much of a pipe dream. Making pathogen control and reduction the primary job of USDA poultry inspection seems no closer now than when it was first proposed in 1998.

As long as the 1957 model continues, the several hundred USDA poultry inspectors will go to work every day, stand mostly on platforms and watch upwards of 9 billion bird carcasses fly by. Almost all will be totally uniform in size, shape and age.

I’m not sure what hundreds of eyes seeing the same thing over and over billions of time can really spot, but I damn well know they do not see any pathogens. There must be a better way!

Oh yea, there is, but we are just not using it because pathogen control is taking a back seat to union politics. After Jack-in-the-Box, USDA got serious about pathogens and started to make changes. In 1996 came the Hazard Analysis and Critical Control Points (HACCP) rules.

Two years later, with HACCP in place, USDA announced it would conduct a pilot program in 20 plants that would deploy inspectors differently. Inspectors would be used on and off the line. The off-line inspectors would be charged with verifications and system inspection duties, essentially taking responsibility for seeing that the plant’s HACCP was being implemented.

But all hell broke loose. The American Federation of Government Employees sued, and through the federal courts and negotiations with USDA got an agreement to prevent expansion of the pilot program (known as HIMP).

So there is has remained. A small group of plants operating outside the 1957 inspection model, generating data. The federal court said generating data was okay, as long as USDA did not go overboard and start using what they’ve learned to actually start controlling pathogens in poultry.

Well, to her great credit, USDA Under Secretary for Food Safety Elisabeth Hagen has turned what’s been learned from HIMP into a new rule for the poultry industry. Just as she did in making the six non-O157 E. coli strains adulterants, Hagen is showing courage while doing what’s best for food safety.

She says “refocused inspections” in poultry plants piloting HIMP have shown that both Salmonella and Campylobacter can be reduced. Her predecessor, Dr. Richard Raymond, says HIMP demonstrated drops in fecal material and septic birds.

Let’s see, we’ve learned a few thing about food safety since 1957. We know what works and we know how to apply those techniques. If we do so, there will be fewer illnesses and deaths. It’s pretty simple.

USDA should adopt this new rule, and get on to seeing what works and does not work on a larger scale. Clearly, the 1957 model is broken. It should have been abandoned a long, long time ago.

Like so many posts that I read about on the new proposed poultry inspection system, it is loaded with innuendos, inflammatory comments and is often just plain wrong.

But to lay the ground work for this OpEd, let’s talk about the modernization of the poultry inspection system for a few paragraphs.

First of all, the Poultry Products Inspection System was signed into law in 1957 by then-President Dwight D. Eisenhower. I was a 10-year-old boy living in Loup City, Nebraska at the time.

A lot has changed since then, but not the way the USDA inspects poultry.

One of the less obvious things that has changed is the condition of the birds we eat. Back then the intent of the law was to have federal inspectors in poultry slaughter plants looking at carcasses for things that might harm our health, like tumors, abcesses and signs of sepsis.

The birds 56 years later are much healthier and are much younger as a result of animal husbandry advances and genetics. Most of today’s broilers go to harvest between 35 and 42 days of age.

Another change is what the inspectors are looking for. As birds fly back at a maximum speed of slightly less than two seconds per bird, the inspectors are pulling birds off the line that have broken wings and drumsticks. That is correct. They are doing quality control for the profitable chicken industry.

Those things don’t make us sick; pathogens do. And you can’t see pathogens with the naked eye.

The modernized inspection system will be a copy of the HACCP-based Inspection Models Project (HIMP), something that has been in place in 20 broiler establishments for 14 years and the safety has been demonstrated repeatedly.

So, now to Mother Jones’ post and some clarification of statements made.

Quote: “That would mean there are three fewer inspectors for a production line running 25 percent faster.”

Not true. That statement, first of all assumes there are four FSIS inspectors in every chicken plant, and that just is not the case.

Secondly, it fails to explain that the birds will still be inspected for bruises and fractures, but the company will be paying for that quality control, not you and me, the tax payers.

Quote: “The department expects to save $90 million over three years by firing inspectors.”

Again, not true. The USDA’s leaders at the Food Safety and Inspection Service estimate that 1,500 full-time slaughter inspectors will get upgrades from GS7 to GS8 and be moved from on-line jobs inspecting a chicken carcass every 2 seconds, 30 every minute, 180 every hour, 1,480 every day to an off-line position in their plants.

These off-line inspectors are trained to provide verification measures such as examining the plant records, focusing on HACCP plans, drawing samples for pathogen testing and doing visual examination of the plant and its contents for sanitation issues.

Off-line inspection will not only bring better compensation, but those inspectors in the current HIMP say that the work is much more stimulating and personally rewarding.

Over the time frame of implementation, Dr. Hagen has told me that there may be a reduction of 750-800 positions, but she also has told me that “this will be done entirely through attrition without backfilling, etc.—no layoffs.”

So why the uproar about jobs anyway? Isn’t efficiency something we want more of from our government? Well, if the bargaining unit loses 800 members they lose dues and maybe a chairman.

Quote: “To control pathogens, the poultry plants would be allowed to conduct ‘online reprocessing’ — that is dousing all the bird carcasses that pass through the line, ‘whether they are contaminated or not,’ with water laced with chlorine.”

Oh My Gosh. Another attempt to inflame the consumers just like the lean finely textured beef that had been treated with ammonia for 20 years to make it safer to eat.

Guess what? This is not a new treatment to try and reduce the pathogen load. It has been routine in most large plants for years.

The article has a quote from Food and Water Watch that states the highest error rate in HIMP plants was with inspectors missing dressing defects such as feathers. Again, that is a plant quality assurance problem and not a public health concern.

About one-third of the article is about worker safety. This only serves as a distraction and is an OSHA concern, not a food safety concern. The companies can hire as many workers as they feel they need to safely fabricate these carcasses.

So many discussants try to work in the number of FSIS FTEs, the safety of the worker and the economics of the industry.

This is ALL about food safety and bringing poultry inspection into the 21st century. The rest, like saving dollars, more affordable poultry meat and who does quality control are not the issues that will affect my health as I age.

Lower Salmonella and Campylobacter contamination rates will do that. And more off-line inspectors can do just that.

Here’s hoping that as a result of all the misdirected debate, and the misinformation being distributed, the Obama Administration will not “chicken” out on its announced goals.

Now, I am the Under Secretary for Food Safety at the U.S. Department of Agriculture.  In my current role, I oversee dedicated USDA inspectors, scientists, veterinarians, and numerous other personnel who protect food that we eat every day. There is nothing more fundamental than being able to feed your own family a meal that will not make you sick, or worse, put you in the hospital.

I understand that there has been a lot of confusion about a proposal by USDA’s Food Safety and Inspection Service (FSIS) to modernize inspection at poultry slaughter plants.

I would like to try to eliminate that confusion.  

First and most importantly, we put forward this modernization proposal because we have data demonstrating that the system it embodies will prevent foodborne illnesses – approximately 5,000 per year.  It will prevent illnesses by making commonsense, scientifically verified changes in the way inspection personnel do their work in plants.

This is significant because for the past 10 years, the food safety community hasn’t been able to make any headway in the fight against two dangerous strains of bacteria that are commonly found in poultry products – Salmonella and Campylobacter. While poultry only accounts for a fraction of the illnesses attributable to Salmonella and Campylobacter, the numbers from these pathogens are still significant. Together, these two bacteria cause an approximate 344,000 poultry-associated foodborne illnesses every year.  The most troubling aspect of these data is that, despite all our efforts, rates of illness caused by these two foodborne pathogens have been stagnant, even showing occasional rises, in recent years.  

We need to find a way to reverse the trend, and if we are to do so, one thing is clear: we cannot continue regulating the poultry industry as we have.  FSIS can’t keep focusing on food quality assurance tasks – work that our food safety inspectors are currently doing – and simply cross our fingers, hoping that checking for extra feathers and bruises in chickens will make a dent in the rates of illnesses caused by Salmonella and Campylobacter.   We need all of our employees to be focused on a single purpose: to protect public health through food safety.   Our inspectors shouldn’t be doing a company’s quality assurance work.  They should be making sure that a company produces safe food.

Under our newly proposed inspection system, most inspectors who have performed quality control checks under our old system would perform food safety tasks that have been demonstrated to make your food safer, like making sure a company’s food safety plan is effective and conducting tests for the harmful pathogens which actually cause foodborne illness.

We started testing a new type of inspection system in a pilot program that began in 1999.  In these plants, Salmonella and Campylobacter contamination rates actually decreased quite quickly.  This refocused inspection works.

If we were to finalize our proposal and implement this new type of inspection system broadly, we would be enabling our employees to do more, and we as an Agency would be doing a better job, to fulfill our mission. We would still be in every poultry slaughter plant every day, inspecting every chicken that enters the food supply.  We would just be doing it better. 

I understand that in the course of this discussion, some have raised concerns for the workers in poultry plants.  They ask – if this new inspection system causes changes in the way that plants operate – will it make poultry plants more dangerous for the people who work there?

Let me be clear: USDA would never put forward a rule that would put anyone in harm’s way.  This is not a choice between food safety and worker safety.  The data that we have to date does not show any link between this new type of inspection system and increased risk for poultry industry employees or our own inspection personnel.  And as we evaluate next steps for this proposal, we are working with our federal partners to ensure that worker health isn’t harmed – and is in fact improved.

I don’t want to minimize the discussion about worker health.  We do need to have a discussion on the health of workers in the industry.  That discussion is underway.  While we as a food safety agency do not have the ability or expertise to regulate worker safety, we have been working closely with the Occupational Safety and Health Administration and the National Institute for Occupational Safety and Health on important efforts to strengthen the federal government’s data collection and enforcement activities in this space.  These two federal agencies have the regulatory authority and expertise to improve worker safety. 

As a result of these efforts – and the discussion started by this proposed rule – we as a federal government are talking about worker health in the poultry industry in a way that we never have before.

Most importantly, our data show that we can make progress in meeting our mission and ensuring a safer food supply.  We have a major tool at our disposal to reduce foodborne illness, and this is but one of many ways that USDA is working hard to keep you safe from foodborne illness.  If you had the opportunity to save a life, to spare a mother or father from the agony of having a child in the hospital, wouldn’t you jump at the chance?

“Risky Meat,” written by Sarah Klein and Caroline Smith DeWaal, ranked meat and poultry products from highest to lowest risk based upon 12 years of CDC outbreak data and over 1,700 outbreaks. Rather than merely counting illnesses, the severity of the illness was calculated using the hospitalization rate. For example, Listeria monocytogenes, with a hospitalization rate of 94 percent, was given a severity score of 0.94, while Clostridium perfringens, with a hospitalization rate of 0.6 percent, was counted at 0.006. Chicken and ground beef were most likely to cause severe illness and were classified as most risky.

Guidance on how to reduce risk is available by clicking on A CSPI Field Guide to Meat & Poultry Safety. The Consumer Fact Sheets include tips on food preparation, cooking and storage. They recommend washing hands and utensils, indicate appropriate refrigerator temperature, advise using a thermometer to tell when a safe temperature has been reached, and specify the safe time interval between cooking and serving. The Fact Sheets also correctly addresses popular myths related to the safety of locally produced food or eating at an upscale restaurant. I especially like this one: “Bacteria don’t know whether they are at a 5-star restaurant, expensive grocery store, or on a local farm-so practice ‘defensive eating’ every time.” But there is no mention that little used technologies can significantly reduce the risk of foodborne illness.

More than 10 years ago the Centers for Disease Control and Prevention (CDC) identified ground beef, poultry, and processed meat as linked to severe foodborne illness and documented that irradiating these foods would significantly reduce illness, hospitalization and death (Tauxe 2001).

While advising people to wash their hands and use a thermometer when cooking is appropriate, it is unlikely to produce a big change in behavior. When we videotaped 200 households preparing burgers in their homes, we found less than half washed their hands before beginning to cook, only 40 percent of hand washing events involved soap, 32 percent did not wash their hands between touching raw meat and preparing a salad, and only 4 percent used a thermometer to tell when their meat was done (Phang and Bruhn 2011). Amazingly, there was no difference in behavior between those who reported having had food safety training and those without training.

Irradiation is not magical. It doesn’t protect us from prions which lead to Bovine Spongiform Encephalopathy (Mad Cow Disease) and it doesn’t knock out norovirus. People must use proper sanitation, but irradiation can destroy 99.999 percent of E coli O157:H7 in burgers and 99.9 percent of Salmonella in chicken, and it inactivates other pathogens as well (Sommers and Fan 2011). Because the pathogens are destroyed before they enter the home or commercial kitchen, illness due to cross-contamination is reduced. High pressure processing (HHP) can protect packaged deli meats from Listeria and raw oysters from Vibrio (Black, Stewart et al. 2011). Doesn’t it make sense for industry to use the best methods that effectively destroy pathogens and for health educators to advise consumers to select these products?

If we really want to reduce foodborne illness, relying on the consumer to do everything right is unlikely to be effective. While people must take personal responsibility, the food industry needs to provide a product that has the highest level of safety possible.

Technologies currently available, like irradiation and high pressure processing, can provide a level of safety unavailable elsewhere. Food Safety News’ review of irradiation affirmed that irradiation offers significant food safety advantages (Prakash 2010). The meat and poultry industry should offer safety-enhanced irradiated and HHP processed meats, the food service industry should select them, and supermarkets should offer these products to the consumer. A serious commitment to reduce foodborne illness should include a recommendation to select irradiated meat and poultry and HHP products.

Works Cited

Black, E. P., C. M. Stewart and D. G. Hoover (2011). Microbiological Aspects of High-Pressure Food Processing. Nonthermal Processing Technologis for Food. G. V. B.-C. Howard Q. Zhang, V.M. Balasubramaniam, C. P. Dunne, Daniel F. Farkas, and James T.C. Yuan, Wiley-blackwell: 51-71.

Phang, H. S. and C. M. Bruhn (2011). “Burger preparation: What consumers say and do in their home.” J. Food Protection 74(10): 1708-1716.

Prakash, A. (2010) “Is Food Irradiation the Future? Part II.” Food Safety News, July 12.

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The Humane Society of the United States, PETA and other organizations that want us to stop slaughtering animals for human consumption keep the videos and headlines coming, and we are making their task just too easy.

Many of these cull cows are spent dairy cows as was the case at Westland/Hallmark and most recently at Central Valley Meat Co.

The cow may be well over 10 years of age, 10 years that were spent basically eating and being milked without much physical conditioning present and now she is becoming lame, or producing less milk, or showing signs of deterioration of her health in some other fashion.

When an older cow has reached this point in her life, her owner may have her transported to a sale barn to be auctioned off. Following that she is reloaded onto another truck and transported to a slaughter plant and placed in a holding pen until the FSIS public health veterinarian can observe her in motion and at rest.

And then she must be able to walk to the knock box on her own legs and of her own free will. But she just may not be able and willing after all of this commotion.

The transporting may take place during inclement weather and cover hundreds of miles, and all this time the cow goes without being milked if still lactating.

No wonder some of them just lie down and refuse to get back up—they are weakened from their journey, they are old and tired, and they may be just plain miserable.

One might think that it is only logical to not send a lactating cow to market, but the cost of grain to feed a cow while going dry and administering antibiotics in the udder to prevent mastitis present a quandary of how best to handle the situation from an economic standpoint.

It used to be, after the first case of Mad Cow was found in Washington State and the Interim Final Rule was written to protect us from consuming the BSE prions, that if a cow had been observed in motion and at rest and passed by the vet and then refused to get up, the vet could return to the pen to examine her.

If a valid cause, such as a fractured leg or ruptured tendon, was found for becoming what is known as a “downer cow”, she could be humanely euthanized on the spot, labeled U.S. Suspect, and then taken to the facility for further fabrication and examination.

That rule changed after Westland/Hallmark when Secretary Vilsack declared all downer cows banned from the food supply.

In some cases perfectly good meat now is going to waste, which adds to the conundrum of what to do with cull cows.

These are high risk cows for becoming downers, but they are still a commodity with a price tag.

And they present the anti-meat groups with plenty of ammunition to try and portray an industry as being cruel and inhumane.

I suggest to the readers that it just might be cruel and inhumane to send a cow that is still lactating to the auction block and all that that entails.

It might also be cruel and inhumane to send a very old but dry cow on her final journey to the slaughter house if she is too weak and feeble to make the trip.

And it certainly is a very bad public relations move to do any of the above, enabling damning undercover footage to be filmed.

I believe the dairy industry must do a better job of evaluating which cows to send to slaughter and which ones to euthanize and send to rendering.

The industry could help its image by consistently following the 10 best practices for culling and transporting dairy cows to packing facilities as written by the National Milk Producers Federation after the Westland/Hallmark incident.

It would not only be the humane thing to do, it would be the politically correct thing to do.

But this is not just about the dairy industry. Once the cow leaves the dairy farm, someone else is responsible for feeding and watering that animal. They need to be held accountable as well.

The bottom line is pretty simple. If a cull cow is too weak to walk, there is no way to make her get up and go.

Just like there is no way to make the public forget those awful videos we have watched of people trying to do just that—make the cows get up and go against all odds.

According to the CDC, at least 73 people fell ill with Salmonella serotype Saintpaul infections between January and April of this year after eating cucumbers.  On April 24, the U.S. Food and Drug Administration placed two Mexican import firms on an “import alert,” stating that cucumbers from the farms would be denied admission into the U.S. unless the suppliers were able to prove the produce was free of Salmonella.

People started falling ill with Salmonella infections before the Sequester, so there’s no question that these cucumbers made it into our food supply even before cuts to food inspection.  When the funding cuts are in full effect, will we see even more outbreaks from both imported and home-grown food?

I shudder at the thought of what these cuts will truly mean in terms of the safety of our food supply.

The USDA’s Microbiological Data Program (MDP), which used to conduct 80 percent of all federal produce testing for pathogenic bacteria, officially shut down on December 31, 2012.

Would MDP have discovered contamination on cucumbers before they got to market? 

We may never know—and we may think of cucumbers as fairly benign since they’re not linked to food safety problems as often as leafy greens or melons, but this outbreak demonstrates that all fresh produce poses a food safety threat and cuts to federal programs may already be having an impact.