“There is something fascinating about science.  One gets such wholesale returns of conjecture out of such a trifling investment of fact.”  — Mark Twain

If only Mark Twain were alive today, he would have a field day commenting on what the U.S. Department of Agriculture considers to be “scientific”.  

Subsequent to the Jack In The Box E. coli outbreak in 1993, USDA desperately and hurriedly implemented the current Hazard Analysis Critical Control Point (HACCP) protocol of deregulated meat inspection.  HACCP was originally invented by Pillsbury, focused on the production of consistently safe food for NASA and the Army.  Pillsbury’s HACCP required “Kill Steps” during food production, meaning that the food had to be subjected to a kill step such as fully cooking or irradiation, effectively killing all pathogens.  Pillsbury’s HACCP system was truly based in science, and creates safe food.

USDA intentionally changed the Pillsbury protocol, but of course, retained the right to classify its HACCP imposter as allegedly being “science-based”.  USDA’s Food Safety and Inspection Service (FSIS) demands that all federally inspected plants implement USDA-style HACCP.  Thus, FSIS requires that HACCP be used for all raw meat and poultry, which by definition does not utilize kill steps, but still qualifies for USDA-style HACCP.

Raw meat and poultry carry pathogens, such as E. coli and Salmonella.  These enteric bacteria originate in animals’ intestines, and can easily be deposited onto dressed carcasses via sloppy kill floor dressing procedures.  FSIS knowingly allows such enteric bacteria to be shipped into commerce from the source-originating slaughter plants.  The agency’s endorsement of shipping E. coli O157:H7 to downstream further processing plants, retail meat markets, and restaurants is an interesting case study.

A high percentage of beef shipped into commerce from slaughter plants is in the form of vacuum-packed intact cuts of meat, known as boxed beef.  FSIS allows such intact cuts, which are surface contaminated with E. coli O157:H7, to be shipped from the source slaughter plants to downstream further processing establishments.  FSIS blithely dismisses E. coli to be a mere contaminant when found on the surface of intact cuts.  However, when the downstream processor such as retail meat markets and restaurants process the intact cuts into steaks, roasts and ground beef which is laced with the previously-existing E. coli, FSIS nonchalantly concludes that the heretofore harmless E. coli have supernaturally morphed into adulterants.  FSIS places all blame for the existence of these pathogens on the downstream entity, accusing them of being noncompliant with sanitary food processing protocol.  

How did this absurd turn of events occur?  To answer this, we must briefly review statements made by FSIS in the 1990s as it tortured its definition of “science” in order to implement the agency’s pre-determined meat inspection system desired by FSIS.

In a series of meat industry conferences to publicly discuss USDA-style HACCP in the 1990s, FSIS stated that the agency’s role would change under HACCP to include the following:

1.  Under HACCP, the agency’s role would become “hands off“, instead of the traditional “hands on” role FSIS had previously embraced.

2.  Under HACCP, the agency would no longer police the industry, but the industry would police itself.

3.  Under HACCP, the agency would disband its previous command and control authority.

4.  Under HACCP, each plant could write its own HACCP Plan, and that the agency could not dictate what must be in these individually customized HACCP Plans.

History has shown that FSIS is fully compliant with these four pre-HACCP promises, but only at the largest plants which enjoy political clout and deep pockets.  Conversely, FSIS has used HACCP to hyper-regulate and hagride small plants, a startling number of which have exited USDA inspection.

One advantage HACCP gifted to FSIS was insulating the agency from liability for pathogens and outbreaks.  How could the agency be held even partially responsible for pathogens in the food supply when the agency was limited to a “hands off” non-involvement role, could no longer police the industry, and no longer enjoyed command and control authority?  FSIS can’t be responsible for meat it never inspected!  Another advantage is the comfort granted to the agency to embrace a semi-retired stance at the big packers, greatly reducing the delicate discomfort involved in challenging the largest plants when problems arise.  FSIS remains unaware of recurring problems, because it is relieved of its previous hands on policing role, coupled with loss of command and control authority.

During these afore-mentioned industry conferences, the agency made continuous references to the fact that USDA-style HACCP is “science based“, which allegedly would diminish the shipment of pathogens into commerce.  When conference attendees pressed FSIS spokespeople to explain why USDA-style HACCP is based in science, the agency explained that microbiological testing would be an integral part of HACCP.  FSIS spokespeople explained that HACCP would require extensive testing both by the agency, and by the meat plants.  In the 56 years my plant had operated prior to HACCP, I had never collected one meat sample for microbial analysis.  After HACCP’s implementation, both the agency and I have collected multiple dozens of samples for microbial tests.  Testing became the heart and soul of USDA-style HACCP.  

On January 26, 1998, the largest packing plants implemented HACCP.  A mere six days later, on February 1, 1998, FSIS issued Directive 10,010.1 which essentially exempted the large plants from agency-conducted microbial testing.  Plants killing thousands of beef daily became off-limits for FSIS sampling.  Meanwhile, the agency continued to test at smaller plants.  FSIS bureaucrats thus define “science” differently at small plants, compared to large plants.  What was the natural consequence of exempting large plants from USDA testing?

A superlative example of the impact of exempting large plants from agency-conducted sampling was exposed during the 19.1 million pound recall of E. coli-contaminated meat from the ConAgra plant in Greeley, Colorado in June 2002.  Exempted from agency-conducted sampling, ConAgra implemented a “multiple hurdle pathogen intervention system” which ostensibly “virtually sterilized carcasses”, as printed in a ConAgra marketing brochure.  Subsequent to the 19.1 million pound recall, the Office of the Inspector General (OIG) investigated the circumstances surrounding the recall.  One quote from OIG’s scathing report is, “Data was available to both ConAgra and USDA in the period prior to the recall that indicated that E. coli contamination was becoming a CONTINUOUS (emphasis added) problem at ConAgra.”   Instead of virtually sterilizing carcasses, ConAgra was continuously contaminating carcasses.  In the 100 days prior to the recall, ConAgra’s in-house testing revealed the presence of E. coli in meat on 34 of those days.  However, ConAgra did not implement corrective actions to prevent recurrences, and USDA did not mandate corrective actions, having been relegated to a “Hands Off” role absent command and control.

When critics reveal these glaring and intentional oversights, FSIS responds by stating that USDA-style HACCP is based in “science”.  Therefore, anyone revealing problems with USDA-style HACCP is discredited as being opposed to scientific advancements.  No one wants to be classified as opposed to science.  FSIS uses this lame excuse as an opportunity to silence all its critics, since who can argue with science? &nbsp

Whenever any USDA official claims that agency policies are science-based, red flags should go up everywhere.  While the agency piously proclaims that its policies utilize an “abundance of caution”, evidence continues to reveal the agency operates under an “abandance” of caution, while hiding behind USDA-style HACCP’s skirt.  The agency’s slovenly recumbent lack of oversight at large plants is justified by its desire to maintain a “hands off” meat non-inspection role, its unwillingness to police the industry, and abhorrence at the prospect of using command and control authority at the largest slaughter entities.  The Big 4 meat slaughter companies kill 88 percent of our feedlot cattle, constituting a substantial adversary to an agency–which is paralyzed by the fear of litigation from the Big 4.  

“Science” to FSIS means agency semi-retirement at the largest slaughter entities.  This is a primary reason for our ongoing outbreaks and recurring recalls.  History has proven that USDA-style HACCP is NOT science-based, but based in political science and science fiction.  This is precisely the problem to which Mark Twain referred by extracting wholesale conjectures from a small investment of fact.  USDA intentionally bastardized Pillsbury’s HACCP program, while disingenuously classifying the agency’s deregulated system of non-inspection as “science-based”.  Consumers continue to pay the price for such sleight of hand.  

Oh what a twisted web we weave, when at first we intend to deceive.