The guest op-ed piece by former UDSA Under Secretary for Food Safety Richard Raymond entitled, “Can We Talk Turkey?” had some factual errors that need to be addressed, along with some pieces of information that readers need to have in order to put some of the issues he raised into proper perspective. 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,”, January 20, 2012 (see (3)  See (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 (7)  Southern Poverty Law Center.  “Unsafe at These Speeds:  Alabama’s Poultry Industry and its Disposable Workers,” March 2013 (see (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 (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