There are many arguments, pro and con, about efforts of the U.S. Department of Agriculture’s Food Safety and Inspection Service (FSIS) to renovate its meat processing inspection process. In my last editorial, I outlined the origin and pitfalls of FSIS’ proposal to extend the decade-old HACCP Inspection Models Project (HIMP) pilot program into plants nationwide. The debate on HIMP has a variety of perspectives. The discussion may twist and turn, but for those who work in the business, it’s always about line speed. Even with massive poultry recalls, foodborne illness outbreaks, and compromises in worker safety, FSIS intends to allow further increases in line speeds. The 175 birds-per-minute proposed line speed more than doubles the current standard of 70 birds per minute under Streamlined Inspection System regulations. I entered the FSIS inspection workforce in 1986, shortly after the introduction of the Streamlined Inspection System in poultry inspection. I also worked in beef slaughter inspection where the line speed had recently increased. It was readily apparent to me that high line speeds increase inspector error, increase the impact of contamination through process problems, and contribute to worker injury for those working the processing lines. FSIS intends to allow plants to essentially double their line speed with respect to the current regulated rate of inspection. To understand the negative impact of this serious breakdown in regulatory influence, one should look at the run up to where we are today. When I came on board with FSIS, plants were allowed to “reprocess” carcasses contaminated with feces and digestive tract contents. Prior to that, plants had to prevent contamination by fecal material. Evisceration processes under Streamlined Inspection routinely operated at significant rates of contamination. Contamination rates of  20 or 30 percent and higher were not uncommon. I immediately learned that the remedy for high rates of contamination was to decrease the line speed. This would sometimes happen through FSIS control of the line speed, and, at other times, occurred due to plant processes not being able to keep up with widespread contamination and disease conditions. Plants were allowed to recondition contaminated carcasses at an off-line location by rinsing the contamination off with chlorinated water. It was an almost daily event for the off-line reprocessing station to become overwhelmed with a high volume of FSIS-retained carcasses. This would often trigger line-speed reductions or complete halting of the slaughter process for the reprocessing work to “catch up.” The high rates of contamination were typically related to a combination of causes. First, poultry growers would sometimes delay the withdrawal of feed from live chickens to sustain a desired live weight. This was done to maximize the financial return on the weight of their flocks. Second, mechanized processing would sometimes not be able to “properly synchronize” with carcasses during the evisceration process, causing digestive tract contents to be damaged, and a resulting contamination of carcasses. Third, plant workers, who were unable to sustain their manipulation of carcasses at sustained and tedious line speeds, would damage the digestive tract tissue, causing contamination of carcasses. The sustained processing errors that contaminate carcasses cause on-line inspectors to become fixated and overwhelmed with errors so that individual inspection decisions become less accurate, further impeding the process of passing carcasses that are free of disease conditions and/or contamination. Remember, this commonly happens at the current line speeds. Under HIMP, plant employees would suffer the same mental and physical impairments, exacerbated by further increases in line speed. Unlike FSIS inspectors, plant “sorters” in the HIMP pilot plants are under pressure from their production supervisors to do whatever it takes to maintain the maximum rate of production. To address this matter of continuous contamination of carcasses, FSIS directed inspectors to pass contaminated carcasses and allow an “online reprocessing” step to neutralize pathogenic bacterial contamination. In other words, fecal contamination is spread and theoretically sanitized in the anti-microbial intervention process. These systems introduce a rinse with an anti-microbial treatment such as Tri-Sodium Phosphate or Acidified Sodium Chlorite. The result is sustained line speeds and more profitable production yields. Judging by recent findings by Consumer Reports of high levels of Salmonella contamination at the consumer level, this profit comes at a cost to consumers who are sometimes sickened by poultry products. The Hazard Analysis Critical Control Points law, in the form of Federal Regulation 9 CFR 417.6 (e) states that a plant’s HACCP plan is determined to be inadequate if, “Adulterated product is produced or shipped.” While FSIS, the industry, and consumer groups wrangle as to whether Salmonella should or should not be considered an “adulterant,” the findings by Consumer Reports demonstrates that poultry at the consumer level is contaminated with pathogenic bacteria. And it’s not just Salmonella. Campylobacter, Klebsiella pneumoniae, and Staphylococcus aureus were found in poultry identified in the aforementioned Consumer Reports article. It is my opinion that historic increases in line speed have had a significant negative impact on the FSIS inspection process. It is also my assertion that the HIMP will significantly worsen problems of consumer and plant worker safety. There comes a time to introduce pragmatism into the discussion of the point where profitability and safety cross. While I fully accept the reality of the industry’s need to cut costs and make processing more profitable, it must be balanced within the scope of consumer safety and product viability. Drastic increases in line speeds will enhance neither. This is the reality that any practical discussion of government inspection modification must accept.

  • tallen2007

    Thank you for taking the time to post this. It should be clearly enough explained for everyone to understand!

  • Kenny Underwood

    As a 37 year veteran of FSIS which began under traditional inspection with line speeds of 54 birds per minute I concur with everything in the article. In the beginning of my career, fecal contamination was trimmed off, then came reprocessing off line, then on line reprocessing with speeds up to 140 birds per minute. At each change, whether is was SIS, NELS, or Maestro, each of which was designed to reduce the number of inspectors and at the same time increase line speeds there was an increase in fecal contamination. But the important thing is the poultry industry is making billions.

    • Brad Baker (BB)

      Good to see you over here Kenny. You may not remember me, but you trained me several years ago when I first became a CSI. I agree with you and everything in this article.

      • Kenny Underwood

        Good to hear from you Brad. I do remember you well.

  • Foster Leaf

    I agree that increasing line speed results in increasing product contamination. I too was around in the early 1980s and you ignore one important fact. Government, not industry, created the problems you describe. FSIS came to industry with offers of increased line speeds when FSIS wanted to implement SIS, NELS, and NTIS. FSIS came to industry with offers of increased line speeds when FSIS wanted to introduce HIMP. Now FSIS is offering industry increased line speeds as part of its New Poultry Inspection System and Salmonella Improvement Plan. So why does FSIS make these offers? FSIS will tell you that it is all about food safety, but that is not true. Over the last four decades, Congress has not funded FSIS to continue business as usual and poultry inspection is the largest consumer of FSIS inspection resources. All of these new poultry inspection initiatives are FSIS responses to decreasing inspection resources, not industry attempts to increase profits at consumer expense.

    • Alvin Sewell

      I have 18 years of war stories of how FSIS spends more time in lock step with industry marching orders rather than it’s “alleged” consumer protection role. It is, in fact, a charade. I was a hard line consumer safety proponent as an inspector, from the time I was a GS-5 to GS-9 IIC functions. I paid a price for my insurrections of holding the line on regulatory matters. I am proud of the enforcement actions that I was involved with; whistleblowing to OSHA on FSIS employee safety issues; telling the truth to the public at the expense of my personal welfare; and framed a letter of caution as a badge of honor when a corrupt IIC ordered me to ignore sanitation problems in a filthy plant. That plant, by the way, was leveled to the ground when the new owners realized it was a rust and roach factory and not a viable facility. FSIS did no one a favor by discouraging enforcement and improvements in facility improvements. Plant employees were laid off, growers were shut out, and the consumer was let down. This is the problem. FSIS is NOT doing the industry any favors by letting contaminated product to reach the consumer. They are NOT doing human resources any favor by facilitating line speeds that will injure employees at a higher rate. They ARE not doing the industry any favor by lowering standards that make U.S. meat and poultry less competitive in a growing world market. Anyone who has worked hard to protect the consumer has witnessed what happens when FSIS lowers the standards. In the short term, everyone is happy, but in the long run it gives way to negative effects across the whole range of issues. I used to tell plant managers in large and small facilities, “If you are concerned with meeting the FSIS standard, you’ve set the bar too low”.

      • Your words are absolute truth and your actions throughout your history of employment, I suspect, are admirable, commendable and rare.

  • John Munsell

    Alvin, you mentioned above “To address the matter of continuous contamination of carcasses, FSIS directed inspectors to pass contaminated carcasses and allow an online reprocessing step to netrualize pathogenic bacterial contamination”, which you identified in your next paragraph as a rinse. Alvin, as the slaughter production day goes on, and continuing loads of pathogens bombard the rinse, just how unsanitary and unsafe must that rinse become? I’ve always referred to it as a pathogen soup, and no one has disagreed. I’m disappointed I always had a beef plant, not a poultry plant. Why? Because FSIS doesn’t allow small slaughter plants to rinse contaminants such as hair and fecal off of beef carcasses. At least at small plants, every little hair or speck of anything must be hand-trimmed off. I suggested to agency authorities that they allow us to rinse such things off, only to be told that regulations prohibit it. Ironic ain’t it, how poultry can be “sanitized” via a rinse, even though the pathogen load on chickens is very high. Apparently pathogens dervied from poultry don’t sicken consumers, but beef-sourced pathogens do. Ahhh, the beauty of the agency’s robust “science-based” inspection system, which is no longer focused on meat inspection, but on paperwork auditing. Thanks for your insight, which is common sense, guaranteeing that FSIS will summarily dismiss your opinions. John Munsell

  • flameforjustice

    Thankfully I don’t eat any animal flesh but I’m still very much concerned because I have family members and others I care about who eat animal flesh. Just knowing that other human beings especially children in the USA are being sold and/or fed this germ laden, potentially life threatening filth is disgraceful and most of all frightening.

  • Consumer

    I am curious what steps are proposed by FSIS to increase surveillence of the pathogens. Do they propose increased FSIS verification testing, heightened performance standards, or increased off-line verification checks for quality defects (economic adulteration of scabs, feathers, bruised meat, etc.)? All I hear about is decreased on-line carcass inspection and increased line speeds. How does FSIS support that these two steps will lower incidents of food borne illness? I see where the inspectors are being removed, but I don’t see where inspection is being increased. The “reallocation of resources” would suggest that more inspection will be implemented elsewhere in the process, but it appears to be just a “reduction of resources”. By the way, has Elizabeth Hagen gotten her consulting position yet with the Natioanl Broiler Council?

  • Unfortunately, what you suggest is no where near the way the system works. There are no “surprise” reviews at all. Landscaping and janitorial workers are often handed knives and placed on the line for inspection time to increase the numbers in the line worker ranks. The slaughterhouse owner only has to call their congressional representatives and complain about a Veterinary Inspector to get them reassigned or removed, for costing them too much money with correct regulatory practices. The system is and has been entirely corrupt for quite some time and the only thing that forces a recall is a story on the evening news. Profits rule and accountability be damned, says the owner driving his Bentley away from the stink hole he calls a “food plant.”