I recently retired from the Office of Policy and Program Development (OPPD) at the Food Safety Inspection Service (FSIS) after more than 30 years with the U.S. Department of Agriculture. For what it’s worth, I’d like to share my thoughts on FSIS culture and six issues that represent significant investments of my time and energy. I took the oath of office on a Monday and reported for work the next morning. As a veterinarian, my first assignment was as Supervisory Veterinary Medical Officer (SVMO) at a small swine slaughter facility. I spent my first weeks with other veterinarians learning slaughter inspection and sanitation. I learned command and control from their actions and statements. Industry was the enemy, and my job was to protect the consumer from industry. I learned management by avoidance from my first supervisor, who repeatedly told me to avoid actions that might cause inspector or establishment complaints to the Area Office. He also told me that helping me solve my problems was not his job. My first assignment left me unprepared for my second assignment as SVMO at a large livestock slaughter and processing establishment. The vacancy in the Circuit Supervisor position did not help. Between the company’s corporate support structure and the FSIS inspector’s union, I was repeatedly chewed up and spit out that first year. The job was not fun. About this time, the Area Office sent me to training in Fort Worth, TX. The curriculum ignored the practical reality of command and control and management by avoidance that I experienced in the field. Deliverance came later that year in the form of Dr. H., the best mentor I ever had. He taught me how to be hard on problems and soft on people. The job became enjoyable. Five years later, I earned a promotion in a location where my wife and I chose to remain. Twenty-four years later, I am retired. I’d like to share my thoughts on six issues that occupied my time and energy at FSIS, as well as my grade for how well FSIS handles them:
- I give FSIS a B for its training programs. Moving the training center to Texas A&M, increasing the scholastic standards for training courses, and standardizing field training significantly improved training. The current training program is even better. New-hire veterinarians no longer arrive at their first assignment unprepared and alone. The absence of sustaining support from OPPD in Omaha prevents a higher grade. The previous Office of Field Operations (OFO), Technical Service Center (TSC) operation engaged in critical thinking and problem-solving in partnership with field employees. The current OPPD operation does not. Solving problems is not their job.
- I give FSIS a D for data collection. FSIS does not collect data with improvement in mind. The Public Health Information System and its predecessors, the Performance Based Inspection System and Inspection System Work Plan, are little more than scheduling tools. They document the quantity of work performed, but nothing about its quality or effect. FSIS abandoned its Public Health Human Resources System, another data-driven initiative, after managers failed to implement the system as designed and deliver the increased performance sought. Right now, FSIS struggles with the fact that its data-collection efforts cannot validate its strategic plan.
- I give FSIS an A for its residue program. When I joined FSIS, residue testing was a passive activity, in-plant testing nonexistent, SVMO-generated samples rare, and carcass condemnation rarer. Today, SVMOs proactively retain and test suspect carcasses. Carcass condemnation for a residue violation is common. No other FSIS program is as successful at finding and eliminating adulterated product. The credit belongs not to FSIS, but to Dr. S., an FSIS SVMO whose curiosity led him to prove that the existing residue program failed to identify residue violations in dairy cattle.
- I give FSIS a C for its humane slaughter program. When I joined FSIS, there was no District Veterinary Medical Specialist and humane slaughter was a non-issue. Today, humane slaughter is a front-page concern. Unfortunately, fear of unfavorable press, not the intent of Congress, drives the FSIS humane-handling agenda, which allows the animal-rights movement to co-opt FSIS. The best evidence of co-opting is the FSIS extra-legal attempt to create the perception of inhumane slaughter of poultry where it does not exist.
- I give FSIS a C for its pathogen-control programs. The 1993 E. coli O157:H7 outbreak was a kick in the pants for FSIS, and it responded commendably. FSIS declared the microorganism a “poisonous or deleterious substance.” It required safe-handling statements on raw meat products. It elevated standards for determinations that E. coli O157:H7 was not a food safety hazard reasonably likely to occur. It introduced product verification testing. The policies for Listeria monocytogenes in RTE products were a logical next step. FSIS deserves no commendation, however, for its Salmonella policies. In 1974, FSIS successfully argued in federal court that Salmonella does not adulterate raw poultry. In 2001, again in federal court, FSIS unsuccessfully argued that Salmonella does adulterate raw meat. No one wants Salmonella on raw meat and poultry products. However, attempting to regulate Salmonella as a food safety hazard is as fruitless as pounding square pegs in round holes. Even worse, expending resources to perpetuate the public perception of a regulatory Salmonella performance standard – which does not exist – is bad stewardship of appropriated funds.
- I give FSIS a C for its implementation of Hazard Analysis and Critical Control Point (HACCP). The sanitation and HACCP regulations in 9 CFR 416 and 417 are the most significant change to meat and poultry inspection since the Wholesome Meat and Poultry Products Acts. FSIS called HACCP a “paradigm shift” in the FSIS approach to inspection and declared “command and control’ dead. The battle cry from the OFO, TSC, which implemented HACCP, was “let the system work.” It was an exciting time, a potential renaissance. FSIS made progress and credit is due, but the paradigm did not shift. Command and control did not die. FSIS simply replaced the strong-arm dictatorship of the Inspector in Charge with the bureaucratic tyranny of the policy-maker. Offering waivers to establishments that promise to do your bidding is subornation, not experimentation. Threatening public disclosure of opinions called Memorandums of Interview is intimidation, not enforcement.
Ask FSIS why it exists and you hear about Upton Sinclair’s novel, “The Jungle,” and how USDA inspectors protected the consumer from the meat-packing industry. That same 1905 command-and-control culture is alive and well in 2014. To abandon command and control, to allow the system to work, suggests that a policeman is no longer necessary. Perpetuating the perception of a “bad guy” serves FSIS interests, not public interests. I do not know when or where the culture of management by avoidance originated, but it, too, is alive and well. Fecal Soup, Jack in the Box, AgriProcessors and Hallmark are all evidence of avoidance to act until after third parties made public what FSIS previously ignored. A reliance on product verification testing evidences avoidance to apply its own inspection processes, the HACCP principles FSIS requires of industry. Managerial avoidance also exists. I have witnessed FSIS managers exclude employees from productive work because it is easier to avoid a dissenting opinion than to consider it. Beginning in May 2013, I watched FSIS pay a co-worker to stay home and do nothing because it is easier to hide management failures than admit them and easier to avoid individuals than deal with them. Her sole responsibility is to call in each morning and ask if the director has any work for her to do. To date, no work has been assigned. FSIS serves a useful public purpose, and I do not regret 30-plus years invested in that purpose. I will miss the people, but not the process. A lot changed in 30 years, but some important things did not.
