The current volley of documents and letters, concerning line speed and worker safety, is telling. It shows us volumes about the push for the HACCP Based Models Project (HIMP) into law. It also shows the urgency of ramming HIMP into place on a timeline that does not have room for dissent nor discussion. In the CQ Congressional Transcripts of the House Appropriations Subcommittee meeting on the Fiscal 2015 Budget for Food Safety1, the meeting minutes indicated just how chaotic the process for HIMP implementation has become. In the opening statement, Congressman Robert Aderholt said, “As we discuss various FSIS rules and regulations, let me be clear about one thing. America is blessed to have the safest food supply in the world. When false accusations and misinformation enters the media and the public domain, it is a disservice to America’s farmers, ranchers and consumers. Sound science should always guide food safety and the decisions that follow.” Misinformation? From where? Could it be the misinformation from FSIS on worker safety? The Food Safety News article of April 10, 2014, “NIOSH Director Says FSIS Administrator Misinterpreted Line-Speed Study2”. The article states, “Line speed affects the periodicity of repetitive and forceful movements, which are key causes of musculoskeletal disorders.” Or could Congressman Aderholt be referring to the misinformation on basing claims of decreased salmonella rates under HIMP, contradicting FSIS’ own data on HIMP vs. Non-HIMP comparison plants? Or is Congressman Aderholt referencing a GAO report that states, “GAO identified weaknesses including that training of plant personnel assuming sorting responsibilities on the slaughter line is not required or standardized and that faster line speeds allowed under the pilot projects raise concerns about food safety and worker safety.” It would seem that the misinformation that is circulating surrounding the Food Safety Modernization Act is coming from the entities that are charged with legitimizing it. This is a disservice to the consumers and industry workers, who Congressman Aderholt claims to represent. This is not science. It’s politics. One reality is that a faster line speed does change the task and the health parameters. Take, for instance, an inspector or plant sorter task. When the Streamlined Inspection System (SIS) at 70 birds per minute was enhanced by the New Line Speed Inspection System (NELS) at 91 birds per minute, the task changed. While an additional inspector was added to each line, there is an anomaly that was readily noticed by workers. Each carcass arrives at a given work speed traveling at a higher relative motion. In other words, the carcasses per minute or hour may lower somewhat, but the motion is at a higher rate as it passes each worker. This requires faster and higher impact work per carcass. This would be true of any task on the line. The movement of each carcass is faster and the time to complete a task is shorter. This translates into increased physical and psychological stress. A horrific illustration of this was in a plant where I was assigned went from SIS to NELS. A line worker who harvested chicken livers got her thumbs trapped in the shackles and was dragged off of her work stand, hung from the moving line, and fell to the floor while her thumbs remained in the shackles. This all happened before anyone could stop the line. Consider this. The Letter to Food Safety Inspection Service NIOSH Health Hazard Evaluation at a South Carolina Poultry Plant, 2014, states, “In its evaluation of the plant before any production line speed changes had occurred, NIOSH investigators found an alarming 42% prevalence of carpal tunnel syndrome (CTS) in exposed workers. The CTS risk, confirmed by a nerve conduction study, was not unexpected considering the repetitive and forceful motions required by exposed workers to process poultry.” The letter further states,  “NIOSH also found that most of its 31 recommendations, including NIOSH’s primary recommendation to redesign the jobs to reduce the risk of CTS due to forceful and repetitive motions, and to address the alarming prevalence of CTS found on its first visit, had not been implemented” (emphasis added). This is a telling statement. It would seem that worker safety is not on the front burner or even a serious consideration when it comes to “modernization.” It would also seem that if the proposed system does not meet or exceed the current standard, that is considered “modernization.” From Table 3-12 Salmonella Percent Positive Rates for HIMP and Non-HIMP Broiler Establishments: 2010 statistics show there was a higher rate of salmonella positive findings in HIMP Broiler plants vs. Non-HIMP Comparison Establishments. Back to the issue of worker safety: Did anyone else take notice of the conspicuous low numbers of “Other” in the race breakdown of the NIOSH report? On page 9, Table 2, Demographic and personal characteristics of questionnaire participants: 13 classified as “White,” 298 classified as “Black or African American,” and 7 classified as “Other.” I question this cross section as measured against the industry demographic of workers. Are plant workers’ injuries, including those of minorities and migrant workers “acceptable”? Is worker injury an acceptable loss as measured against profitability as enhanced by the higher line speed? Why do I make this point? Poor and migrant workers may be less assertive about reporting injuries. Workers in these categories need to work and may be more tolerant of injuries. They may have fewer options for seeking medical help. They may also be in a communication vacuum where they do not fully understand their rights and options. This is my opinion, based on 15 years of observation, working in over 30 different plants, large and small. There are hard and ugly issues within these discussions. They are being held in an arena of suits, politics, and money. There are human lives at stake. The lives of plant workers, consumers, and their families are subject to the fallout of poor decision making, based on questionable evidence. All parties that are glossing over these reports identifying problems with inspection and line speed changes must stop using the word “science”. As far as Congressman Aderholt’s claims of “misinformation”, he needs to reword his wording to “agenda distractions.” This process is severely flawed and is no where near an authentic discussion of problem solving. Every grievance I filed; every whistle I blew, every call for help was always, always aimed toward finding a solution. On more than a few occasions my efforts were successful. In the aforementioned Congressional Transcript, Congresswoman Rosa DeLauro states, And that’s why 68 of us — 67 of us — and 68 with myself asked to withdraw this rule because we are not dealing with a robust database on which to try to move forward in terms of where risk is and how you determine where you’d go based on risk. As my colleague in FSIS, Don Mussachio used to say, “So what, now what?” This process is long overdue for an overhaul. All stakeholders need to drop their cognitive dissonance and fix this broken model. 1. Congressional Hearings April 3, 2014 – Final House Appropriations Subcommittee on Agriculture, Rural Development, Food and Drug Administration and Related Agencies Holds Hearing on President Obama’s Fiscal 2015 Budget for Food Safety –  Attached 2. NIOSH Director Says FSIS Administrator Misinterpreted Line-Speed Study