The USDA’s Food Safety and Inspection Service’s new regulatory system for market hogs is a direct descendant of the food safety reforms first put in place after the Jack-in-the-Box tragedy 25 years ago.
FSIS made it official Tuesday by sending the “final rule” to the publisher of the Federal Register. It was approved Friday by the White House’s Office of Management and Budget (OMB).
Mindy Brashears, USDA’s deputy undersecretary for food safety, believes the New Swine Inspection System (NSIS) is another food safety improvement with a long ancestry.
“This is the next phase of our HACCP implementation,” says the former Texas Tech University food safety professor.
Brashears predicts 30-to-35 swine slaughter plants will fairly quickly opt-in to the NSIS. Most will be larger establishments. The change frees up FSIS personnel from sorting duties, giving them more time for “offline” inspections for enforcement of hazard and sanitation plans.
Brashears also thinks the change up testing requirements also only makes sense. With the NSIS, generic E.coli testing ends, but sampling for microbial organisms is required. And, FSIS will decide where sampling occurs.
Like the pre-2011 caucus testing for Salmonella, the generic E. coli testing produces uniformly low results. Brashears says such flatline data is not helpful. She says changing up testing makes the most sense.
The new rule anticipates healthier animals and carcasses with fewer defects reaching the Agency’s inspectors. That’s because the rule makes it clear than only establishment personnel is responsible for sorting that occurs before FSIS does the antemortem inspection.
Key elements of the NSIS, according to the Final Rule include:
- Requiring establishment personnel to sort and remove unfit animals before the antemortem inspection by FSIS inspectors and to trim and identify defects on carcasses and parts before the post-mortem inspection by FSIS inspectors.
- Requiring establishment personnel to identify animals or carcasses, that they have sorted and removed for disposal before FSIS inspection, with a unique tag, tattoo, or similar device, and to develop, implement, and maintain written procedures in their HACCP system to ensure that animals and carcasses sorted and removed for disposal do not enter the human food supply.
- Requiring establishments to maintain records to document the total number of animals and carcasses sorted and removed per day and the reasons for their removal;
- Requiring establishment personnel to immediately notify FSIS inspectors if they identify, while conducting sorting activities, an animal or carcass that they suspect has a reportable or foreign animal disease such as African swine fever, classical swine fever, or Nipah virus encephalitis;
- Shifting agency resources to conduct more offline inspection activities that are more effective in ensuring food safety, which allows for up to two offline verification inspectors per line per shift and reduces the number of online inspectors to a maximum of three per line per shift;
- Requiring establishments to maintain records documenting that products resulting from their slaughter operations meet the new definition of ready-to-cook (RTC) pork product, which is any slaughtered pork product sufficiently free from bile, hair, scurf, dirt, hooves, toenails, claws, bruises, edema, scabs, skin lesions, icterus, foreign material, and odor which is suitable for cooking without need of further processing; and
- Revoking maximum line speeds and authorizing establishments to determine their line speeds based on their ability to maintain process control for preventing fecal contamination and meeting microbial performance measures for carcasses during the slaughter operation. FSIS retains the ability to slow or stop the line, as needed.
In the past five years, the New Poultry Inspection System (NPIS) has been adopted by 101 chicken and 17 turkey establishments along with one operator doing both. Seven more want to opt-in to NPIS.
FSIS has that experience plus 22 years with a pilot program, known as HIMP or the HACCP Inspection Models Project. HIMP enlisted 20 young chicken, five young turkeys, and five market hog plants to make new tracks, beginning in 1997.
HIMP was an extension of the Hazard Analysis and Critical Control Point (HACCP) planning doctrine that USDA borrowed from the Space Program after the E. coli outbreak associated with Jack-the-Box.
Market hog establishments opting into the NSIS will get more offline inspections, while FSIS will still be doing 100 percent carcass-by-carcass inspection as required by law. Gains in food safety, FSIS officials say, may come with attention to HACCP and Sanitation plans.
Over the years, the tasks being turned over to companies under NSIS are depicted as inspection-related by critics. It’s not that simple, however. The 209-page Final Rule assigns company sorters who “will be required to incise mandibular lymph nodes and palpate the viscera to detect the presence of animal diseases.”
Brashears says the task requires taking a sharp knife to the lymph node, and people can be taught how to do it fairly quickly. However, if not done correctly, FSIS personnel will slow or even shut down the line.
Twisting the knife in lymph nodes is one of the tasks the sorters must perform before they can present a hog to FSIS for inspection. Unfit animals need to be removed before antemortem inspection and defects on carcasses and parts must be removed before post-mortem inspection by FSIS inspectors.
While the Final Rule is largely about opting in or out of the new system, it includes more than that.
“Under this final rule, FSIS is also making several changes that will affect all establishments that slaughter swine, regardless of the inspection system under which they operate,” it says.
“Specifically, all official swine slaughter establishments must develop, implement, and maintain in their HACCP plans, sanitation standard operating procedures (sanitation SOPs), or other prerequisite programs (hereafter collectively referred to as their HACCP systems), written procedures to prevent the contamination of carcasses and parts by enteric pathogens, and visible fecal material, ingesta, and milk throughout the entire slaughter and dressing operation. These procedures must include sampling and analysis for microbial organisms to monitor the process control for enteric pathogens, as well as written procedures to prevent visible fecal material, ingesta, and milk contamination.”
Also, all hog operations will be “required to collect and test two carcass samples for microbial organisms, one at pre-evisceration and one at post-chill (i.e., the point in the slaughter process after the carcass has chilled in the cooler and after all slaughter interventions are completed), or, for very low-volume establishments, a single post-chill carcass sample.
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