Dear Editor,

This letter addresses a recent publication by L.A. Cox, about which Food Safety News wrote in the article “Faster line speeds may not be the food safety issue some thought.” Mr. Cox is an industry supporter whose research is harmful to public health. His support of high-speed slaughter falls in line with his historical industry alliances. Furthermore, he based his publication “Higher Line Speed in Young Chicken Slaughter Establishments Does Not Predict Increased Salmonella Contamination Risks” on fundamentally flawed data. 

Mr. Cox’s study relied on Food Safety and Inspection Service (“FSIS”) data that slaughterhouses generated by operating under a waiver program. This waiver program decreases the number of FSIS inspectors at each slaughterhouse and largely allows slaughterhouses to self-regulate. These slaughterhouses were able to submit falsified or inaccurate information that indicated compliance with FSIS standards. A neutral third-party did not check to ensure the slaughterhouses’ data was accurate. Dependence on such unreliable data renders Mr. Cox’s conclusions dubious at best. 

Indeed, the Government Accountability Project’s Food Integrity Campaign gathered testimony from FSIS inspectors – who worked in the very waivered slaughterhouses whose data Cox relied on – which makes clear that these slaughterhouses manipulated their systems to evade detection of violations. For instance, many waivered slaughterhouses changed the order of their line speed inspection procedures so that FSIS inspectors could not submit Noncompliance Reports for the myriad adulterated carcasses that entered the food supply. 

And, an affidavit (Issue Area: “Food Safety,” Campaign: “High-Speed Poultry,” Affidavit #7) from a slaughterhouse supervisor avers that leadership heavily influenced workers not to report violations they witnessed. They explained that supervisors “would mix a ‘good’ flock with the bad flock and turn up the speed of the evisceration line so that it would be more difficult for the [FSIS] inspector to catch the bad birds.” The supervisor further explained they would change expiration date labels on products to make the slaughterhouse look like it was meeting its fresh poultry quota when it was actually sending older products to consumers. The supervisor also witnessed the slaughterhouse’s Hazard Analysis and Critical Control Points Coordinator – who is responsible for identifying food safety and public health concerns – falsely record temperatures of meat refrigeration equipment to make the slaughterhouse appear to be in compliance. 

In addition, many inspectors stated in their affidavits that they would not eat produce from the waivered slaughterhouses in which they worked, and that they were concerned for the public’s health should high-speed chicken slaughter become the national standard. 

Reliance on such flawed data is unsurprising given Mr. Cox’s history of making statistical conclusions that support industries, which imperil the environment and public health. For instance, he concluded that humans would be worse off if the agriculture industry stopped feeding their food-destined animals certain antibiotics—a practice intended to increase animals’ weight quickly and cheaply. Scientists have linked using antibiotics for this purpose to the development of antibiotic-resistant illnesses in humans, which cause approximately 35,000 deaths every year.  Several peerreviewed publications have confirmed that this antibiotic use does cause antibiotic-resistant diseases and harms human consumers. Furthermore, Mr. Cox’s publication contradicts data that the Centers for Disease Control and Prevention has published for years. 

The FSIS needs neutral studies that scientists base on reliable data in order to inform the public whether high-speed slaughter lines are safe, or are simply another way for the poultry industry to compromise human health for one more dollar.

— Jessica Chapman of the Animal Law Litigation Clinic, Lewis & Clark Law School

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