What’s behind the New Swine Slaughter Inspection System?
"Trump eased regulation in meat processing plants. Guess what."
One position taken by a Trump appointee.
By Chuck Jolley on January 10, 2020
Q&A Analysis
The Hill, a Washington-based news publication, recently published a story about the New Swine Slaughter Inspection System (NSIS), an outgrowth of the U.S. Department of Agriculture’s Food Safety Inspection Service (FSIS) HACCP-Based Inspection Model Project (HIMP) with these warnings: “A new rule . . . would reduce the number of government food safety inspectors in pork plants by 40 percent and remove most of the remaining inspectors. In their place, a smaller number of company employees — who are not required to receive any training — would conduct the ‘sorting’ tasks. The rule would allow companies to design their microbiological testing programs to measure food safety rather than requiring companies to meet the same standard.”
The story continued “. . . the new rule would remove all line speed limits in the plants, allowing companies to speed up their lines with abandon. With fewer government inspectors on the slaughter lines, there would be fewer trained workers watching out for consumer safety.”
The limitations were obvious. Poke-and-sniff could find quality control problems, such as carcass bruising and broken bones. But E. coli O157:H7 contamination or any of the other pathogenic bacteria that might be present takes a swab and a petri dish.
The USDA believed checking for bruising and other visual imperfections can be done quickly and efficiently online by people with reasonably good eyesight. Better to sample and test for contamination in the lab than try to watch for it at even 10 carcasses per minute. Their research was designed to bring food safety practices from its mid-20th century roots to the 21st century, a nearly 60-year leap forward.
Still, the FSIS plan met with considerable controversy. To learn the facts as FSIS saw them, I called on Mindy Brashears. She was a professor of food science at Texas Tech University until she was nominated by President Trump to lead the FSIS.
Coming on to the scene after almost all the work on HIMP was complete, she had no real skin in the game. She took a fresh look at it, more than ready to veto the program if it didn’t meet some very rigorous scientific standards. I asked her some questions about the program and her reactions to it.
Q. The new swine slaughter inspection system (NSIS) has been piloted at five pork processing plants and was developed over many years of research and evaluation. Would you walk me through that process?
A. Because NSIS was on the horizon when I began with FSIS, I took a special interest in reviewing the proposed rule with an intense focus on the history and data collected to inform the rule. I took a very scientific approach to analyzing the system as I have done with other major tasks in my career. I asked for all of the data collected (not just summary data) and also conducted a thorough review of methodologies, study design, peer reviews and statistical analysis (among other things).
My commitment at FSIS is to make data-driven, science-based decisions and I had to be confident that this new system was the right thing to do. After weeks of reviewing data, visiting plants and having in-depth conversations with our staff, inspectors and even employees at establishments that operated under the new system, I was confident that the move to NSIS was the right thing to do to protect public health and improve food safety.
What is also very important to note is the fact that I also listened to opposing arguments against moving ahead with NSIS. Regardless of the individual or group making a claim or request, I have a high standard for data and science. We can’t make decisions based on emotion, hearsay or anecdotes because lives are at stake. Not one single opposing group was able to provide any genuine data to indicate we should not move forward with NSIS on any point of contention related to public health. It is important that the facts are the facts so we can make our food supply safe and move forward to protect the American citizen from foodborne illness.
I’m happy to walk you through our scientific approach to modernizing swine inspection on a high level because there is a large amount of information and data that went into making this deliberative and thoughtful decision. The research did not begin overnight and actually stretches back to the late 1990s after the transition to Hazard Analysis & Critical Control Points (HACCP)-based systems in meat and poultry processing plants. As you already know, FSIS adjusted the overall processes and sanitation in federal establishments to focus on pathogen prevention by implementing HACCP/Pathogen Reduction (PR) regulations and Sanitation Standard Operating Procedures (SSOP).
In 1997, FSIS initiated the HACCP-Based Inspection Models Project (HIMP) pilot in 30 volunteer slaughter establishments (20 young chicken, five turkey, and five market hog) to determine whether new slaughter inspection procedures, along with new plant responsibilities could improve food safety—while simultaneously increasing consumer protection. These facilities have been successfully operating under this system for more than 20 years and data collected in these facilities has informed decisions for New Swine Inspection Systems (NSIS) and New Poultry Inspection Systems (Implemented a few years ago).
The five comparable market hog slaughter establishments listed below volunteered for the HIMP pilot:
* Clemens Food Group, LLC in Hatfield, Pa.
* Quality Pork Processors in Austin, Minn.
* Smithfield Packaged Meats in Vernon, Calif.
* Swift Pork Company in Beardstown, Ill.
* WholeStone Farms Cooperative, Inc. in Fremont, Neb.
More than 20 years later and with significant experience and data in hand, FSIS issued the Modernization of Swine Slaughter Inspection proposed rule in 2018. This rule was formed by pathogen data collected in the facilities as well as data collected on inspection tasks. Summaries of the data are in the presentation. Most people do not know that the Agency prioritizes inspection tasks that are directly related to pathogen presence and public health. As you would expect, inspection tasks related to HACCP and Sanitation rank high when it comes to food safety.
The final rule was published in September 2019 and has two parts:
* All official swine slaughter establishments are required to develop, implement and maintain in their HACCP systems written procedures to prevent the contamination of carcasses and parts by enteric pathogens, fecal material, ingesta and milk throughout the entire slaughter and dressing operation. These procedures will include sampling and analysis for microbial organisms to monitor process control for enteric pathogens, as well as written procedures to prevent visible fecal material, ingesta and milk contamination.
An important aspect of this that never gets mentioned in the media is the fact that now the establishments must test for indicator bacteria in two locations for process control to determine if the process is preventing contamination. These requirements are for all swine facilities.
* The New Swine Slaughter Inspection System (NSIS) which establishments can choose to operate under or they can remain under the traditional slaughter inspection system. NSIS does NOT delegate any inspection authority to the plant. FSIS inspectors perform all inspection tasks and there is still 100% ante-mortem and post-mortem inspection.
There is a reduction in the total number of inspectors. Those under NSIS will not have food inspectors present in the plant. They will have Consumer Safety Inspectors (CSI) and our DVM inspectors. The CSIs have more experience and training in food safety, HACCP and Sanitation tasks and will be performing the online and off-line inspection tasks.
Establishments choosing to operate under the new system are required to sort and remove unfit animals before FSIS ante-mortem inspection and to trim and identify defects on carcasses and parts before FSIS post-mortem inspection. In a traditional inspection system, the inspector would see a defect (bruise, fecal contamination, etc.) and then direct the plant employee to remove it.
Now the plant employees are allowed to do that before it reaches the inspector, so the carcasses are cleaner when inspection occurs. If a defect is found by an inspector, then the plant must still go back and take corrective actions. As already stated, FSIS is still conducting 100% carcass-by-carcass inspection as required by law but now the plants are responsible for only presenting product that will pass inspection. This allows FSIS inspectors to focus more on food safety issues and less on quality defects.
Again, and I can’t emphasize this enough, USDA inspectors will continue to conduct inspection of all animals at ante-mortem and all carcasses and parts on post-mortem as mandated by Congress.
Q. What input did you get from industry resources like the National Pork Board and the National Pork Producers Council? How about the general public?
A. The proposed rule received over 83,000 public comments, which were reviewed and addressed in the final rule. The agency received overwhelming positive support from industry groups like the National Pork Board and the National Pork Producers Council due to FSIS’ desire to bring innovation to the inspection process, while still producing safe and wholesome pork products for consumers.
It is important to remember that five companies were already operating under this system for more than 20 years so the industry was very familiar with the successes and benefits of this program. In some regards this is also about leveling the playing field so that all of industry can operate in this inspection system and innovate like their five counterparts above.
Other comments received from the general public may be read, along with the agency’s response, in the final rule. Each and every comment was considered and a response was given categorically.
Q. NSIS is an outgrowth of the HIMP program, of course, which dates back to 1997. Will its adoption lead to similar programs – sooner or later? And will it take 20+ years to test and begin to implement?
A. The agency has a mission to ensure that everyone’s meat, poultry and processed egg products are safe. Government inspection must keep pace with the scientific world. It is our obligation to the consumer to allow for the implementation of innovative solutions and new technologies as well as systems that protect public health. It is a challenge because generally people do not like change and are opposed to innovation. Think about all of the safety and scientific advances over the last 30 years such as airbags, smartphones and here we are doing inspection the same way we were 50-60 years ago.
Unfortunately, many groups want us to stay stuck in the past. We will not. We are committed to improving food safety. This means that the modernization of inspection and policies is necessary in order to protect public health. As a scientist, I’ve seen pathogens constantly adapt to their environment, so we must continually modernize our approach to stay ahead of their impact on our food supply.
For poultry, FSIS published a final rule for the New Poultry Inspection System (NPIS) on Aug. 24, 2014, which serves as an optional inspection system for young chicken and all turkey slaughter establishments. NPIS also reduces the risk of foodborne illness by focusing FSIS inspection activities on those tasks that reduce contamination on chicken and turkey products. As of Dec. 17, 2019, there are 126 USDA poultry slaughter establishments operating under NPIS and it has been a successful transition. It is important to note a trend towards improved food safety because, after a year of collecting data, 89% of the plants under NSIS are meeting performance standards for Salmonella. We will continue to monitor this.
Under NPIS, one federal inspector is assigned to each evisceration line to conduct postmortem inspection of each carcass and one off-line inspector for each evisceration line to conduct food safety and other verification inspection tasks.
FSIS recently conducted an analysis to determine whether specific off-line inspection tasks were performed more frequently after an establishment’s conversion to NPIS. The analysis includes 72 formerly non-HIMP establishments that converted to NPIS, using Public Health Information System (PHIS) inspection task data from May 2015 to April 2019.
The analysis illustrates that:
* Inspectors consistently completed a higher number of selected food safety-related offline inspection tasks, including the new NPIS inspection tasks after NPIS implementation.
* The new NPIS Zero Tolerance Food Safety Verification task is being performed at or near four times more often after NPIS conversion as compared to the pre-NPIS Poultry Zero Tolerance Verification task.
* The rate of noncompliance records (NRs) documented for these zero tolerance verification tasks more than tripled in conjunction with the increase in tasks performed.
FSIS leadership and I have been very public about our intentions to modernize all components of inspection. The agency mentioned beef modernization at numerous food safety and stakeholder conferences and even held two roundtables in May of 2018 to gather feedback and ideas on how the agency could modernize its approach to inspecting beef. It is FSIS’s statutory duty to protect public health by ensuring we modernize our inspection systems, policies and use scientific approaches and we will be committed to overseeing beef modernization. Initially, this will be done on a case-by-case basis using a waiver system. Those operating under the waiver will be assessed and data collected will be used to inform the future of beef modernization.
In 2020 we also plan to announce modernization of egg products inspection. For egg products, we will move to a HACCP-based system as we have already done in meat and poultry operations.
Q. The plan was endorsed by the National Association of Federal Veterinarians, a strong note of approval from a very well-respected organization. Several other groups strongly object, citing the end of online inspection, faster line speeds, and the ability of a plant to ‘set its own rules’ as dangerous and detrimental to food safety. How do you respond to their fears?
A. Let me be clear: FSIS has not delegated any of its authority. There is much misinformation out there. Online inspection has not ended at all.
There are key differences between NSIS and traditional inspection:
* Under traditional inspection, market hog establishments voluntarily segregate animals before FSIS inspection. Under NSIS, this sorting process will be mandatory.
* Under NSIS, if establishment employees do not properly sort animals for food safety conditions before FSIS inspection, the establishment will receive a non-compliance record (NR). They do not receive NRs under traditional inspection. This is a motivation factor for plants to do things correctly.
As already stated, under the final rule, FSIS inspectors will continue to conduct 100 percent carcass-by-carcass inspection; the plant employees will prepare and present the carcasses and parts to FSIS inspectors for inspection. Also, FSIS inspectors will continue to slow and stop the line to ensure food safety and inspection are achieved. The inspector always has the right to do this even when the plant is operating at increased line speeds.
In the HIMP studies, there was little difference in line speeds. It is not as if the lines will be running out of control (see the presentation for details). A couple of practical things I want to point out:
1. The plant will still be bound by cooler space and the number of carcasses that can be put in a cooler.
2. Line speeds are ONLY in slaughter areas because they are set for inspection.
If needed, our inspectors can slow the line. There has never been a line speed limit in fabrication or other downstream processing areas. The most important thing to note about line speeds is the fact that you can stop the line and observe an entire carcass, and you will never see Salmonella, Campylobacter or any other pathogen. We must focus on HACCP, sanitation and implementation of food safety technologies to keep the product safe. Our modernized inspection systems are the next phase of HACCP implementation as we focus inspection resources on off-line tasks related directly to food safety.
The final rule also allows FSIS inspectors to complete more offline food safety and humane handling verification tasks to monitor compliance. These offline inspection tasks have a more direct impact on food safety and animal welfare.
I hear all of the fears cited by these special interest groups, but as a scientist, I can’t rely on anecdotes. I tell all of these critics and groups “bring me the data” and yet none of them can. At the end of the day, I can only assume this is a basic fear of change or some ulterior motive that is causing them to spread misinformation and fear.
Q. Pork plants have the option of working the new program into their in-plant processes or standing pat with their current program. Won’t trying the blend the old with the new create industry and public confusion?
A. No, the process is very straightforward. The final rule gives market hog establishments the choice to operate under NSIS or to continue to operate under the traditional slaughter inspection system. All market establishments will initially have six months from the date of publication in the Federal Register to notify their district office of their intent to operate under NSIS. Establishments that do not notify their district office of their intent to transition during this time will be deemed to have chosen to continue to operate under traditional inspection. Market hog establishments that decide that they would like to convert to NSIS after the initial notification date may notify their district office of their intent at any time after that date.
FSIS will then implement NSIS in the additional establishments that intend to convert on a schedule consistent with the availability of agency resources and establishment readiness.
As previously noted, some aspects are required for all establishments.
Q. The rollout has just begun. How is it going? Who’s onboard? What are some of the objections and “attaboys” you’ve heard?
A. Some establishments have contacted their FSIS district office expressing interest in converting to NSIS. However, to date, the agency has not received a written commitment with a proposed conversion date from any swine slaughter establishment. The final rule published in the Federal Register on Oct. 1, 2019 and establishments have until April 1, 2020, to notify their FSIS district office of their intent to operate under NSIS. As we begin to roll out the system, I will be happy to follow up with additional information.
Editor’s note: This is an edited and shortened version of Chuck Jolley’s interview with Mindy Brashears that was originally posted by Feedstuffs. It is published here with permission.
'No way food safety not compromised': US regulation rollbacks during Covid-19 criticised
"Trump eased regulation in meat processing plants. Guess what."
Major pork plant closed after hundreds of workers contract coronavirus, while speeding up of poultry production lines raises concerns over standards
Bibi van der Zee, Tom Levitt and Andrew Wasley
Mon 20 Apr 2020 21.43 AEST Last modified on Mon 20 Apr 2020 21.49 AEST
The surge of coronavirus cases at Smithfield Foods in Sioux Falls has highlighted the vulnerability of meat-processing workers. Photograph: Erin Bormett/AP
The US government is accelerating controversial regulatory rollbacks to speed up production at meat plants, as companies express growing alarm at the impact of Covid-19 on their operations.
A union representing federal food safety inspectors has said faster lines will make it harder to catch “pathology that shouldn’t be going out to the consumers”.
“There is no way that food safety is not compromised when the sole trained government inspector on the slaughter line in a chicken plant is expected to examine three birds every second,” said Tony Corbo, senior government affairs representative at Food .. https://www.theguardian.com/environment/food .. & Water Watch. “The US government has stepped on the accelerator to grant these waivers while everyone is concentrating on the Covid-19 epidemic.”
A spokesperson for the FSIS accused campaigners of “spreading fear among the American public”. “The agency’s decisions [on granting line speed waiver requests] are based on data gathered under the Hazard Analysis and Critical Control Points (HACCP)-based Inspection Models Project (HIMP) pilot study. The 20-year pilot showed that online inspectors in HIMP young chicken establishments were able to conduct an effective online inspection of each carcass when operating at a line speed of up to 175 bpm and that HIMP establishments were able to control for pathogens at the line speeds authorized under HIMP.”
Under traditional poultry processing rules, line speeds ran at 140 birds a minute, and required at least four inspectors to be stationed on each line, tasked with checking carcasses for defects, disease or contamination, including fecal matter which can cause salmonella. That has since been reduced to one inspector per line, with individual regulatory waivers .. https://www.fsis.usda.gov/wps/wcm/connect/5bd6c2c0-5e37-4397-9ed4-2468c2168557/2018-0014.htm?MOD=AJPERES .. enabling line speed increases.
“It potentially reduces some of the quality control efforts, but I am not concerned about worker safety as a result of the increased line speeds. Some plants are actually reducing speeds because of employee absenteeism,” said Adam Speck, a senior commodity analyst at IHS Markit’s Agribusiness Intelligence.
‘People are getting sick from our poultry production’
The line speed increases come as Guardian data analysis reveals that at least one in 10 US poultry slaughterhouses failed government salmonella tests last year. In some categories, failure rates are as high as 34%.
"People are getting sick from our poultry production system, and we think that is a public health emergency. Tony Corbo
“We’ve been playing around with these standards for 20 years now,” said Corbo, one of the parties to the petition, “and it doesn’t seem to be working in terms of reducing the amount of food-borne illness in this country. People are getting sick from our poultry production system, and we think that is a public health emergency.”
The FSIS has made attempts to bring down salmonella levels and reduce food-borne illness. The FSIS pointed out to the Guardian that the number of establishments in category three [it has a rating system to encourage improvement] has been halved since 2017. But a Guardian analysis of the FSIS’s reports for the last year shows that for chicken carcass plants, an average 11.8% of inspected plants still failed the standard.
Poultry plants have been given permission to speed up production lines despite warnings that it could compromise food safety. Photograph: Nati Harnik/AP
A spokesperson for the Chicken Council disagreed with criticisms of the sector. He told the Guardian: “No one wants to reduce salmonella more than the companies producing our food. Our families eat the same chicken.” The council opposes the petition, he stated. “We agree with FSIS, and previous court rulings, that a science-based, multitiered approach aimed at reducing all salmonella on raw meat and poultry products results in a more appropriate and effective use of agency resources compared to a separate and specific focus on specific individual strains.”
Campaigners say the FSIS is limited in its ability to keep US meat and poultry healthy. A critical report on the FSIS by the US Government Accountability Office in 2018 .. https://www.gao.gov/assets/700/690709.pdf .. stated that a review of data had shown that “some plants are still not meeting pathogen standards – in some cases repeatedly not meeting the standards – and are allowed to operate”. It also pointed out that the agency still had no mandatory recall authority.
“The Workers Are Being Sacrificed”: As Cases Mounted, Meatpacker JBS Kept People on Crowded Factory Floors
"Trump eased regulation in meat processing plants. Guess what."
With coronavirus outbreaks at two-thirds of the company’s beef processing plants, employees are asking, “Why didn’t they help protect us?”
Esther Honig and Ted Genoways5 hours ago
[...]
By mid-March, Rodriguez says she started noticing co-workers missing from the line. The parking lot seemed emptier than usual. According to data from the county health department, COVID-19 had already begun spreading among workers at the plant. Yet even as Colorado schools were ordered to close and the country declared a national emergency, the production line at JBS continued to run as usual.
On March 20, Rodriguez showed up for her shift at 5:45 a.m. and later that day shared lunch with her dad. As she left that afternoon, her mom called to say her dad had come home sick and gone to urgent care with a high temperature. Doctors said his symptoms were consistent with COVID-19 and advised him and the rest of the family to self-quarantine. Rodriguez says she called her supervisor to report that she’d likely been exposed. “They said, ‘But you’re not symptomatic, so you should come to work.’” If she wanted to take two weeks off to quarantine, Rodriguez says, she was told she would lose her job and would have to reapply after 90 days. “No one is forced to come to work and no one is punished for being absent for health reasons,” a JBS spokesperson said in an emailed statement. “If anyone experienced something different, that is troubling and not consistent with our culture or our policies.”
A week after visiting urgent care, Rodriguez’s father was admitted to the hospital, where he tested positive for the virus and was placed in the ICU on a ventilator. Days later, news hit the local press: The JBS plant was in the grip of a full-blown outbreak. Since then, the Colorado Department of Public Health and Environment has found that more than 245 workers have tested positive, and six have died. But the company has refused to offer tests of its line workers, and it reopened earlier this week—barely halfway through a two-week quarantine mandated by the health department. On Tuesday, President Trump issued an executive order to classify meatpacking plants as critical under the Defense Production Act, meaning that plants would be required to remain open. “We thank the Administration for acknowledging the important role food companies serve and ensuring that our food supply will remain resilient during these unprecedented times,” JBS wrote in a statement praising the move.
Workers fear that JBS is signaling that it intends to use the White House order as cover to continue production, even as advocates argue that protections for workers are insufficient. “All these years that my dad has given them,” Rodriguez says. “This is how they’re going to show they care?”
The JBS plant in Greeley is hardly unique. In recent weeks, there have been significant COVID-19 outbreaks at JBS’s beef processing plants in Souderton, Pennsylvania; Plainwell, Michigan; Green Bay, Wisconsin; Cactus, Texas; and Grand Island, Nebraska. Including Greeley, these account for six of the company’s nine beef plants nationwide. Similar outbreaks have hit three of its five pork processing plants. At the same time, dozens of plants owned by other companies, including Tyson Foods and Smithfield, have seen outbreaks among their workers and in surrounding communities. All told in the US, per data collected by the Food and Environment Reporting Network, at least 99 meatpacking and processed food plants have confirmed cases of COVID-19, and at least 20 meatpacking plants and five processed food plants are currently closed. At least 6,832 workers are confirmed sick and at least 25 have died.
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