Proposal would shift federal inspectors toward oversight
June 13, 2018
Proposed regulations would shift food inspection duties in swine slaughter facilities from federal employees to private ones.
They also would remove set limits on slaughter line speeds. Companies could move as fast as equipment and contamination controls allowed.
The Department of Agriculture's Food Safety and Inspection Service published the proposal in a Feb. 1 Federal Register notice.
Swine slaughter companies could choose whether to participate in the new system, under which fewer FSIS inspectors would work on pork production lines. Company workers would remove unfit animals ahead of slaughter and carcass defects on production lines, and federal inspectors would see the rest.
FSIS officials say the remaining inspectors would spend more time verifying compliance with sanitation and handling standards, focusing on risk.
Dr. Michelle Sprague, chair of the AVMA Animal Welfare Committee and the committee's representative from the American Association of Swine Veterinarians, said she expects federal inspectors would spend more time verifying compliance with welfare-related aspects of production and that the FSIS would require training for company inspectors. The AVMA and AASV have not taken positions on the proposal. Dr. Sprague provided her own opinions.
FSIS officials sought public comment through April 2. Commenters who identified themselves as veterinarians or FSIS inspectors said faster production with less-well-trained inspectors would hurt pigs and reduce food safety.
FSIS officials responded that the changes would modernize inspection systems in ways that would improve food safety, animal welfare, and inspection efficiency and effectiveness. The proposal follows a model used in a pilot program over the past 20 years.
Expectation versus implementation
Dr. William James worked for the FSIS for 28 years and retired as chief veterinarian in 2011, and he owns a company that consults on food safety, trade, slaughter, processing, and humane handling issues. He supports the proposed changes to post-slaughter inspection of carcasses and parts.
But he said having company employees—rather than FSIS veterinarians—sort which animals go to slaughter ahead of live animal inspection risks missing signs of reportable animal diseases. That risks animal health and, to a lesser extent, public health.
Seeing disease signs at slaughter helps identify diseases in source herds. He noted that a veterinarian at a U.K. slaughter plant was the first to identify foot-and-mouth disease during the country's 2001 outbreak, and Dr. James thinks the disaster would have been worse without that identification.
The FSIS needs to be careful about reducing its presence and ability to monitor for disease, he said. There is no better animal collection point for such monitoring than a slaughter plant.
Dr. Michael Gilsdorf, who had been CEO of the National Association of Federal Veterinarians until May 1, expressed similar concerns on behalf of that organization. FSIS veterinarians should see all live animals, he said.
Company workers could sort carcasses out of the food chain on the basis of disease signs—lumps, bumps, and bruises, Dr. James said. The federal veterinarians who oversee them would then spend less time supervising other federal employees and more on food safety.
Dr. Gilsdorf said no diseased carcasses should reach FSIS inspectors at the end of production lines in any program.
Most opinions Dr. Gilsdorf has heard from USDA veterinarians have been positive. He expects the agency would need the same number of veterinarians, and the changes should reduce burnout, which has led to vacancies and recruitment problems.
Dr. Gilsdorf said the food inspection system could further improve with better collection of residue and microbiological samples and faster results.
Dr. Sprague said the proposal "provides us the opportunity to improve animal welfare at packing plants."
At slaughter plants participating in the FSIS pilot program for the changes, federal inspectors spent more time than inspectors at other plants did on monitoring animal welfare, unloading of animals from trucks, feed and water availability, animal slips and falls, and stunning, she said.
"All of the areas where there's potential risk for welfare issues to arise, those things are being monitored even more closely in the plants that are using these processes," she said.
She is excited about the potential for animal welfare improvements. If the changes affect food safety, she expects improvement.
Dr. James expects FSIS veterinarians and lay inspectors will spend more time on postmortem food safety and processing, but he has heard no indication they will spend more time observing live animals during unloading, movement, or time in pens.
In response to the proposal, at least 15 people who submitted comments identified themselves as veterinarians. Fourteen expressed opposition, and one signed a request by two trade organizations to extend the comment period. The 14 opposed to the change said slaughter plant workers could abuse pigs, fail to administer stunning, and miss defects in trying to keep up with faster production speeds.
The current maximum production line speed is about 1,100 hogs per hour. Hog slaughter plants in a pilot program reached 1,300 per hour.
The Food Integrity Campaign of the Government Accountability Project, a whistleblower advocacy organization, provided four affidavits—three with redacted names—from FSIS inspectors at plants participating in the pilot program. The campaign collected the affidavits in 2014 for a potential lawsuit.
The affidavits describe contamination, lack of oversight, and a production speed too fast for company workers to spot and remove defects even if they were well-trained and allowed to intervene. Joe Ferguson, who identified himself as a 23-year employee of the FSIS and has since retired, said in his affidavit that company sorters don't know how to cut lymph nodes, and carcasses pass through production despite visible defects such as bile and signs of chronic pleuritis.
"Personally, I will not eat any products that bear the name of the company for which this meat is produced—I don't think that it is wholesome or safe to consume," he wrote.
A fifth affidavit given to GAP in April, provided to JAVMA News with the name redacted, states that swine with visible abscesses, for example, were sent to slaughter at pilot program plants, and federal inspectors missed the abscesses because production speed was too fast. The author is identified as another FSIS inspector.
Dr. Sprague said production lines already run near designed speed limits. While line speeds may rise, she said the pilot program indicated other, slower processes would limit speeds before stunning could become hurried. She also said she has seen no data to support concerns about the FSIS proposal.
Federal inspectors always monitor stunning, and she expects they will spend more time watching where animals are moved to ensure animals are not rushed.
Another commenter, Dr. Ana Malone Oliver, who identified herself as an FSIS veterinarian, wrote that FSIS inspectors and veterinarians are trained to identify foodborne illness sources, foreign animal diseases, and neurologic diseases and should retain those responsibilities. Having slaughter plant employees sort, trim, and remove lesions and other defects from carcasses prior to federal inspection could obscure conditions known to cause food poisoning.
"Additional off-line inspection tasks should be put into place; but not at the expense of removing FSIS inspectors from the line where the verification of pork wholesomeness is most critical," she wrote.
A statement provided by an FSIS spokeswoman said federal inspectors will continue inspecting all carcasses, and they will retain the ability to slow or stop production lines if issues arise.
My fear is that, perhaps, a move like this away from the federal government having this level of control is relying on the food industry of decades ago.
Darin Detwiler, assistant dean, Northeastern University College of Professional Studies, and a professor of food regulatory policy
An April 23 letter to Agriculture Secretary Sonny Perdue from 63 members of Congress states that turning inspection duties over to slaughter companies, without requiring or funding training, endangers workers, the public, and animals. Connecticut Rep. Rosa DeLauro and Wisconsin Rep. Mark Pocan are the lead authors, according to DeLauro's office.
"The USDA justifies the line speed increase by using a small, poorly assessed pilot project where none of the plants continuously operated at faster line speeds and all had serious safety issues," the letter states. It calls for a peer-reviewed risk assessment that would be made available for public comment.
In 2014, FSIS officials published a comparison of the five pilot programs at hog slaughter plants and 21 others in years 2006-13, except for 2011, a transition year for FSIS information systems.
They had comparable condemnation rates. The report states that the plants with pilot programs received more food safety–related inspections off the production lines and had higher compliance with sanitation and hazard-related regulations, at least equivalent Salmonella-positive test rates, and lower chemical residue contamination rates.
Darin Detwiler, who is a doctor of law and policy, assistant dean of the Northeastern University College of Professional Studies in Boston, and a professor of food regulatory policy, said the FSIS proposal fits a pattern of efforts to reduce federal oversight in favor of monitoring by states and third-party auditors. He is concerned the changes will reverse progress made in food safety during the past 25 years.
"My fear is that, perhaps, a move like this away from the federal government having this level of control is relying on the food industry of decades ago," he said.
Dr. Detwiler has worked in food policy since his 17-month-old son, Riley, died in 1993 in an Escherichia coli outbreak that killed four children and sickened more than 500 people.
He has worked since with government and industry on food safety policy, including serving on the USDA National Advisory Committee on Meat and Poultry Inspection.
In 1993, the FSIS relied on organoleptic—sensory—assessments. Reforms since 1996 have made industry plan and act to prevent pathogen contamination as well as declare that E coli O157:H7 is a food adulterant.
Progress required radical changes in inspection, monitoring, and public education, along with scientific advances, Dr. Detwiler said. The FDA Food Safety Modernization Act, passed in 2011, requires that food companies identify hazards and reduce risk with, among other tools, third-party audits.
Ideally, Dr. Detwiler said, companies will follow the proposed FSIS rules, if adopted, and people will be safe. But reducing federal control would give power to companies that fought public health protections—such as safety labels on raw meats—and that sell products in a complex international system.
"Ideally, this would be a scenario that creates an additional level of control as opposed to one that eliminates federal oversight," he said. "The average consumer has no idea what's going on with this—you know, who regulates what and how. They just assume that the food they serve their family is not going to make them sick, hospitalized, or dead."