000921 FSIA Administrator Discusses HACCP Changes

Washington - Following are comments by Thomas Billy, Food Safety & Inspection Service Administrator. “I would like to discuss some modifications we have made in the HACCP- Based Inspection Models Project. I continue to be excited about this project and the resulting food safety gains. I believe we have found a solution where FSIS can meet the demands of the Federal Meat Inspection Act and Poultry Products Inspection Act while continuing to capitalize on the food safety gains garnered by this project.

“As FSIS Administrator -- and as a consumer -- I believe the customer deserves a safer and more wholesome product. When we embarked on the models project, for the first time we measured the accomplishments of the current system. While traditional inspection is good, it could be better. Too many food safety defects are passing through the current inspection system. And, other defects that are not food safety issues but are still unacceptable are also too frequent in our current system. While perfection under any system is impossible, we must strive to improve. I will not accept less--nor should any consumer. The data collected shows that we can do better and therefore we must make every effort to improve our current system.

“The models project raises the bar for food safety and other consumer protection concerns. With this pilot project we measured how many defects pass our inspection system, put them into categories, and set pilot performance standards that these plants must achieve. This does not mean that defects unacceptable under the traditional inspection systems are now acceptable. But, under the models project, we are demanding an improvement over what our inspectors are currently achieving. Thus the pilot performance standards are based on the 75th percentile of what is achieved under our current, traditional method of inspection. When plants enter HIMP, they must therefore improve their process in order to meet these new, tougher, standards.

“Just as under traditional inspection, federally funded FSIS inspectors are continuously present and inspect each carcass. And, the pilot project includes more verification to ensure standards are met, including four times as many food safety checks.

“Plants have the responsibility to meet the pilot performance standards, and our inspectors have the responsibility and authority to ensure that they do so.

“Thus far under this project we have made significant food safety gains. Last month, we released some data from RTI, an independent third party, that show significant gains. We also have some new data based on FSIS in-plant checks. Our own FSIS inspectors in seven HIMP plants recorded these data. It is taken over a much longer time frame than the RTI data we released last month and therefore the numbers reflect not only substantial but improved performance in most areas.

“In the sixteen plants included in baseline the traditional system achieved a 0.1% rate for infectious conditions and 1.5% rate for fecal contamination. Despite these findings, we set the tolerance for food safety at zero. Under the models project in which plant sorters address these defects with FSIS oversight and verification inspection, those numbers have been reduced to an average of nearly zero and 0.2% respectively.

“For OCP-1-animal diseases such as airsacculitis-the performance standard based on traditional inspection is set at 1.7%. FSIS inspector data shows the seven plants are achieving a 0.9% rate. In EVERY CATEGORY, important gains have been achieved-the plants are performing better under the pilot project than plants achieved under traditional inspection.

“It would be irresponsible to turn away from such marvelous gains.

“That said, let me turn to the legal challenges we are facing with this project.

“Union leadership challenged FSIS in DC District Court. FSIS initially prevailed, but the decision was overturned on appeal. The decision has been remanded to the original DC District Court. This morning we met with union leadership and lawyers and presented changes we will make to the project to bring the project into compliance with statutory requirements.

“In redesigning this project, we wanted to ensure that we did not turn our backs on the important gains achieved, and that our inspection force still has the capability of both inspecting carcasses and checking the plants' systems. Also, to meet with the appellate court's interpretation of the Federal Meat Inspection Act and Poultry Products Inspection Act, we decided to assign a federal inspector to a fixed position on the line to make critical determinations on each carcass.

“We have handed out three charts today, to help you visualize how inspection works under traditional inspection, under the pilot project, and the revisions we have just made. “Under traditional inspection, FSIS inspectors identify and condemn certain abnormal conditions that affect the entire carcass disposition such as septicemia/toxemia and extensive airsacculitis. Establishment personnel are responsible for the identification and removal of all localized (trimmable) conditions included in the finished product standards (FPS). Examples of these conditions are sores, breast blisters, bruises, localized airsacculitis and feathers. Twice each shift, we check 10 birds for zero-tolerance on fecal contamination, and twice each shift we check 10 birds for finished product standards.

“Under the initial models project design, inspectors are not tied to a fixed point on the line. Oversight inspectors are mobile and concentrate on where they see problems occurring at any point along the slaughter line. Verification inspection involves removing birds from the line and performing checks for both food safety and other consumer protections. Food Safety checks involve 10 bird sample sets eight times per shift. Inspectors have two-way radios and communicate with each other when problems with the plant's system are seen. If an inspector sees a possible problem, he or she calls for an immediate test to check the plant process.

“Under our revised design, we have placed a carcass inspector at a fixed point just before the birds go into the chiller. This inspector will be the final checkpoint for consumer-ready product. We will also continue to have an off-line inspector to verify that plant personnel are appropriately handling any defects and to ensure the overall design and execution of all of the establishments HACCP and process control procedures. We will still be conducting four times as many food safety checks than occur under traditional inspection.

“On August 25, 2000, AFGE, on behalf of the National Joint Council of Food Inspection Locals, filed a motion requesting the US District Court to enjoin the models project. If the injunction is granted, inspectors would be reassigned to fixed locations on the slaughter line and would perform traditional inspection duties. FSIS would be forced to revoke existing HIMP related promotions for more than 200 field employees. The agency believes that the demonstrated improvements in food safety under HIMP do not warrant the sweeping action requested by the union. The agency also believes the changes we are discussing today bring the project into compliance with statutory requirements. We expect to begin implementing these changes September 18.

“In closing, I want to emphasize that we cannot turn our back on improving inspection. While the union leadership has begun a campaign of misinformation, not all the inspectors in the plants are in agreement. I will quote from an inspector who posted a message on the union web page:”

" ... If we can further improve our inspection through more micro checks, more food safety checks and the same amount of checks as FPS then what is better. Also the product is now getting sorted more than before; not less and we still have the chance to look at all the carcasses that are on the line. ... "

Another inspector said:

"I am entitled to my opinion that we are not serving the American public in the best way by inspecting using an outdated system, whereby we cannot see the microorganisms that are causing 5000 deaths or more a year in this country. ..."

I agree. We would not be responsible if we turned our backs on these demonstrated food safety gains.

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