The unfortunate part of  the so-called “modernization” of poultry safety is that it doesn’t modernize much. It cuts the FSIS budget and workforce, which was done in advance of even knowing whether the kinks were worked out of the new system. It increases profits for this industry, which is perfectly fine unless it comes at the cost of worker safety. And it potentially causes compromises in consumer safety if not correctly implemented.

Having watched this program from the very beginning, I know well the potential for success and failure of this model. It has potential. When it was designed, it immediately cured critical problems that FSIS line inspectors were experiencing: repetitive hand-motion injuries, mental fatigue, muscular-skeletal disorders, among others.

Unfortunately, it now transfers those problems to plant employees who do not have the protections that federal workers enjoy. Many will say this is not true because plant workers are protected by OSHA standards. Those who believe this live an illusion and have not spent much time in the reality of poultry processing. Plant workers will suffer the pain to protect their low-wage jobs, jobs that they cannot afford to lose in a world of poverty in small-town America.

It is up to Congress to cause the meaningful implementation of this new system. FSIS and the industry have dropped the ball on the NIOSH study, dropped the ball on the GAO report, and turned a deaf ear to many consumer safety group’s concerns, while staying in the news with recalls and foodborne illness outbreaks from poultry products. To allow this “modernization” to take place without some honest repair will be a disaster.

Here’s the problem. It is one thing to get a model program running in a first-class plant that has incentives to ensure the project’s success. These plants have large-scale corporate money advancing the project to make it run as well as possible to keep the corporate image intact and moving forward. It is entirely another situation to be in a plant that is running close to the edge on profit and loss and is then being forced to implement a program it is neither interested in nor equipped to put into place. This is the reality, and everyone involved knows it.

There are those who may say that, if these companies cannot compete, that’s their problem, and the market will take care of that issue. Well, there are two problems with that idea. One, the consumer bears the penalty of the transitional period when poor processing conditions put contaminated and diseased poultry into commerce. Second, it is not a fair practice for FSIS to do a poor job of implementing a program so that the big companies can take over the smaller companies. This hurts not only the companies; it hurts consumers. Read “The Meat Racket” for a glimpse into the world of corporate takeovers and price-fixing.

No, USDA is a marketing service for the poultry business — all of it, and not just part of it. And FSIS is a regulatory entity for consumer protection. It’s not just a good idea. It’s the law.

And to those who say that FSIS will effectively regulate the implementation of the new system, I have two words: “Foster Farms.” The regulatory machine that is FSIS is stumbling along at best. FSIS routinely bullies small plant operators yet allows large plants to run while poisoning the public. The agency bends and turns along pressure lines that range from big-money agribusiness to media exposure and Congressional pressure and to influences other than science. FSIS will be under serious pressure to make the new system work.

When “HIMP” first got off the ground in 1999, I visited plants that had chronic Noncompliance Records for fecal contamination. The plants did not implement effective preventive measures as required under the federal law for daily failures of its HACCP system. To expect FSIS to be able to shut down plants and slow down a huge poultry-producing machine is ludicrous.

No, Congress is responsible for this program. (See my article, “Is HIMP Circling the Drain?” in Food Safety News, April 28, 2014.) They have heard every detail and are fully aware of the problems. Congress has an oversight committee with the power to get this right. They are fully aware of FSIS breakdowns in addressing issues of worker safety and performance integrity. The monkey is on Congress’ back to get this right. Again, chances of that happening are almost nil.

As I previously stated, the system, with some modification, has the potential for being an improvement over the current program.

The current state of the project is far from being ready for prime time.

Hazard Analysis Critical Control Points, or “HACCP,” is a change to the federal law for meat and poultry inspection that was put into effect in 1998 for large plants. HACCP puts increased responsibility for food safety on to the companies’ management and lessens government authority to take actions, in real-time, to prevent unsafe food from reaching the consumer.

The HACCP Based Models Project has been functioning in pilot plants for more than 13 years. But, during that time, FSIS has failed to effectively demonstrate the viability of the pilot program through objective and statistically sound measures.

There have been numerous reports that criticize the performance of HIMP by consumer safety groups such as the Government Accountably Project, Public Citizen, the Food and Water Project and the government’s own Government Accountability Office (GAO). The GAO reported its concerns in December 2001 and again in August 2013, with many of the problems identified in the 2001 report again identified in 2013. This means that problems with the pilot program have been occurring in selected plants for more than a decade.

The pilot plants ship product to consumers as if it had been produced under proven inspection methods, meaning that consumers have no practical way of knowing if the meat and poultry they buy is produced in one of these “experimental plants.”

In a U.S. Centers for Disease Control and Prevention (CDC) report entitled, “No Progress in Salmonella During Past 15 Years – Food safety annual report card targets hard-to-prevent infection,” CDC Director Thomas R. Frieden, M.D., M.P.H. stated:

 “Although foodborne infections have decreased by nearly one-fourth in the past 15 years, more than 1 million people in this country become ill from Salmonella each year, and Salmonella accounts for about half of the hospitalizations and deaths among the nine foodborne illnesses CDC tracks through FoodNet.”

In the same report, Elisabeth Hagen, MD., then-Under Secretary for Food Safety in the Department of Agriculture, states,

“…  far too many people still get sick from the food they eat, so we have more work to do. That is why we are looking at all options, from farm to table, in order to make food safer and prevent illnesses from E. coli, Salmonella, and other harmful pathogens.”

I was a FSIS employee for 18 years, from 1987 through 2004. I served as a Consumer Safety Inspector in beef, pork and poultry plants in more than 30 different assignments locations. I was promoted five times in my career and was active in improvements in consumer safety and in employee safety and in addressing inadequate staffing within the FSIS inspection program. I was a dedicated public servant and believed strongly in the FSIS mission of consumer protection.

In 1997, FSIS asked the National Joint Council of Food Inspection Locals (the U.S. government meat inspectors’ union) to submit proposals to redesign the carcass-by-carcass inspection system. I co-wrote and submitted a proposal that would become the precursor of the HIMP model. The union was not opposed to improving the current inspection system. It was fully understood that changes in slaughter processing through mechanization was allowing significant contamination of carcasses to occur after food safety decisions by FSIS inspectors.

The proposed reconfiguration moved government oversight to the end of the process, increased the rate of “finished product standards” testing, and greatly improved the health and safety conditions of inspectors.  The proposal also gave sensible flexibility to adapt to temporary inspection staffing changes and corrected shortcomings in the traditional configuration of inspection.

FSIS adopted the proposal, radically modified it, and installed their version of a pilot configuration in several plants. In the process of transforming the union proposal, FSIS declassified disease conditions as a public health concern and restricted control by the inspector at the end of the processing line. Using the FSIS modified model, the final inspector is restricted in taking immediate action to stop contaminated carcasses from passing to the further processing and packing steps. Plant “sorters” replaced federal inspectors for segregation of diseased carcasses. The sorters are not required to have specific training and are under the direct control of plant production managers who are responsible for maximizing production rate and volume.

I was tasked, through a negotiated agreement between FSIS management and the Inspector’s Union, with evaluating the effectiveness of the HIMP pilot. Not only did I personally observe pilot plant performance during periodic visits, I placed union representatives in the pilot plants who evaluated processing performance through independent testing conducted parallel to FSIS and plant quality control testing. Not unexpectedly, the pilot project did not perform as was hoped due to drastic deviations from the union proposal.

One key element of the union’s proposal was to maintain the regulated line speeds of 70 to 91 birds per minute in poultry plants. This was critical due to the observed contamination rates in processing at those line speeds. Increasing the line speeds would logically result in an increased volume of contaminated product. Yet, FSIS deleted this requirement of the proposal and allowed plants to run at any speed that plant management desired.

Pilot plants almost immediately doubled their line speeds and, as predicted, allowed digestive tract contamination of product affecting huge numbers of carcasses without effective remedy. Even under the scrutiny of pilot plant performance, the HIMP model failed to prevent recurring incidents of visible fecal contamination of product, as documented by FSIS Noncompliance Records. Recurring failures of the pilot plants’ HACCP plan occurred with “no effective corrective actions and preventive measures” as required under law. Failures on the part of FSIS management to respond to problems in the pilot plants that I evaluated prompted me to become a “whistleblower” through the Government Accountability Project. I also shared my findings with Public Citizen, an advocate for consumer safety and government integrity.

In 2000, I compiled a report on HIMP pilot plant performance that revealed serious failures of the FSIS surveillance and enforcement of the law. I made exhaustive efforts to get FSIS management to respond to repetitive HACCP failures that were documented on their own FSIS Noncompliance Reports. In March 2000, I presented my report at a public meeting in Washington, D.C. FSIS management officials, industry representatives, and consumer groups attended the meeting, along with members of the media. Following the presentation of my report, the manager of one of the pilot plants left the meeting and immediately withdrew his plant from participation in the HIMP pilot program.

In 2013, the Government Accountability Office published its objections over data gathering in HIMP pilot plants. The GAO report noted:

“The U.S. Department of Agriculture (USDA) has not thoroughly evaluated the performance of each of the pilot projects over time even though the agency stated it would do so when it announced the pilot projects […] Specifically, there are limitations in the agency’s data analyses in its report evaluating the pilot project at young chicken plants, and there is no report evaluating the pilot project at young turkey plants.”

The HACCP Based Models Project configuration has significant problems that must be addressed if consumer safety is to be safeguarded. In future articles for Food Safety News, I will outline serious problems in a deregulated government surveillance program, the over-reliance on anti-microbial interventions in meat and poultry production, and the evolution of a failing inspection program to protect consumers from foodborne illness resulting from contaminated meat and poultry. I will also detail specific improvements to the federal inspection system that can be made to correct shortcomings in consumer safety.