Keep Poultry Processing Safe

New changes to USDA Poultry Inspection will result in unwholesome product.
FOOD ALERT!
PROPOSED USDA CHANGES TO POULTRY INSPECTION

I was a supervisor in the Poultry Processing Industry for five years.  Presently, I am a Poultry Inspector with the USDA.  The USDA is presently in the process of preparing to implement a drastic change in the way all poultry in the United States is inspected and in the way it will qualify for the “USDA Inspected” seal.  I truly believe these changes, which have been forged in the name of cost-saving will prove detrimental to the consumer.

At present, 7 Billion head of Poultry are processed in the United States on an annual basis (Turkey and Young Chickens).  At present, EACH of those 7 Billion heads are individually inspected by a trained, federally appointed USDA Food Safety Inspection Services officer.  We are agents of the United States Government.  We carry badges,
have been trained and are continuously involved in ongoing training relative to the inspection of poultry.  Before any
head of poultry can receive the seal of “USDA Inspected”, it is now physically examined for diseases, systemic infections, and wholesomeness.  There are federal directives which describe how we will perform these inspections,
how to identify the diseases and infections, the disposition of affected birds as well as all aspects of the processing function from pre-slaughter to post-slaughter.

The number 7 Billion is staggering, but at present, the Consumer can be confident knowing that EACH head of poultry has been individually inspected by a Federal Agent.

There are currently three inspection systems in place throughout the entire Poultry Industry.  The most common of these is the one I will address.  The others are similar, with slight variations.  The most common system has four USDA Inspectors on a line.  After evisceration, the poultry is conveyed on this line and presented to the inspectors for examination.  Each Inspector has a Plant employee as a “helper”.  The Poultry is conveyed on this line at the rate of 140 birds per minute.  Thus, each Inspector examines 35 birds per minute.  If the Inspector detects disease, systemic infection or any defect (bruises, fecal contamination, gall bladder eruption) which would make all or part of the bird
unfit for consumption, it is removed from the line, marked by the “helper” and sent for further processing to make it
fit for consumption.  Certain diseases, infections, or marked other conditions result in the bird being condemned and not further processed for human consumption.

As it stands, the system now assures NO adulterated product will be allowed to pass for human consumption.

Under the system I am discussing, most processing plants utilize at least three lines, some, many more.  However, each line, no matter the number of lines, has four USDA Inspectors.  Additionally, higher level Inspectors (Consumer Safety Inspectors) are continuously monitoring all other operations of the processing plant.  There is also a Supervisory Inspector who is responsible for all Inspectors in the plant and a Public Health Veterinarian who is the Inspector In Charge and ultimately responsible for the Implementation and Enforcement of all Federal Directives relative to the processing of Poultry in the United States.  As these are all Federal employees and not employees of the processing plant, there is no possibility of intimidation or harassment of these Inspectors.  Most plants run two shifts per day with a third shift which does not process but instead cleans and sanitizes all equipment in the plant which then must be inspected by USDA inspectors be fore another “start-up” can occur.  There is a duplication of all USDA Inspectors, Supervisors, and Veterinarians for each shift.  That's many USDA Inspectors at each processing plant, but again, EACH head of Poultry is physically inspected by a trained, Federal Agent.

Perhaps as important as the Inspection activity performed by Agents within the processing plant is the indirect function provided by their mere presence.  A processing plant is an enormous operation.  Most plants will process 1-3 million or more heads of poultry per week!  The First Processing area, which we are now discussing, is critical to the production of unadulterated poultry in the United States.  It is here that adulterated, diseased, and unwholesome poultry, unfit for human consumption is identified and disposed of or identified for further processing.  It is also here where plant-induced adulterations may be negligently or inadvertently introduced into the processing or poultry.  Common instances of plant-induced adulterations are condensation dripping from overhead pipes and equipment (think Legionaires Disease), cross contamination, negligent or careless handling, insufficient personal sanitation, insufficient or careless cleaning of equipment and facility, insufficient and falsified documentation.  All these are presently controlled by the number of Agents in the processing plant.  They are on constant vigil for any instance which varies from Federal Guidelines and Directives and plant personnel are aware of that.  Often, now, it will be the
Inspector on the line who sees a plant employee pick a chicken from the floor, throw it away, and then proceed to handle other chickens without first sanitizing his hands.  Or the Inspector may see an plant employee cleaning  the floor with a high-pressure hose and spraying the debris from the floor onto chickens being conveyed for inspection.
The variations are many but the outcome is the same, without the eyes of the Inspector to detect them, these instances could lead to adulterated product.

                                                                             THE PROPOSAL

Urged by the present Administration to cut costs, the USDA has proposed many changes which I believe will jeopardize the food safety of all Processed Poultry in the United States, if implemented.  The details of this proposed change can be found in the Federal Register, Volume 17/No. 16, titled “Modernization of Poultry Slaughter Inspection”.

Under this proposal there would be a drastic reduction in the number of Federal USDA Food Safety Inspectors.
Proposed instead is that Plant employees would take over the role of USDA Inspectors.  There would be a pre-sorting of birds prior to inspection and the four USDA Inspectors per line as discussed previously would be replaced by four plant employees.  These employees would not be under the control of a Federal Agency.  They would not receive the initial and ongoing training which current USDA Inspection Agents undergo.  As plant employees, they would be subject to intimidation in the performance of their duties.  As plant employees, they would not provide the adjunct function of observing and stopping plant-induced adulterations.  In fact, as the poultry processing industry is extremely competitive in the United States, quite the opposite could be true.  At present, a USDA Inspector has the authority to stop the line and thus the processing operation until a violation or discrepancy is corrected.  Can anyone believe that a plant employee would dare do so?  Would the “fox guarding the hen house” be anything less than appropriate here?

Under this proposal, line speeds would be increased from 140 birds per minute to 190 birds per minute with the same number of inspectors (now plant employees) performing the inspections!  While at present inspections are performed by Federal Agents who are sworn to their position and who have demonstrated a negligible turn-over rate, the inspections will now be performed by plant employees.  Having worked as an employee of a processing plant, as a supervisor, I can assure that constant turn-over is the norm.

Why don't I trust the plant?  One example sticks in my craw, especially since I am now an Inspector with the USDA.
I noted before that line speeds are federally defined as 140 birds per minute on a four-inspector line, in the inspectiion system most prevalent in the United States at present.  This has been determined by the USDA to be the maximum speed at which an Inspector can effectively examine a head of poultry and make an appropriate disposition.  Were a plant concerned about producing an unadulterated product rather than processing as many head as possible, it would be in its best interest to assure always that line speeds were maintained at 140 birds per minute.  The reality is that there is a constant battle between the online inspectors and plant supervisors to maintain that rate.  The plant is constantly trying to surreptitiously increase line speed without detection by online Inspectors.  And, from my years as an employee of a plant rather than the USDA, I assure you we did raise the line speed for no reason more noble than to have a shorter work day.  There was no consideration of how that increase in speed would affect the final product.

The number of USDA Inspectors per plan under the proposal would be halved in most instances.  There would be no more online inspectors, having been replaced by plant personnel.  There would only be one USDA inspector at the point where inspected birds leave the inspection line and enter a chilling process and that inspector would be looking at 190 birds per minute, on the exterior only, looking only for fecal matter and bruises!  That same Inspector presently is required to examine only 35 birds per minute!  Supervisory Inspectors (GS-9's) would be eliminated.  As proposed,
7 Billion head of Poultry a year would bear the USDA seal of Inspection without having been EACH physically inspected by a USDA Inspector.  This a “sampling” process, best suited to “formula” food processing facilities.  If you have ever baked a cake, you know that as long as you follow the formula, you will get the same cake every time.  Thus, if you are inspecting a cake baking facility, you can “sample” the various stages of the process to see if the “formula” is being followed.  Not so when you are inspecting constantly changing, evolving animals in a slaughter process.  One of the reasons there is a USDA veterinarian on staff at all times in Poultry Processing Plants is so he may be consulted by the Inspector when a bird presents with an unknown or new condition or disease!

Thus, the stage is set.  The USDA will reduce its Inspection Staff by almost half.  7 Billion head of Poultry  per year, which once were all individually physically inspected by Federal USDA Food Safety Inspectors will now be inspected by plant employees and only “sample”-inspected by USDA personnel.  All secondary Inspector functions which prevented plant-induced adulterations will be curtailed or greatly minimalized.  The USDA proposes that this will save the American Taxpayer $90million per year.  With 7 Billion head of Poultry slaughtered each year in the United States that calculates to be $.66/per chicken or turkey.  Is it really worth it?

There is still time to stop this but time is of the essence.  A comment period is currently in effect before implementation of this proposal.  If you agree with me that the proposed change is unacceptable direct your comments to:   WWW.regulations.gov.

I don't want the Fox watching the Hen House!  Do You?