Poultry Inspection Modernization
The U.S. Department of Agriculture (USDA) has been exploring the modernization of its poultry inspection system for two decades – a system that was originally developed in the 1950s. USDA’s Food Safety and Inspection Service in 1997 reported that studies by the National Academy of Sciences, the General Accounting Office and USDA “have established the need for fundamental change in the USDA meat and poultry inspection program.”
The U.S. Department of Agriculture (USDA) has been exploring the modernization of its poultry inspection system for two decades – a system that was originally developed in the 1950s. USDA’s Food Safety and Inspection Service (FSIS) in 1997 reported that studies by the National Academy of Sciences, the General Accounting Office and USDA “have established the need for fundamental change in the USDA meat and poultry inspection program.”
A pilot program was put in place in 1997 in 20 chicken plants, called the HACCP-Based Inspection Models Project, or HIMP. The goal of HIMP was to test an alternative food safety inspection system that sought to decrease pathogen contamination in poultry by refocusing FSIS inspector activities from low-value food safety activities such as carcass sorting to high-value food safety activities such as offline food safety verification tasks. It has since been studied, debated and reviewed in depth for almost 20 years to assure its effectiveness as to how best modernize chicken inspection while improving food safety and protecting workers.
As part of the new inspection system, plants were permitted to operate their evisceration line speeds at 175 birds per minute, versus 140 birds per minute in traditional inspection systems. The evisceration line is the part of the plant where the birds’ organs are removed, the carcass is cleaned and inspected. This part of the process is highly automated and it is not the part of the plant where the birds are killed, or where workers cut up the chicken for packaging.
Because of the success of the pilot program over a 13 year period, USDA in 2012 proposed to give more chicken plants the option of operating under the new system, which USDA now calls the New Poultry Inspection System (NPIS). Those plants that opted in to NPIS would be allowed to operate at 175 bpm under the proposed rule.
In 2014, FSIS published the final NPIS regulation, based in large part on HIMP. NPIS incorporated many of HIMP’s components, and in proposing the rule, FSIS explained that “permitting FSIS to conduct more food safety related offline inspection activities, will allow for better use of FSIS inspection resources, and will lead to industry innovations in operations and processing.” This was consistent with HIMP’s original goal.
However, despite FSIS’s findings that HIMP plants could maintain food safety standards using line speeds of up to 175 bpm, the final rule arbitrarily limited participating establishments’ line speeds to 140 bpm for chickens without meaningful justification. The arbitrarily limited line speeds have deterred many establishments from opting into the NPIS system, and significantly fewer plants opted into the program than FSIS anticipated.
Ultimately, with either inspection system—traditional poultry inspection or NPIS—and with any line speed, the end result is the same: rigorous food safety standards are applied to all chicken products and these products must meet or exceed these safety standards set forth by USDA in order to reach consumers.
Myths and Facts about the Modernization of Poultry Inspection System
Here’s a look at separating myths versus facts about line speeds and what the modernized poultry inspection system means for the chicken industry, for worker safety, and the safety of chicken products.
For the Chicken Industry:
Myth: The proposed rule would “privatize” chicken inspection. Fact: The chicken industry remains one of the most heavily regulated industries in the United States. Under the modernization and in the HIMP pilot program, USDA remains in its oversight role and USDA inspectors will still be in every plant, looking at each carcass to ensure the safety of chicken products and providing them with the USDA seal of approval for wholesomeness. The proportion of them doing critical food safety-related tasks will actually increase. Specifically, a USDA poultry inspector will be stationed further down the evisceration line and just before the chiller to ensure that birds have been properly processed. The facility will now be in charge of its own quality assurance program by training sorters to remove any quality defects from carcasses thereby allowing FSIS inspectors to focus more on food safety-related parameters and not visible defects.
For our Workforce
Myth: The proposed rule is likely to prove harmful for worker safety. Fact: There is no evidence in the pilot program over the past 18 years to substantiate the assertion that increased line speeds will increase injuries. In fact, the safety record in all poultry plants has improved dramatically. Bureau of Labor Statistics’ data show the industry has had an 82 percent decrease in its worker injury and illness rates since 1994, falling to 4.2 cases per 100 full-time workers in 2016 from 22.7 in 1994.
The total recordable poultry processing illness and injury rate of 4.2 is at an all-time low and lower than the rate of 4.7 for the entire food manufacturing sector. To put the rate of 4.2 into perspective, it is lower than the rate for similar animal slaughter industries (6.9), soft drink manufacturing (7.4), cheese manufacturing (4.8) and bakeries and tortilla manufacturing (4.3). Furthermore the more than five-fold decrease in injury rates in the poultry industry from 1994-2015 coincided with a period of substantial increases in line speeds, bird size, and automation. Technological improvements in processing tend to correspond to safer workplaces.
In addition, FSIS accounts for worker safety in the current line speed regulation by including a provision requiring plants to comply with federal worker safety requirements. The provision makes clear that all plants, regardless of the line speed at which they operate, must provide workers with a workplace free from recognized hazards that are likely to cause death or serious physical harm and to comply with all Occupational Safety and Health Administration (OSHA) standards.
Myth: The proposed rule calls for less federal oversight, effectively incentivizing companies to cheat federal rules and doing so would endanger workers.
Fact: Each establishment participating in NPIS is required to submit an annual attestation to FSIS stating that the establishment maintains a program to monitor and document any work-related conditions of establishment workers. This program must include the following elements: a) policies to encourage early reporting of symptoms of injuries and illnesses, and assurance that the plant has no policies or programs in place that would discourage the reporting of injuries and illnesses; (b) notification to employees of the nature and early symptoms of occupational illnesses and injuries; and (c) monitoring of injury and illness logs, as well as nurse or medical office logs, workers’ compensation data, and any other injury or illness information available. The proposed rule would not affect any of this attestation requirement.
Myth: With line speed increases, poultry plant workers will be forced to work with knives and other sharp objects at a frenetic, chaotic pace, with little to no way to slow down the process.
Fact: The line speed increases only pertain to the middle part of the production line, known as the evisceration line. The evisceration line is the part of the plant where the birds’ organs are removed, the carcass is cleaned and inspected. This part of the process is highly automated and it is not the part of the plant where the birds are killed, or where workers cut up the chicken for packaging.
FSIS itself noted in the preamble to the NPIS proposed rule that there is an important distinction between line speed and work pace. A worker’s exposure to musculoskeletal disorder (MSD) risk factors, such as repetitive or prolonged hand activity, is affected by his or her work pace. Work pace, in turn, is the product of many factors, one of which is line speed. Other factors affecting work pace include staffing levels, plant layout and product flow, factors which FSIS does not regulate but that establishments may adjust as appropriate to ensure that line speeds do not jeopardize worker safety. In addition, FSIS inspectors are required to slow down or stop the line if process control is not maintained. Further, USDA has a memorandum of understanding (MOU) with the Occupational Safety and Health Administration (OSHA) requiring both OSHA and FSIS inspectors to confidentially report workplace hazards affecting plant employees.
Myth: Studies that looked at traditional poultry plants where line speeds were 70 to 91 birds per minute, found that 59 percent of workers had definite or possible carpal tunnel syndrome (CTS). Modernization would increase the percentage of workers with CTS and other repetitive motion injuries.
Fact: These studies actually focused on plant activities outside of the slaughtering process and thus are unrelated to the activities covered in the proposed rule. In terms of worker safety, the part of the line (evisceration) that deals with the speed increase is almost entirely automated. Second processing lines, where workers debone and cut up chicken parts, would remain one-fifth of the speed as the evisceration line. At the same time the industry has been increasing line speeds over the past 20 years, the poultry industry’ injury and illness rate has fallen 82 percent, according to the Department of Labor. Furthermore, much of the process under which line speeds would increase due to waivers requested by NCC in the NPIS is automated, therefore would have little effect on workers’ repetitive motion injuries.
For Food Safety
Myth: The proposal would likely increase the rates of ‘defects’ for birds going down the processing line, allowing each plant to decide the appropriate level of ‘defects,’ which can include blisters, bruises, scabs, feathers, bile, ingesta, and a variety of poultry-specific diseases.
Fact: Science-based evidence demonstrates that there is no correlation between visible defects and food-borne illness. Additionally, under the proposed rule, industry must comply with current Ready-to-Cook regulatory standards, which addresses ‘defects’ for poultry products. From a common sense viewpoint, a company would harm the marketability and demand for their product if they allowed visible ‘defects’ on their products. Also, though it is left unspecified how industry is to go about complying with performance standards on bird defects, it is ultimately FSIS that establishes and enforces those performance standards. Therefore, the result is the same in either case, but it takes less agency resources under NPIS to achieve the same result in terms of bird ‘defects.’
Myth: A single government inspector would have only one-third of a second to examine each chicken carcass for food safety and other problems.
Fact: You can’t see Salmonella no matter how fast or slow the line speed moves. A person cannot visually inspect a bird and point out which ones have Salmonella on them or not. Visual inspection is only one of several other scientifically-validated measures to protect food from contamination and to reduce bacteria levels at dozens of different points during the entire production process. While visual inspection will remain a vital part of the inspection process, it will be coupled with additional pathogen detection capabilities performed offline. The number of these offline inspections has quadrupled under NPIS, according to an October 2017 presentation released by FSIS. Ultimately, no less visual inspection will occur under NPIS than occurred under the traditional inspection system. By having industry employees perform more cosmetic inspection (done by visual inspection), FSIS inspectors can be used at the end of the line as a final judge and off-line doing many other tasks to ensure a safe and wholesome chicken product.
Myth: When birds arrive at the inspector, they’re often covered in fecal matter or were improperly killed, leading to greater risk of diseases like septicemia or toxemia.
Fact: The data show that as a result of industry practices, such as carcass sorting activities, very few adulterated poultry carcasses are presented to inspectors stationed at the end of the slaughter line in HIMP establishments, according to a 2016 Government Accountability Office (GAO) report. The number of carcasses with septicemia, toxemia, or fecal material that arrive at the online carcass inspector location is very low (less than 8 carcasses with infectious conditions per million carcasses processed and less than 0.8 carcasses with fecal contamination per 1,000 carcasses). These levels are less than those found in non-HIMP plants. The carcass inspector further reduces the number of carcasses with septicemia/toxemia or visible fecal contamination, according to the data. For septicemia/toxemia, the carcass inspector detected affected carcasses at a rate of 0.000004% or 4 per 100 million carcasses slaughtered. For visible fecal contamination, the CI detected affected carcasses at a rate of 0.0009% or 9 per million carcasses slaughtered. These data demonstrate that carcasses affected with these diseases and fecal contamination are detected and condemned in HIMP establishments before entering the chiller. This data shows that the online inspectors in HIMP plants are performing in a manner that enables them to properly inspect each carcass and, therefore, make the necessary inspection to adequately identify adulterated carcasses.
Myth: With less government inspectors on the line, rates of food-borne diseases like Salmonella and Campylobacter will increase.
Fact: Under the new inspection system, rates of these diseases have fallen by half of traditional inspection rates. According to an October 2017 presentation released by FSIS providing updated NPIS food safety information from data on 176 chicken and 41 turkey slaughter plants, Salmonella positive rates in chicken fell to 1.56 percent from 3.01 percent. In HIMP-converted plants, this rate fell to 2.9 percent from 8.9 percent for chicken carcasses, while the rate for chicken parts remained basically flat. These data show that the prevalence of these diseases decreases when more offline inspection is done by FSIS, while visual inspection to detect bird ‘defects’ can be done by industry personnel. In this arrangement, precious agency resources are stewarded more wisely all while ensuring a safer and more wholesome product for the American public.
“A landmark study demonstrated that plants with higher line speeds met or exceeded FSIS food safety standards,” wrote Doug Collins, Congressman from Georgia’s Ninth District, for The Hill in October of 2017. “Among other successes, FSIS (that is, the government inspectors) saw the percentages of unacceptable samples for E. coli fall from 3.9 percent to 0.7 percent while the plants were able to operate at increased speeds. The rates of Salmonella and Campylobacter bacteria further show that these have food safety outcomes as good as or better than traditionally-run plants, whose line speeds are capped at an arbitrary 140 bpm.”
USDA Poultry Slaughter Inspection Rule Timeline of Events
1957 – Regulations for poultry slaughter inspection adopted.
1985 – – National Academy of Sciences report, “Meat and Poultry Inspection: The Scientific Basis of the Nation’s Program,” recommended that USDA’s Food Safety and Inspection Service (FSIS) focus on pathogenic organisms and require that all official establishments operate under a Hazard Analysis and Critical Control Point (HACCP) system for control of pathogens and other safety hazards.
1987 – Second National Academy of Sciences report, “Poultry Inspection: The Basis for a Risk Assessment Approach,” concluded, “that the present system of inspection does very little to protect the public against microbial hazards in young chickens.”
1994 – Government Accountability Office report, “Meat Safety: Inspection System’s Ability to Detect Harmful Bacteria Remains Limited,” stated the resource problem clearly. “Labor-intensive inspection procedures and inflexible inspection frequencies drain resources that could be put to better use in a risk-based system. To better protect the public from foodborne illnesses, FSIS must move to a modern, scientific, risk-based inspection system.”
1996 – FSIS Issues Pathogen Reduction and Hazard Analysis and Critical Control Point (HACCP) Rule. HACCP is a method of identifying potential problem areas and maintaining written plans for managing the risks they present.
1997 – FSIS Proposes HACCP-Based Inspection Model Project (HIMP)
1999 – HIMP goes into effect in 20 chicken processing plants, five turkey plants and one pork plant
2012 – January – After collecting data for 13 years, FSIS proposes a modernized Poultry Slaughter Inspection system, a voluntary expansion of the HIMP pilot.
2012 – April – FSIS extends comment period on proposed rule
2012 – May 29 – Comment period closes
2014 – July 10 – USDA sends final rule to OMB for review
2014 – July 31 – OMB clears rule and sends final to USDA.
2014 – August 21 – USDA publishes final rule in the Federal Register
2017 – September 1 — National Chicken Council (NCC) petitioned USDA-FSIS to implement a waiver system to permit young chicken slaughter establishments participating in the NPIS and the Salmonella Initiative Program (SIP) to operate without the line speed limitations imposed under the NPIS.
2017 – October 13 – USDA-FSIS announced a 60-day period for the public to comment on the chicken industry’s petition to waive line speed restrictions under the New Poultry Inspection System (NPIS).
2017 – December 13 – 60 day USDA-FSIS comment period closes.