Government called on to slow down meatpacking lines
The Lincoln Journal-Star reported today that the Nebraska Appleseed Center (NAC) called for government regulation that would require meatpacking companies to slow down production lines. The story highlights NAC's concerns that food safety is compromised when production lines move too quickly for line workers to properly assess risks. From the article:
Swift-moving production lines processing 400 head of cattle per hour are the major cause of worker injuries and put food safety at risk, said Milo Mumgaard, executive director of the public policy center.“The simple truth is that it all happens too fast,” he said.
Mumgaard urged Secretary of Agriculture Mike Johanns to “require the industry to slow down.”
It is Johanns’ job to “ensure our hamburgers -- and the workers who process them -- are as safe as they can be,” Mumgaard said. “Slowing down the line is a great place to start.”
Numerous perjorative terms have been used to criticize me since I went public in 2002 when I exposed inadequate USDA meat inspection policies. Whistleblower, reactionary, consumer activist, communist, right wing radical, poor loser, ad infinitum. Some of those titles I wear proudly. I unabashedly admit that I believe that meaningful reforms must be implemented by USDA in the meat inspection and production system.
However, I feel that any attempt to improve food safety by imposing maximum speeds on meat production lines is inappropriate, unjustified, but especially, misdirected. It is theoretically possible that well managed meat plants which utilize a plethora of scientifically advanced multiple hurdle intervention steps could actually INCREASE chain speeds, and still consistently produce safe food. The real issue here is not chain speed, but food safety, and they are not necessarily directly related.
How can we make a scientifically correct determination of the efficacy of individual plant's ability to produce safe food? How can we make a defensible correlation between individual plant's chain speed and wholesomeness of food? Answer: microbiological testing!
However, my perception is that the big slaughter facilities and USDA are both opposed to any meaningful incidence of microbial testing, for fear of finding problems. USDA also knows that if a substantial number of lab positives occur, that the agency's involvement under the HACCP umbrella will be exposed to be inappropriately inadequate. Numerous agency insiders readily admit that when HACCP was introduced, the agency's primary focus changed from safe food to reducing agency liability. Food borne outbreaks and the detection of contaminated meat constitute a black eye to USDA's public image, and must be avoided at all costs. Therefore, testing has become an enemy, rather than an ally.
USDA itself publicly stated that its role under the HACCP umbrella was to be "Hands Off", while the plants are to "police themselves". Some industries can safely function in a deregulated environment, but meat production is not one of them.
If maximum chain speeds were legislatively mandated to reduce by 25 % for example, the same plants which currently lack management committment to safe food would continue to produce the same amount of contaminated food as it did prior to the forced reduction. Simultaneously, plant management who are proactively committed to continual improvement in sanitary production practices (and there are lots of these) could possibly increase chain speeds and still produce safe food.
The primary regulatory and management tool which could allow changes in chain speed is pathogen testing. Some plants will fight increased testing to the death, while some will embrace additional testing because they are legitimately confident in their operations. USDA will forever fight a SUBSTANTIAL increase in testing, allegedly for budgetary reasons. In other words, the agency can't afford to conduct a large degree of testing, but consumers can afford to get sick from eating USDA inspected AND PASSED! meat.
Changes in microbial testing must incorporate the following changes, at bare minimum. This is only a partial, preliminary list to consider.
1. USDA must conduct meaningful testing of carcasses, trim, boxed beef, and ground beef at plants of all sizes, with no exceptions. Frequency of testing must be based on volume of production, as well as the plant's historical microbial test results.
2. Testing must be for generic as well as specific pathogen determination.
3. All testing, whether collected by the plant or USDA, must be shared with each other on a real-time basis.
4. All testing must be fully concluded. In other words, any "potential positive" or "presumptive positive" test results must be subjected to additional testing to determine confirmed results. The mere determination of potential or presumptive results prematurely truncates the potential benefits of the microbial testing which should be fully completed.
5. All testing must mandate copious documentation of all evidence related to the TRUE ORIGIN of meat which is being sampled. All evidence gathering must be accomplished at the time of sample collection, and not delayed for several days. Intentional obfuscation of the true origin of the meat can no longer be allowed in a truly "science based" meat inspection system. Neither the agency nor the industry can be allowed to place arbitrary restrictions on evidence gathering.......no stone may be left unturned.
6. The Bioterrorism Act of 2002 requires that all entities involved in the production, distribution or sale of food products in the U.S. must be able to track their products - and all components thereof - two steps back and one step forward in the supply chain. Incomplete sampling/testing protocol which does not comply with these regulations are in violation of the Bioterrorism Act.
7. Tracebacks to the TRUE ORIGIN of contamination must be science based and expeditious if consumers are to be protected. Tracebacks will be accomplished only if thorough scientific documentation is conducted on a real time basis.
8. All test results from both USDA testing as well as plant testing must be available to the citizenry via the Freedom of Information Act.
As other entities contribute their ideas, this list may grow dramatically.
If the above eight suggestions were mandated, it is easy to see how both the USDA and the industry would perceive the need to quickly detect problems and immediately resolve them. Lab test results would provide indisputable evidence of a plant's ability (or failure) to produce safe food. The results of pathogen testing would remove the issue of chain speed from its current subjective and biased personal opinions to the scientific arena of irrefutable and undeniable evidence.
Our free enterprise system must allow well-managed companies to maximize their efficiency and chain speeds when lab tests prove their ability to produce safe food. Such companies must be rewarded for their ambitious committment to public health imperatives. Likewise, free enterprise also allows for ill-managed companies to fail, under USDA's watchful eye. Establishing artificial production line speeds absent microbial test results is unjustified, unscientific, and counter-intuitive. It is also anathema to our free enterprise, capitalistic system which provides rewards to excellence in the marketplace. It also dumbs down baseline requirements, forcing all plants to do only whatever is required to meet this artificial standard.
Let's empower and liberate enlightened plant management (and there are many) to utilize their R & D findings and continually improve their sanitary production of safe food. Anyone denying the meat industry this right might be the ones classified as communist.
USDA's current rallying call is "Educate before you Regulate". It could also be "Liberate before you Regulate".
This could be a win-win situation. Artificial standards could very well constitute a lose-lose environment.
Let's allow the industry to operate in a transparent environment, and allow true leaders and their companies to be rewarded for excellency.
I am not addressing the relationship between chain speed and employee safety. Where there is a will, there is a way, and this problem can likewise be resolved, perhaps with the placement of additional workers on the line.
Elsa Murano was correct when she said "There is no such thing as risk-free raw meat". No one can deny that some pathogens will slip through the cracks, especially at the large volume plants. The problem then becomes how the agency will respond to lab positives? Should the detection of one lab positive force the agency to close a plant? No. If the same plant continually experiences ongoing lab positives and is unwilling or unable to implement effective corrective action, should the agency remove its inspection force? Very possibly yes. The gray area resides in the area between these two examples.
The establishment of an arbitrary maximum of lab positives is not the answer, because each plant and situation is different. We must anticipate that more problems will slip through the cracks at large plants than at small plants, merely because of the volume of production. Proper resolution of this potential dilemma requires professionalism and a committment to public health on part of both the USDA and plant management. Our meat production/inspection system should no longer tolerate rebellious plant management who are unwilling to place public health interests over corporate profits, nor power-hungry, overly zealous regulators whose macabre career advancement is predicated on abusing and hagriding plant owners. Both entities must be accountable for their actions. Common sense must prevail, in the midst of a willingness to sit down and reason together.
John W. Munsell
President, Montana Quality Foods & Processing
Manager, Foundation for Accountability in Regulatory Enforcement (FARE)
Miles City, MT
406-234-1877
406-853-1878 Cell
406-234-0265 Fax
pdoggy@midrivers.com