Within a year after posting this Notice, a USDA veterinarian who shares my opinions about the need for changes in meat inspection policies, attended a USDA-conducted management training session at Texas A & M. One of the trainers was an agency official from Washington, D.C. During a coffee break, the vet privately asked the agency official if the Notice was issued because of what had transpired at Montana Quality Foods from January - June 2002. The official responded affirmatively. Why do I bring this up?

Frankly, the USDA coverup of the true origin of E.coli-contaminated meat at my plant was exposed on NBC Nightly News with Tom Brokaw on 8-1-02. While the agency did its best to close me down for four months, I aggressively opposed their unethical actions and continued to demand that they implement policies which would enable, in fact require, trace backs to the origin. They steadfastly refused.

Now that the cat was out of the bag, the agency issued Notice 44-02 to portray FSIS as the premier public health defender in the nation. Because of the national scope of outbreaks in 2002, plants felt obligated to admit that E.coli was likely to appear in their plants, which forced them to devise protocol to mitigate such possibilities. The result was primarily the formulation of additional paperwork documents which ostensibly would "prevent" previously contaminated meat from entering their facilities. For example, plants commenced requiring their suppliers to provide annual letters of certification which were boiler plate, generic statements which made statements like:

"We are in full compliance with our HACCP plans"

"We fully meet all our CCP's"

"We test 100 % of our lots of trimmings"

"Independent 3rd party entities have validated that our HACCP plans are effective in consistently producing safe meat"

"All ground beef and boneless trimmings originated from production lots of trim which were tested for E.coli, and tested negative"

Etc, etc. Most of the manufacturers' annual certifications made the same or similar statements.

Since testing continued to reveal the ongoing production of contaminated meat, the agency responded by mandating that downline further processing plants have much more thorough supplier certifications on file.........while not elucidating exactly what the new certifications should say, causing nationwide confusion and unnecessary animosity between FSIS field force and company management, neither of whom had been provided a road map about what the agency was expecting. It has remained a paper chase to this day, absent clear guidelines.

Simultaneously, the large slaughter plants have implemented new pathogen intervention steps, which HAD seemed to be reducing the incidence of contaminated meat. Please know that the primary recommendation made by FSIS was merely their requirement that every plant reassess their HACCP plans. The fact the agency does not explain this fact is that the agency's open-ended statement provides the appearance, or perception, that the agency has unilaterally mandated numerous new requirements on the industry, which is not true.

The agency's "strong and persistent enforcement of inspection laws" as quoted above from Mike Johanns is a ruse. The agency boldly monitors activities at small plants, and have verbally mandated a minimum quota of NR's (Noncompliance Reports) at the small plants, while further insulating the large slaughter plants from any meaningful enforcement oversight or liability for producing pathogen-laced meat.

At the risk of being redundent, the frequency of outbreaks and recalls will most likely increase as long as the agency refuses to place accountability at the true source of contamination. USDA's half hazard investigative efforts are consistently and prematurely truncated at the downline further processing plants. Such establishments lack the financial wherewithal or political clout to engage the agency in protracted litigation while defending their rights. Therefore, small plants resign themselves to the inevitable enforcement actions, and do whatever the agency "suggests" (actually demands) just to keep the facility up and running. I finally realized I was living a lie, which is that HACCP is a "science based" meat production system. While I successfully jettisoned personal ownership of my plant, the vast majority of plant owners have clung to their marginal operations, hoping beyond hope that USDA will eventually implement common sense and ethical policies.

Now, the agency is running out of options, and are grasping at Risk Based Inspection, which may never come on line. The last thing the agency wants to do is trace back to the origin, because such evidence would require the agency to engage the big plants with effective enforcement actions.

John W. Munsell