Who

1
Whos Minding the StoreThe Current State of
Food Safety and How it Can Be Improved
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USDAs Current Method of Meat Non-Inspection,
Called HACCP

• Hazard Analysis Critical Control Point
• Pillsbury 1960s NASA Ready to Eat Food for
  Astronauts

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Two Major Differences Pillsbury Versus Today

• Pillsbury Enjoyed a Government Cost Plus Program
• Today - Raw Meat Versus R.T.E.

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HACCP Implemented Subsequent to J.I.T.B. Outbreak
in 1993
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• FSIS role under HACCP would be HANDS OFF
• FSIS will no longer police the industry. Plants
  will have to police themselves.
• FSIS will disband its previous command and
  control.

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• Plants must write their own HACCP plans. FSIS
  cant tell plants how to write HACCP plans.
• Old inspection program was ORGANOLEPTIC, but
  HACCP is SCIENCE based.

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SCIENCE BASED

• How did FSIS define SCIENCE ?
• Answer Microbiological testing

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• January 26th, 1998 Large Plants Implemented
  HACCP
• February 1st, 1998 FSIS Issued Directive
  10,010.1, exempted qualified large slaughter
  plants from agency conducted microbial sampling

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• Large plants killing thousands daily were now off
  the agencys microbial radar
• Plants doing more business in four hours than
  some small plants do in a year were no longer
  subjected to FSIS testing

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Greatly Increased Scrutiny at Small Plants

• NOT production lines
• But on Paperwork
• Daily Records
• Written HACCP Plans
• FSIS primary focus is on paperwork inspection,
  not meat inspection

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HACCPs Beauty to FSIS

• Agency has Semi-Retired
• Delicate Issues at Big Plants?
• No Problem! HANDS OFF!
• Agency cannot be held even partially liable for
  contaminated meat it never inspected.

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2000 OIG Audit Report

• FSIShad reduced its oversight beyond what was
  prudent and necessary for the protection of the
  consumer.
• Although FSIS inspectors were aware of these
  HACCP deficiencies, they did not take
  corrective action because of uncertainties of
  their authority to do so.

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2003 OIG Report on ConAgra Investigation

• USDA inspectors followed policies that
  effectively limited the documents the inspectors
  could review and the enforcement actions they
  were allowed to take.
• USDA had reduced its oversight short of what was
  prudent and necessary for the protection of the
  consumer.

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2003 OIG Report on ConAgra Investigation

• Although animal feces on product was repeatedly
  observed during production at ConAgra, USDA took
  no enforcement action.

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USDA Inspected and Passed Est. 999999

• Passed indeed, frequently not inspected
• Mark should be changed to state Produced at
  HACCP Plant 999999.

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ENTERIC bacteria

• Originating From Animals intestines
• By Extension From Manure Covered Hides

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D.L.F.P.N.S.P.P.

• Down Line, Further Processing Non-Slaughter
  Processing Plants
• Examples of DLFPNSPP

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D.L.F.P.N.S.P.P.

• Retail Meat Markets Safeway, Costco, Walmart
• Further Processing Plants
• Restaurants Sizzlers, etc
• All DESTINATION Facilities!

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FSIS Answer

• Bring harsh enforcement action against the
  allegedly deficient DESTINATION facility.
• Do NOT trace back to the originating source
  slaughter plant.

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When an inspector collects a ground beef sample
for microbial analysis at a USDA lab, the
inspector is not allowed to document the source
slaughter house origin of the meat being sampled
on the day of sample collection.
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D.L.F.P.N.S.P.P. Responses

• FSIS shows little, if ANY, interest in tracing
  back to the slaughter house origin.
• FSIS places all liability for the contaminated
  meat on the victimized DLFPNSPP.
• If the DLFPNSPP is federally inspected, it must
  describe how recurrences will be prevented.

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MISSION IMPOSSIBLE

• Contributes to Recurring Outbreaks and Recalls
• DLFPNSPP now responsible for their suppliers
  recurring sanitation problems.

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WHO IS IN CHARGE?

• Perverted definition of SCIENCE is in charge.
• Big slaughter plants are in charge. Top 4 packers
  kill over 80 of feedlot steers and heifers.

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WHO IS NOT IN CHARGE?

• Recumbent FSIS
• FSIS Undersight of Big Packers is Underwhelming

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WHAT SHOULD BE DONE?

• Remove Meat Inspection from FSIS.
• Create a New Agency in Charge of ALL Food
  Inspection.
• Inspection Consisting of organoleptic
  inspection, coupled with a dramatic increase in
  government testing.

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WHAT SHOULD BE DONE?

• Plants Should Still Write HACCP Plans. Good
  Management Tool.
• Tracebacks to the Origin Must Be Mandated
  Whenever Possible.
• E. Coli Must Be Declared an Adulterant Wherever
  it is Found, Starting with the Slaughter House
  Floor.

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WHAT SHOULD BE DONE?

• New Agency Must Be HANDS ON.
• National Standards Must Be Re-enacted to Return
  sanity to the Meat Inspection / Production
  Environment.
• Congress Must Provide Increased Funding for More
  Inspectors More Microbial Testing.

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HACCP is Not Based in Science, But in Political
Science
Political Science Virtually Guarantees Continuing
Outbreaks Recalls
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There may be some industries which respond well
to deregulation.
Meat is not one of them.
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FORCE THE SOURCE