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Industry supports the government's HACCP-based Inspection Models Project (HIMP). Consumer groups and the meat inspectors union believe it's fatally flawed, even after winning concessions in the courts. How can the U.S. government fulfill its mandate to protect the public and still create a plausibly practical, science-based inspection strategy?

By Bob Sperber
Managing Editor, Meat and Poultry Online

Contents
Industry Backs Billy
Union, appeals court, forced changes
Consumer group continues opposition
Union, too, remains opposed
Myths and facts on both sides
For more information…

So far, public comment consists largely of public foment over the HACCP-Based Inspection Models Project (HIMP), a program intended to provide a level of food safety management oversight to the traditional "poke-and-sniff" carcass inspection methods. Following a suit filed and won by the meat inspectors union, the Food Safety and Inspection Service (FSIS) of the U.S. Dept. of Agriculture is modifying its to improve meat and poultry inspection.

FSIS Administrator Tom Billy announced the changes on Aug. 31 that are intended to make the program work for all sides in the political battle going on in Washington D.C. and at plants across the nation. (Click to view the full text of: Statement by Thomas J. Billy, Administrator, Food Safety and Inspection Service, August 31, 2000.) The announcement drew the usual suspects out of the woodwork for a new, voluminous wave of wave of public comment and industry controversy.

Industry Backs Billy(Back to Top)
The most vocal and powerful support for HIMP, even with what it sees as some compromises designed to satisfy inspectors, came from the American Meat Institute . (See related article, AMI comments in support of HIMP.) This is the full text of comments from J. Partick Boyle, president of the American Meat Institute, following Tom Billy's Aug. 31 Announcement.

"USDA's new, HACCP-based inspection system is better for consumers because it puts public health protection first. It does nothing to erode inspectors' authority; rather, it makes the prevention of public health hazards the first priority of inspectors," said Patrick J. Boyle, president of the American Meat Institute.

"AMI strongly supports efforts to modernize meat and poultry inspection in order to keep pace with science and technology. Just as our plants have made many changes to keep pace with science, the government's inspection system must make similar changes," Boyle added. (See related article, AMI comments in support of HIMP .)

These statements were made on Aug. 31, the same day Thomas J. Billy, FSIS Administrator, announced changes to the program. FSIS maintains a Web page of resources for understanding its view of HIMP. Click to access this page.

Union, appeals court, forced changes(Back to Top)
In his Aug. 31 press conference, Billy outlined changes to the program, which focus on assigning one verification inspector on the line as a "final checkpoint" prior to final chilling, to conduct a visual inspection. Other inspectors will continue to move around the line and conducting microbial tests to verify meat quality. (See related article, Billy announces changes to HIMP Project.)

The model provides for four times as many food safety checks than traditional inspection, Billy said. He added that since the pilot program has been in effect, plants are performing better than they did under traditional inspection, and food safety has improved.

Despite his statements to the contrary, union meat inspectors and the U.S. Court of Appeals forced Billy's hand in making the compromise changes. The appeals court believed HIMP was illegal in allowing the industry to inspect itself, and mandated changes.

As covered earlier on this site, the inspectors believed HIMP violated the Meat and Poultry Inspection Acts and sued, winning a July appeal. At the same time, a U.S. report from the office of the U.S. Inspector General sharply criticized the U.S. meat inspection system, adding fuel to the anti-HIMP cause. (See related article, One-Two Punch Hits U.S. Meat Inspection Systems.)

Consumer group continues opposition(Back to Top)
The consumer advocacy group Public Citizen released a report Sept. 5 charging that the HACCP meat inspection system "fails to earn inspectors' seal of approval." According to The Jungle 2000, food safety in the meat industry has declined as the industry assumes more responsibility for inspection.

"Our survey warns consumers that on a good day, their meat and poultry are inspected under an industry honor system – federal inspectors check paperwork, not food, and are prohibited from removing feces and other contaminants before products are stamped with the purple USDA seal of approval," said Felicia Nestor, food safety project director with the Government Accountability Project, which is allied with Public Citizen. (Click to read Nestor's full statement of Sept. 5.)

Public Citizen based its study on a survey it sent to 2,340 out of 3,850 HAACP inspectors. Of that number, 451 responded. The report's findings indicate that under the currently proposed HIMP scenario, inspectors would spend much less time inspecting food and more time inspecting company paperwork that they have no resources to verify.

The survey was reportedly distributed by union leaders and charges "instances when [inspectors] have not taken direct action against contamination (feces, vomit, metal shards, etc.) that they observed and would have taken action under the old system." Under HACCP, inspectors are responsible for making sure that plants follow the HACCP system, but plant employees are the front line against contamination.

A whopping 87% of inspectors responding to the survey reported that company employees secretly ask for inspectors' help when they know of problems that are occurring in a plant, because they fear company retaliation, according to the union and the researchers.

Other results indicate that action is not taken against repeat violators because the department has not issued clear guidelines for government intervention, and that there is insufficient government oversight over testing procedures.

Union, too, remains opposed (Back to Top)
Since the inception of HACCP inspection almost a decade ago, union representatives have been critical of it for giving the "wolf" the key to the proverbial hen-house and—arguably, for its potential to reduce the inspector's role.

"This program was sold to the union as a consumer protection enhancement," said Arthur Hughes, president of the Northeast Council of Food Inspection Locals. "Instead, it ended up deregulating food inspection by shifting the responsibility of meat and poultry inspection to the industry."

Hughes, representing the National Joint Council of Food Inspector Locals in a statement on Sept. 5,. He HACCP and HIMP were both "a disaster for the consumer's expectation of the meat and poultry inspection program," and he invoked both the July appeals court win and the Office of the Inspector General (OIG) report cited earlier in this article.

He accused Billy of promoting HIMP even when FSIS' own data "shows the industry's performance to be out of compliance much of the time, as was the case in the Guntersvile pilot plant," referring to the Alabama plant owned by Goldkist Inc., one of 28 volunteer-plants in the HIMP pilot.

Billy nonetheless praised the industry's performance, praised the success of HIMP, and "defamed" and "ignored" the union and its assertions of the pilots' failures at Guntersville as well as at plants in Pine Mountain and Claxton, GA. At at least one plant, Billy claimed a 92% improvement over the baseline data for the zero tolerance for the visible fecal contamination food safety defect category, but the union claims the opposite: a greater-than-95% degradation in performance for controlling fecal contamination.

"Yet, the Inspector-in-Charge of that very pilot plant was quoted in an Agency statement as praising improvements in the plant's processing innovations and performance," Hughes said in his Sept. 5 statement. (Click here to read Hughes' full Sept. 5 statemen.)

Myths and facts on both sides(Back to Top)
Arguments made in July in the industry and in the pages of the media continue to be relevant to the ongoing argument over HIMP.

Billy on July 21 lashed out against what he called a "campaign of misinformation" based on organized labor's anti-HIMP claims. (See related article FSIS' Billy targets HACCP/HIMP counteroffensive at media, unions). And he released several documents, including MYTHS AND FACTS: Inaccuracies in News Articles Concerning HACCP-Based Inspection Models (HIMP)).

Public Citizen and its allied Government Accountability Project said FSIS had "transposed its myths and facts," characterizing the program as one where the wolf is asked to guard the chicken coop. Nestor called HIMP a program to turn the inspection of meat and poultry over to the industry for self-inspection, that represents a "dismantling of our food inspection system."

To better understand the opposing views, we have posted FSIS' "Myths and Facts," interspersed with responses by the opposition, as provided by Public Citizen and the Government Accountability Project:

"Myth" No.1: The federal agency overseeing food inspection is imposing new rules reclassifying as safe for human consumption animal carcasses with cancers, tumors, and open sores.

FSIS "fact:" Cancers, tumors and open sores have never been acceptable in our inspection program and they're not acceptable now under HIMP. There is no such rule.

Opposing View: According to the agency's own documents, the FSIS is, in fact, permitting meat and poultry that is contaminated by certain animal diseases and defects to enter the food supply. In 1998, FSIS circulated a paper listing those diseases and defects that would be reclassified because they do not present an immediate public health threat; in 1999 it implemented those standards in the pilot plants and has started the process to codify the lower wholesomeness standards and new "inspection" techniques.

"Myth" No.2: HIMP lowers food safety standards.

FSIS' view: Food safety standards have not been lowered. In fact, there are more food safety checks under HIMP than under traditional HACCP inspection.

"Myth" No.3: HIMP relies on scientific testing of samples rather than on traditional item-by-item scrutiny by federal inspectors.

FSIS' view: Under HIMP as under regular HACCP, a Federal inspector inspects all carcasses and makes the determination as to whether it's adulterated.

Opposing view: The second and third myths are actually facts. Under the current inspection process, every carcass has to be inspected. Under the pilot program, only a sample of the carcasses is inspected. Also, federal food inspectors are relegated to being auditors and inspectors of the industry inspectors. In a recent court ruling, a federal appeals court agreed that HIMP was an inspection system of dubious quality. The court stated: "In other words, the government believes that federal employees fulfill their statutory duties to inspect by watching others perform the task. One might as well say that umpires are pitchers because they carefully watch others throw baseballs."

"Myth" No. 4: Defective and diseased carcasses are being approved for human use under the pilot program.

FSIS' View: FSIS policy is and remains that defective and diseased carcasses are not permitted to enter commerce. Regrettably, no inspection system involving humans is foolproof. For the first time in the history of inspection, we had a third party quantify the number of defective and diseased carcasses getting past traditional slaughter inspection versus slaughter inspection under HIMP. The data clearly show a dramatic reduction in the number of defective and diseased carcasses entering commerce. (See table in Backgrounder).

Opposing view: Under the industry self-inspection program, federal meat inspectors inspect fewer than .01 percent of carcasses – all other product is judged using sampling. The sampling standards for what can be released to consumers have large tolerances for diseases and defects, and inspectors are instructed only to keep records of the levels of disease and defective meat that enters the marketplace.

"Myth" No. 5: Even if an inspector sees bad meat going down a processing line, inspectors were told not to remove it and the consumer will take care of the bad product.

FSIS' view: It is not acceptable to FSIS for consumers to receive bad product. The carcasses that are condemned in a traditional plant are condemned in a HIMP plant. The carcasses that are trimmed in a traditional plant are trimmed in a HIMP plant. Inspectors are required to defer stepping in and taking action before the plant has the opportunity to let the system work, which under HIMP, is to have company employees remove the product. However, if the company does not do it, the inspector then is required to step in and correct the situation. This may involve stopping the line.

Opposing view: The inspector is rarely at the end of the processing line. Currently, in poultry slaughtering facilities, each inspector checks approximately 30 birds per minute, which has been considered to be a high rate of speed. In some of the plants that have the pilot project, the rate has increased six-fold, to 170 chickens per minute. It is not humanly possible for proper inspection at these high rates of processing.

For more information…(Back to Top)
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