04/18/2012 08:05 am ET Updated Jun 17, 2012

Mr. Almanza: You Missed Some Key Facts

Last Friday, Alfred Almanza, Administrator for U.S. Department of Agriculture's Food Safety and Inspection Service (FSIS), wrote a post titled "Setting the Record Straight on the Proposed Chicken Inspection Policy." Mr. Almanza talked a lot about facts in his post, but unfortunately he left out many important ones about what exactly this new inspection model would -- and would not -- do.

Food & Water Watch is not a "Johnny-come-lately" to the food safety program at the USDA. Our staff has participated in the Safe Food Coalition -- a group of consumer advocacy organizations, food borne illness victims representatives, and labor organizations -- since 2000. The Safe Food Coalition meets with officials from USDA's Office of Food Safety and the top management of FSIS on a monthly basis. We have also commented on numerous proposed rules over the years that would modify food safety policies for meat and poultry products.

Food & Water Watch is opposed to the proposed poultry inspection rule for several reasons.

First, it is designed to privatize inspection by turning critical inspection functions over to poultry company employees and reduce the number of government inspectors assigned to the slaughter facilities. In poultry slaughter facilities where conventional inspection is conducted, each USDA inspector assigned to the slaughter line is responsible for evaluating carcasses for food safety and wholesomeness defects. Each USDA inspector is expected to evaluate up to 35 birds per minute in a conventional plant. There could be as many as four USDA inspectors assigned to each slaughter line.

In HIMP plants, there is only one inspector assigned to each slaughter line. Inspectors have told us that some plants in the pilot program have assembly lines where 200 birds whiz by per minute. In pilot plants, company employees check carcasses based on certain food safety and wholesomeness regulatory standards that, in conventional plants, USDA inspectors traditionally do. Instead of working on the slaughter line, a USDA verification inspector checks on the work of the company employees by sampling up to 80 carcasses in an eight-hour shift.

In an analysis of USDA inspection records from 14 poultry plants participating in the pilot program in 2011, Food & Water Watch found that company employees missed food safety and wholesomeness defects at an alarming high rate -- as high as 99 percent in one turkey slaughter plant. If this is the error rate based on an 80-carcass sample per shift, how much poultry is making its way to consumers' homes with defects that have not been checked? Furthermore, the Government Accountability Project has secured affidavits from three USDA inspectors who have worked in pilot plants who report that because of excessive line speeds, lack of training and employer intimidation, company employees miss many food safety and wholesomeness issues.

Second, line speeds will be allowed to increase to 175 birds per minute in all poultry slaughter facilities under the proposed rule. Proper inspection cannot occur at these excessive line speeds whether conducted by a trained USDA inspector or a company employee. The agency readily admits that the poultry industry will stand to earn an additional $260 million per year by removing the cap on line speeds. The agency believes that the use of a chemical cocktail at the end of the slaughter process is enough to deal with any food safety issues that might be missed by company employees or the one USDA inspector assigned to the slaughter line. This proposed rule furthers the industrialization of the food supply and needs to be rejected.

Third, the proposed rule does not require company employees to receive any training or prove proficiency in performing duties normally performed by government inspectors who are required to take training before they are assigned to the slaughter line. The proposed rule indicates that the agency will issue a "guidance" document to the industry on how training should be conducted to its employees, but lack of training will not preclude a company employee from performing inspection responsibilities under the proposed rule.

Fourth, increasing line speeds will most likely have an impact on worker safety in these plants. The Government Accountability Office has recommended independent research to determine whether high line speeds lead to an increased incidence of worker injuries. While the narrative to the proposed rule does mention a study to be conducted by the National Institute of Occupational Safety and Health to determine whether increased line speeds have adverse effects on worker health and safety, the agency is not waiting for that study to be completed before proceeding with the implementation of the proposed rule. I strongly believe that the agency should wait until the results of that study are published before moving forward with this new inspection model.

Fifth, the agency contends that implementation of the proposed rule will prevent 5,200 foodborne illnesses. The risk assessment accompanying the proposed rule admits that there is no evidence that the new inspection model will reduce the incidence of campylobacter that is a major source of food borne illness attributed to poultry. The agency's own evaluation of the HIMP project concedes that the salmonella rates in comparably-sized plants not participating in HIMP had lower salmonella rates in 2009 and 2010. Instead of going to Congress to request the authority to enforce pathogen reduction standards, the agency has chosen instead to deregulate. Consequently, I question the agency's assertion about the public health impact of the proposed rule.

What is even more galling about the proposed rule is that the agency failed to conduct any meaningful public meetings to discuss this very complicated proposed rule prior to its publication in the Federal Register or prior to the President incorporating it into his proposed FY 2013 budget. So much for the Administration that promised transparency.

Let's be clear. This proposal is more about cost cutting than modernization and it needs to be withdrawn. Consumers across the country and the world who eat U.S.-processed poultry deserve better.