Technical and Regulatory Update

Technical and Regulatory Update Ashley B. Peterson June 23, 2012

Agenda Goal: Feeding the World Poultry Slaughter Rule NARMS Program Ground Poultry Update Hours of Service Egg Safety Rule

Feeding the World

Global Chicken Consumption

Goal of Global Agriculture To provide safe and wholesome agricultural commodities for both domestic and international markets To meet the demands of customers by providing varietyof agricultural commodities for both domestic and international markets To provide competitively-priced (affordable)agricultural commodities for both domestic and international markets To provide agricultural commodities in a sustainable manner

Challenges Shrinking agricultural land base Shrinking population of employees for agricultural jobs Ignorance and skepticism about agriculture production Consumer groups, activists Ever-changing demands of customers and consumers Increased input costs and decreased input availability Trade barriers Legislative initiatives Concerning government regulations and pending actions

Concerning Government Regulations – Why? People unfamiliar with agricultural practices? Significant events playing roles in increased government oversight? Hallmark-Westland 2010 Egg Recall Media causing unnecessary hysteria? LFTB Arsenic in feather meal Government agencies are feeling pressure: White House, Congress, trading partners, consumer groups, customers? Necessary to keep the industry in line?

Modernization of Poultry Slaughter Inspection Rule to publish in Federal Register on 1/27/2012, 90 day comment period, extended 30 days, ended 5/29/2012 “Voluntary”rule would eliminate the existing inspection system (SIS, NELS, and NTIS). The proposed rule allows More flexibility to determine how to monitor and control food safety risks Holds establishments responsible through recordkeeping, sampling, and increased offline inspection.

Modernization of Poultry Slaughter Inspection Establishments would conduct carcass sorting before inspection. One inspector would be assigned to each line and would be stationed just before the chiller. Would allow lines speeds up to 175 birds per minute for young chickens FSIS would increase focus on offline inspections (e.g., HACCP records review) An inspector would have to be notified before a new flock is slaughtered to allow inspection of the viscera of the first 300 birds slaughtered. Viscera will not need to be presented to the inspector with the carcasses.

Modernization of Poultry Slaughter Inspection Content of pending comments from NCC: Comments contain many clarifying questions, concerns, and suggestions on implementation Sampling requirements should follow HACCP principles RTC standards should be applied at a location of the establishment’s choosing Avian Leukosis should not require whole carcass condemnation Identification of septicemic and toxemic conditions is of critical importance Line speeds should be based on an establishment’s ability to process and present birds Antimicrobials should be allowed for both online and offline reprocessing

Modernization of Poultry Slaughter Inspection • Issues moving forward • USDA is getting pressure from the inspectors union focused on worker safety as the NIOSH study has not been completed • Some poultry plants have agreed to participate • USDA getting pressure from DOL – not consulted during process • USDA and the poultry industry is getting pressure from consumer groups regarding concerns on food safety • Food and Water Watch request • USDA is requesting worker safety information from industry • Rule will not be finalized until after the November election • Implementation remains a concern – must create a level playing field for all who want to participate • Not as easy as flipping a switch *National Institute for Occupational Safety and Health

HIMP vs. Non-HIMP Plants Incidence Rate of Salmonella Positives

NARMS • National Antimicrobial Resistance Monitoring System • Monitors retail meat and poultry as well as on-farm • Funding: FDA to USDA to ARS to NARMS • Recent discussions about pulling NARMS back to FDA • Has been run through Dr. Paula Cray’s lab in Athens, GA • Parallel track has been run through Land Grant Universities • Industry has a trusting relationship with Dr. Paula Cray and if changes are made, industry trust would be lost

NARMS • Have met with FSIS, APHIS, ARS, and NARMS – all have concerns • Have met with FDA and will meet with CDC • Want to hold a joint meeting with CDC/FDA/FSIS/APHIS/ARS/NARMS and poultry industry to discuss concerns and how we think the program should be designed • FDA will hold a public meeting to gather input • Will industry participate moving forward?

Ground Poultry Update • Agency interest around ground poultry continues • Performance standards will be changed (49.9% turkey, 44.6% chicken) • Ground Poultry Subcommittee has developed three day-long sessions • Sessions aimed at bringing experts and industry together to share ideas on how to meet challenges • Live Poultry Production (July 11th) • Evaluating Parts & Interventions (early Sept) • Lotting, Labeling, & Final Product Testing (late October)

Ground Poultry Update • Live Poultry Production • Meeting will be held on July 11th in conjunction with USPoultry and NTF • Focus on common method to analyze Salmonella spp. prior to birds entering plant • Center for Science in the Public Interest (CSPI) petition included Salmonella Heidelberg, Newport, Hadar, and Typhimurium • If a common method can be identified, interested participants can potentially compare live production loads and work together to minimize these impacts

Ground Poultry Update • Specific topics include: • Current trends in live production loads • Sampling protocols used by industry • Assays available to quantify live production loads • Implications of live production results • Current and future monitoring programs • Speakers include: • Dr. Randy Singer, UMN - Dr. Doug Waltman, GA Poultry Lab • Dr. Bruce Stewart-Brown, Perdue • Dr. Bob O’Connor, Foster Farms • Dr. Bob Evans, Cargill - Dr. Beth Krushinskie, Mountaire • Dr. Carl Heeder, Pfizer - Dr. Andy Rhorer • Dr. Jennifer Rice, Neogen

Hours of Service Rule • Final Rule published December 2011, effective July 2013 • 34 hour restart provision once every 168 hours (7 days) • Two consecutive breaks required between 1am and 5am • Second driver would be needed on most long-distance hauls

Hours of Service Rule • Agricultural Exemption? Yes • 100 mile radius should include most live haul • Agriculture commodity includes livestock (poultry and egg-producing poultry) • Exemption “only during planting and harvest periods, as determined by each state” • Agriculture supplies includes livestock feed • Agriculture Exemption? No • Products coming out of the plant are not exempt and would fall under the Hours of Service Rule • Poultry industry is clearly impacted!!

Hours of Service Rule • February 14, 2012, the American Trucking Association filed paperwork with the U.S. Court of Appeals for the D.C. Circuit to initiate a legal challenge to the final rule • ATA identified several areas where the rule falls short of legal standards for regulatory changes: • Restart provision requiring that it include two consecutive periods between 1 a.m. and 5 a.m. • Limits on the frequency with which a driver may use the restart • ATA contends that several aspects of the rule are "arbitrary and capricious" and should be overturned

Hours of Service Rule • NCC involved in twoAmicus Briefs in support of ATA’s legal challenge • NCC was joined by 14 other groups including the American Bakers Association, Food Marketing Institute, National Association of Manufacturers, National Grocers Association, National Retail Federation, National Turkey Federation, National Snack Food Association, US Chamber of Commerce, and US Poultry • Final Briefs are not due to the US Court of Appeals until November 2012 • Next update meeting Monday June 25th

Egg Safety Rule FDA Prevention of Salmonella Enteritidis in Shell Eggs During Production, Storage and Transportation Proposed September 2004; Finalized September 2009 Originally did not include surplus hatching eggs Requires egg producers with 50,000 or more birds or persons who store and/or transport eggs to comply with all regulations by July 9, 2010. Egg producers with less than 50,000 birds but more than 3,000 must comply by July 9, 2012. ALL eggs going into food supply must be refrigerated at 45ºF (7.2ºC) after 36 hours of lay

Egg Safety Rule Concern to broiler industry Refrigeration – cost, time to determine if eggs will be set Hatchability – eggs stored at 45ºF will be substantially impacted Cost to dispose? Impact on landfills? Estimated $12 million impact Waste of viable protein 360 million surplus eggs -> about 1.7 billion grams of protein -> a years supply of protein for about 94,000 people Impact on breaking industry – lost jobs, increase cost of egg products Lack of trust in FSIS’ validated thermal pasteurization step Recent FSIS discussion Upcoming FDA discussion

Thank you for your attention! Questions?

Technical and Regulatory Update