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Who’s Minding the Store: The Current State of Food Safety and How it Can Be Improved. USDA’s Current Method of Meat Non-Inspection, Called HACCP. Hazard Analysis Critical Control Point Pillsbury – 1960’s – NASA – Ready to Eat Food for Astronauts. Two Major Differences Pillsbury Versus Today.
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Who’s Minding the Store:The Current State of Food Safety and How it Can Be Improved
USDA’s Current Method of Meat Non-Inspection, Called HACCP Hazard Analysis Critical Control Point Pillsbury – 1960’s – NASA – Ready to Eat Food for Astronauts
Two Major Differences Pillsbury Versus Today Pillsbury Enjoyed a Government Cost Plus Program Today - Raw Meat Versus R.T.E.
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.
Plants must write their own HACCP plans. FSIS can’t tell plants how to write HACCP plans. Old inspection program was ORGANOLEPTIC, but HACCP is “SCIENCE” based.
“SCIENCE BASED” How did FSIS define “SCIENCE” ? Answer: Microbiological testing
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
Large plants killing thousands daily were now off the agency’s microbial radar Plants doing more business in four hours than some small plants do in a year were no longer subjected to FSIS testing
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
HACCP’s 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.
2000 OIG Audit Report “FSIS…had 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.”
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.”
2003 OIG Report on ConAgra Investigation “Although animal feces on product was repeatedly observed during production at ConAgra, USDA took no enforcement action.”
“USDA Inspected and Passed Est. # 999999” Passed indeed, frequently not inspected Mark should be changed to state: “Produced at HACCP Plant # 999999.”
“ENTERIC” bacteria Originating From Animals’ intestines By Extension: From Manure Covered Hides
D.L.F.P.N.S.P.P. Down Line, Further Processing Non-Slaughter Processing Plants Examples of DLFPNSPP:
D.L.F.P.N.S.P.P. Retail Meat Markets: Safeway, Costco, Walmart Further Processing Plants Restaurants: Sizzlers, etc… All DESTINATION Facilities!
FSIS Answer Bring harsh enforcement action against the allegedly deficient DESTINATION facility. Do NOT trace back to the originating source slaughter plant.
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.
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. D.L.F.P.N.S.P.P. Responses
Contributes to Recurring Outbreaks and Recalls • DLFPNSPP now responsible for their suppliers’ recurring sanitation problems. MISSION IMPOSSIBLE
Perverted definition of “SCIENCE” is in charge. • Big slaughter plants are in charge. Top 4 packers kill over 80% of feedlot steers and heifers. WHO IS IN CHARGE?
WHO IS NOT IN CHARGE? • Recumbent FSIS FSIS Undersight of Big Packers is Underwhelming
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. 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. 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. WHAT SHOULD BE DONE?
HACCP is Not Based in Science, But in Political Science Political Science Virtually Guarantees Continuing Outbreaks & Recalls
There may be some industries which respond well to deregulation. Meat is not one of them.
