Why HIMP really is a game-changer
A recurring question I receive from clients, former colleagues, the public, family and associates is, “HIMP, what’s the big deal with it?” Then it seems everyone has an opinion, most based on what they have “heard” in the media.
So what is HIMP anyway? I asked an associate, Dr. William James of William James & Associates, that question. James was one of the original drafters of the HIMP rules on the FSIS side of the table a number of years ago. Here is what he had to say:
“When I began my career as an FSIS veterinarian in 1983, inspection was primarily ‘organoleptic’ — which just means using our senses of sight, smell and feel to detect abnormalities in the carcasses, heads and viscera of animals. That was fine in 1906, when Congress passed the Federal Meat Inspection Act, but over a century later, it’s professional malpractice for FSIS to continue to rely on organoleptic inspection as the primary approach to inspection.
Today we have a better understanding of the principal causes of foodborne illnesses from meat — bacterial pathogens such as Salmonella and E. coli. But while pathogens are the biggest threat in meat, bacteria are invisible to the naked eye. So what should be done?
In 1996, FSIS published a regulation that called for control of food production processes. The Hazard Analysis and Critical Control Point (HACCP) rule required the industry to implement production and processing systems to prevent and control foodborne hazards, including bacterial pathogens.
Having required companies to focus on what’s most important to food safety, it’s now time for FSIS to do the same. With the Hazard-based Inspection Models Project (HIMP), FSIS is catching up. HIMP focuses the attention of inspection on the same sources of foodborne illnesses we expected companies to focus on when we required the implementation of HACCP. With publication of the final rule, Modernization of Poultry Slaughter Inspection, in August of last year, HIMP in poultry (called the New Poultry Inspection System) is permitted for use in all poultry plants. Now it’s time for swine.
Don’t get me wrong; there is still a place for organoleptic inspection, or sorting. But the diseases and conditions detected by this method are little more than lumps, bumps and bruises. These cosmetic conditions are easily detected by plant personnel, and it should be their job to find and remove them. And under HIMP, an FSIS inspector verifies the proper disposition of every single carcass.
Finally, HIMP food safety standards are tighter than those under traditional inspection. And FSIS inspectors are in every HIMP plant all day every day, ensuring the safety of meat by verifying in-plant food safety processes and sanitation. The number of inspection food safety tasks actually increases under HIMP.
Stricter standards and closer food safety inspection. That’s HIMP.”
After talking with James, I made several Freedom of Information Act requests on microbial sampling in swine. You can see the chart on page 32. A few things jump out at you when you look at the data. The first is that in HIMP plants, E. coli., Campylobacter and hogs with two or three or more positive pathogens per animal are a lot less prevalent. Salmonella positives are statistically the same, and while non-HIMP plants produce more hogs that are pathogen-free they also produce more hogs that have multiple pathogens present.
This data set is part of the National Antimicrobial Resistance System Sampling. As such, it isn’t ideal for a direct comparison; however, it is what the USDA-FSIS has as far as data, or at least what it could find and present in response to the FOIA request.
The question then is this: Is HIMP in swine plants a big deal? In my opinion, the answer is yes. It is a giant leap forward for food safety. Why? The answer is simple.
Instead of a single inspector reviewing the carcass, we now have someone providing constant oversight, i.e., there are now two sets of eyes on each carcass. It is that simple. Under traditional inspection, you only have one set of eyes, and no matter how attentive, well-trained and motivated the USDA-FSIS inspector is, if he or she misses something, there is no one else to catch it. There is no safety net.
With HIMP, we have created the safety net that has been missing from traditional inspection. The one thing I hear when I am performing audits at HIMP plants is the USDA inspector found XYZ that was missed by the establishment’s sorters.
My response is, “If you are in a traditional plant, who is catching what was missed by the USDA inspectors?” The answer to that is simple: no one. So yes, I believe that HIMP is a big deal in swine facilities, and the sooner we can get it rolled out to the swine establishments, the better. NP