Exclusive Q&A with FSIS' Rottenberg, Kiecker
As the meat processing industry continues to change and modernize, the government agency that has been tasked with monitoring it has had to change as well. The Food Safety and Inspection Service, part of the U.S. Department of Agriculture, periodically announces changes to the way that meat processing plants are monitored. The New Swine Slaughter Inspection System would be such a change. Following up on the previous efforts to modernize poultry inspection, NSIS rolled out a series of proposed mandatory and optional changes to the inspection of hog processing plants. Carmen Rottenberg, acting Depute Under Secretary, Office of Food Safety, and Paul Kiecker, Acting Administrator, Office of the Administrator, were on hand at the 2018 IPPE in Atlanta, Ga., to discuss the proposal. They also discussed the issues of regulating small establishments without over-regulating them out of business.
The FSIS’ stated goal is to modernize inspection. How does this new proposal play into that?
Carmen Rottenberg: We really began in the mid-‘90s, moving from a “command and control” approach, where the inspector would take all the responsibility for approving production-related decisions, and we moved to a HACCP-based approach, where the company takes full responsibility for production decisions and executions. They are responsible for producing safe product, and the government inspectors verify that they are producing safe product.
The idea is that if you allow the plants to, using HACCP principles, sort the fit animals from the unfit ones and trim off some quality defects, and present the government inspector with the best product that they can, then the government inspector inspects that. You have an efficient and more effective process. You have less line inspectors in most instances, and we could position our resources in other parts of the plant, verifying food safety tasks that have a direct correlation to human health.
We still have 100% carcass-by-carcass inspection, but it would allow flexibility for plants in terms of how they present carcasses. We started the pilot in swine in the early 2000s, so we have 15 or 16 years worth of data. We have proposed in the modernization of swine inspection both a new swine inspection system that would be an optional inspection system, and I think there are about 40 swine slaughter establishments that would interested in it. The proposal also has other mandatory requirements for all swine establishments related to food safety.
Paul Kiecker: The mandatory aspects are that out of the 600 establishments that slaughter swine, they would all have to have within their HACCP system mandatory sampling to show they have the process in control, they are producing product n a sanitary manner that’s free of enteric pathogens, free of fecal material, free of ingesta and other things that would indicate that the process is out of control. Also to go along with that, there is also a requirement that within their HACCP system they have to have sampling of product contact surfaces prior to beginning operations.
CR: The sampling that Paul was talking about, we’re proposing to remove the generic E. coli sampling requirement that we have. We know that most establishments sample for things other than generic E. coli, and they are in the best position to determine what is the best indicator organism for process control in their establishment. We would remove the generic E. coli requirement and would propose to proscribe a minimum frequency pre-evisceration and post-chill, for sampling for all of the over 600 swine establishments.
What do you see as the role of the federal inspector in a processing plant? Do you think the traditional role that has been is no longer efficient?
CR: The role of the government inspector is to verify that the plant is producing a safe product. Our mission as an agency is to prevent food-borne illness and protect public health. We know that we can do that by verifying that plants are maintaining process control and verify that what they have in their HACCP plan is what they’re doing in actuality. That’s the role of government inspectors.
The current inspection regs were invented in the late 1960s, and it was before the advent of HACCP. The new Swine Inspection System is needed for market hog establishments that are high volume and have moved to new technologies and automation. A command and control approach in the ‘60s was created out of a perceived need to achieve uniformity in all federally inspected establishments. If you’re having command and control and you’re training your inspectors in a certain way, then you want all plants to look the same. But when we moved to HACCP, the onus is on the plant to produce a safe product, and we’re there to verify it. The way that we have inspected has not yet caught up with that.
For smaller producing establishments that are generally less automated and run at slower speeds, traditional inspection is fine, which is why we’re making this an optional system. But the need for higher-volume establishments to innovate and utilize new technologies that are oftentimes directly related to food safety, we need to allow that flexibility to establishments, and we can do that with this new Swine Inspection System. It allows for different line configurations in the plant and allows them to use different interventions before the product gets to our government inspector. But still, 100% carcass-by-carcass inspection.
PK: For the inspector that’s on the line, it’s exactly the same. They do 100% inspection of every part of those carcasses. For the ones that are off-line, they will be doing the same things that they currently do now. They verify other aspects of that system, sanitary dressing, which is directly related to food safety, sampling and verifying that the plant is conducting its sampling the way it is supposed to, and also doing humane handling, and collecting samples as well.
Currently, if you’re a line inspector, that’s all you do — line inspection. Now, underneath this proposal, they would all rotate, so you would spend some time on the line and some time offline doing other agency tasks.
When the Poultry Modernization Act was proposed, the thing that caught a lot of attention was the line speeds. Are there any line speed changes in this instance?
CR: We’re actually proposing to lift the line speed cap altogether, so there would be no line speed cap for pork. Line speeds have been set as work metrics in terms of how fast a line can run and the inspector can do the activities. With the command and control approach, where there is uniformity in all plants, they were based on old work metrics for how many steps it would take from one sorting activity to another sorting activity. They’re totally and completely out of date.
We don’t believe that there needs to be a line speed cap for hogs because we know from the pilot that hog lines can’t really run faster than our inspectors can inspect. We set in the pilot project for poultry that 175 (birds per minute) is the maximum line speed, because at the time we were doing the pilot, about 2007, we found that there were some establishments that were actually running faster than our inspectors could conduct a critical appraisal of the carcass. So we said 175 is the maximum rate at which one government inspector can sit there and make a critical appraisal of every carcass that’s going by. For hogs, they wouldn’t run fast enough that we couldn’t do that. Now, if something changed, then we would look at that. But line speeds, and I think we didn’t do a great job of describing this when we went forward with poultry modernization, are completely and totally about an inspector’s ability to verify the food safety of the product.
Small processors are always concerned about the amount of regulations and the fear of over-regulation. How do you draw that line between having regulations that keep the food safe but not overregulation to where these small companies may decide that it’s not worth staying in operation anymore?
PK: I think that with the sampling we’re requiring to be done, the cost should be minimal, especially for a very small plant. In larger plants, we’re requiring them to take samples pre-evisceration and post-chill, and I believe in the proposal for the very small plants, the only requirement is that they take samples post-chill to demonstrate that they have process control. We’ve made sure that we’re not putting them in a position where we expect them to take a number of samples that won’t support their business. We also have guidelines that we publish as well to give the plants some type of idea on what we would be looking at, as far as the number of samples that would be adequate.
CR: In every rule that we propose, we always specifically ask for very small plants to comment based on what the impact would be. In the last two years, we have been making a significant and concerted effort to get out quarterly throughout the country and have small plant meetings. One of the criticisms that we hear, honestly, is “You put out a 200-page proposal, and I’m a one-man operation. It takes a lot of time to read that.” Or “It would be really helpful if you would put out a compliance guideline out on X and do a webinar to walk us through it.” We’re turning some of the criticisms into tangible ways that the Agency can do a better job on outreach in order to educate the small and very small producers on what it is the Agency is expecting.
Ultimately, we are under constant pressure from consumers in this country to have the safest food supply in the world. It’s a mandate that we take very seriously. We have statutory requirements that ensure that the food is safe if it’s going to be under federal inspection. We do our best to do outreach to the very small plants, when we identify issues.
It’s certainly never our intent to put any company out of business, and just this year we have added to our EIAOs (Enforcement Investigation and Analysis Officers). They are paired up with our district offices, and [we ask that they are] spending at least 25% of their time on outreach with very small plants. We used this method very successfully as we implemented catfish inspection, because there were producers out there who had never even seen an FDA inspector, so the process was very new to them. Even the concept of HACCP was new to many of them. We had great success with them and are using that model in order to have other outreach to small producers.
This secretary, Secretary Perdue, has tasked all the agencies in the USDA to be the most efficient, effective and customer service-oriented agency in the federal government. We’re taking that mandate to heart and looking at ways that we can carry out our public health mission in a way that aids establishments in producing a safe and healthy product. We’re certainly open to suggestions to industry as well.
[As far as] compliance guides, we are doing more and more with them and asking small producers what would be helpful to them. We recognize that they may not have consultants that they’re working with. These guides basically give them a step-by-step way to get through anything new that we are proposing, to tell them exactly what they need to have. It’s like the government is giving you a guide, and they are written for very small plants.
PK: Anytime that a very small plant has a question at all as far as their HACCP system or what support documents are, they can call the district office and request an EIAO to come out. We don’t do that with a regulatory thought process; we do that to assist them in making sure that they can meet the requirements if they intend to.
To view the proposed rule and information on how to comment on the rule, visit the FSIS website at fsis.usda.gov/wps/portal/fsis/topics/regulations/federal-register/proposed-rules.