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Food SafetyPorkExpert Commentary

Regulations & Legislation

FSIS looks to modernize swine slaughter inspection

By Jolyda O. Swaim, Betsy Booren
The National Provisioner's Regulations and Legislation
March 20, 2018

On Feb. 1, the Food Safety and Inspection Service (FSIS or agency) published in the Federal Register a proposed rule that outlines the intent of the agency to modernize swine slaughter inspection. The proposed rule, if finalized, would amend federal meat inspection regulations to create a new inspection system for market hog slaughter establishments as well as changing certain regulatory requirements for all official swine slaughter establishments, regardless of inspection system. 

The proposed New Swine Slaughter Inspection System (NSIS), which was informed by the agency’s experiences under the HACCP-Based Inspection Models Project (HIMP), intends to provide public health protection equivalent to the current inspection system. Establishments will be given the option of operating under the proposed new inspection system or remain under the existing inspection system (“traditional inspection”). Key elements of NSIS include:

  • requiring establishments to sort animals before anti-mortem inspection;
  • requiring establishments to trim and identify defects before post-mortem inspection;
  • requiring establishments to identify animals or carcasses for disposal before inspection, then denature onsite and maintain all appropriate records;
  • requiring establishments to notify FSIS if they suspect an animal or carcass has a reportable or foreign animal disease;
  • requiring establishments maintain records that products meet the new definition of Ready-To-Cook (RTC) pork product, which would be any slaughtered pork product free from bile, hair, scurf, dirt, hooves, toe nails, claws, bruises, edema, scabs, skin lesions, icterus, foreign material, and odor which is suitable for cooking without need of further processing;
  • removing maximum line speed requirements and allowing establishments to determine line speed based on their ability to maintain process control; and
  • reallocating agency resources to conduct more effective food safety activities.

During an outbreak in 2015 that had more than 150 illnesses, the FSIS investigation found evidence of unsanitary conditions, including preoperational food contact surfaces that were contaminated with the outbreak strain of Salmonella. For that reason, the agency believes the proposed food contact surface sampling requirement would reduce the risk of cross-contamination from unsanitary conditions and could identify harborage sites for Salmonella biofilms. As such, for all official swine slaughter establishments, FSIS is proposing each establishment:

  • develop, implement and maintain in their food safety systems written procedures to prevent the contamination of carcasses and parts by enteric pathogens, fecal material, ingesta, and milk throughout the entire slaughter and dressing operation, including microbiological sampling programs to assist in assessing process control and sanitary conditions; and 
  • develop, implement and maintain in their food safety systems written procedures to prevent contamination of the pre-operational environment by enteric pathogens. 

The agency has also made available two draft compliance guidelines for review and comment to assist establishments in complying with the regulatory requirements outlined in the proposed rule. 

The Draft FSIS Compliance Guideline: Modernization of Swine Inspection System Developing Effective Microbiological Sampling Programs in Swine Slaughter Establishments to Assess Process Control and Sanitary Conditions was developed to assist all swine slaughter establishments in complying with the microbiological sampling and analysis regulatory requirements outlined in the proposed rule. The compliance guideline provides recommendations for establishments as they develop written plans for assessing process control, which would include a sampling plan for indicator organisms (e.g. Aerobic Plate Count (APC), generic E. coli, total coliforms, and Enterobacteriaceae). If the proposed rule is finalized as is, this compliance guideline provides recommendations on how establishments can meet the proposed regulatory requirements for having written procedures, including sampling and analysis, to ensure pre-operational food contact surfaces are sanitary and free of enteric pathogens. The effective date of these requirements will be determined after the proposed rule is finalized. It is important to note that the agency encourages establishments to utilize the information provided as it may be helpful for developing programs prior to the finalization of the Proposed Rule.

The Draft Compliance Guideline for Training Establishment Employees under the New Swine Slaughter Inspection System provides recommendations to swine slaughter establishments electing to be inspected under NSIS on how to train their employees to conduct live animal and carcass sorting activities. This Compliance Guideline should be used only after the proposed rule is finalized. 

FSIS opened its 60-day public comment period through April 2 for interested stakeholders to submit comments on the proposed rule as well as the two draft compliance guidelines. 

It is clear FSIS is making good on its goals outline in its 2017-21 strategic plan by modernizing inspection systems, policies and the use of scientific approaches. This proposed rule, along with the New Poultry Inspection System, integration of genome sequencing and the Public Health Information System, among other activities, are just a few examples of how the agency is following the strategic plan. The industry should expect FSIS to continue to modernize the inspection tools and processes that assist it in achieving its public health mission. NP

KEYWORDS: FSIS policy initiatives swine inspection

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Jolyda “Jody” Swaim is a principal at Olsson Frank Weeda Terman Matz PC. For more information, email her at jswaim@ofwlaw.com.

Betsy Booren recently joined Olsson Frank Weeda Terman Matz, PC in Washington, D.C. as senior policy advisor.

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