THE HACCP-based Inspection Models Project (HIMP) is going to be a much more routine inspection program if U.S. Department of Agriculture undersecretary for food safety Dr. Elisabeth Hagen and Food Safety & Inspection Service (FSIS) Administrator Al Almanza have their way.
USDA published a proposal in January 2012 to expand HIMP beyond its current limited size and initiated a public comment period on the proposed rule.
Hagen recently reconfirmed her intent at a March 13 House subcommittee hearing, testifying, "The need for modernizing our food safety system is evident."
(Her entire testimony can be found online at www.fsis.usda.gov/News_&_Events/Testimony_Hagen_031313/index.asp.)
Hagen and Almanza make a fine team that works well together.
Hagen is a physician with specialty training and board certification in infectious diseases, so she knows pathogens.
Almanza started with the agency in 1978 as an entry-level FSIS inspector and moved through the ranks to become district manager for Texas and then FSIS administrator in 2007. He lives and breathes FSIS and knows the inspection system forward and backward.
They both know that when the Poultry Products Inspection Act was signed into law in 1957 by then-President Dwight Eisenhower, the main objective was to remove birds from the line that had obvious blemishes and defects.
Pathogen testing, hazard analysis and critical control points (HACCP) and standard operating procedures were not even in our vocabulary at that time.
A lot has changed in 55 years, but poultry inspection has not.
Poultry inspection needs to use 21st-century technology and knowledge to make food safer. That would be accomplished by HIMP.
HIMP was initially rolled out in 1999 after implementation of the 1996 HACCP systems rule. In the 26 plants that were part of the pilot project, the Research Triangle Institute collected baseline data and then collected the same data again after HIMP was initiated.
Testing millions of broilers for "food safety" and "other consumer protection" issues before and after initiation of the project revealed dramatic declines across the board.
For example, the rate of contamination with fecal material dropped from 1.5% to 0.1%, and the number of carcasses from septic birds went from 0.1% to 0.003%. (FSIS has a zero-tolerance policy for both.)
Similar results were seen for "other consumer protection" issues such as feathers and bruises on meat: All six measurements improved overall.
Hagen also rattled off a few more numbers for HIMP, which include:
* A minimum of 5,000 fewer illnesses per year (that's a very good thing);
* Taxpayer savings of $90 million over the first three years (another good thing), and
* A reduction of $85 million in public health costs (also a very good thing).
Another point not often raised is that the HIMP plants deal with young animals, not older critters like cull cows or even 20-month-old steers. These younger animals are much less likely to have serious diseases and illnesses that might be a threat to public health.
Now, after 14 years of experience, only 20 broiler facilities, five market hog facilities and five young turkey facilities use the HIMP method of inspection.
Collectively, these 30 plants have far lower pathogen contamination rates than the hundreds of plants that are still conducting meat and poultry slaughter and inspection the way Eisenhower envisioned it.
So, why hasn't the project been expanded?
It is because in September 2001, the American Federation of Government Employees filed an appeal to an earlier district court decision, and a new panel of judges was seated to hear oral arguments and review submitted briefs.
The court decided that HIMP was okay as it existed, but no expansion could occur until further data supported FSIS's opinion that product from HIMP plants was safer than from conventionally inspected plants.
The data the judges wanted to see have been collected, and FSIS is attempting to move forward.
However, those speaking for the government employee federation and the National Joint Council of Food Inspection Local Unions (representing non-supervisory FSIS inspectors) will fight tooth and nail against it, because jobs are at stake.
Why does expanding HIMP mean a loss of jobs?
The long answer is that, in conventional poultry plants, line speeds can run at up to 140 birds per minute. Fortunately, FSIS inspectors can spot the carcass of a septic bird from across the plant.
What they are really looking for in the precious little time they have to examine these birds are blemishes and fractured wings and legs.
So, they essentially are doing quality control for the meat and poultry industry using taxpayer dollars to protect the company brand name.
Meanwhile, the HIMP plants train and place their own workforce to do quality control, while FSIS oversees the effort to make certain they are doing their job.
The rest of the FSIS inspectors in HIMP plants have been trained to do off-line inspection, which can better protect consumers from salmonella.
They do this by providing verification measures such as examining plant records, focusing on HACCP plans, drawing samples for pathogen testing and doing visual examination of the plant and its contents.
While traditional line speeds are capped at 140 birds per minute, HIMP plants can run at 175 birds per minute, providing efficiencies in the process and potential savings to the consumer. Therefore, the product from HIMP plants is not only safer but potentially cheaper.
Many false and inaccurate statements about line speeds have been made in this debate.
As for the claim that HIMP puts jobs at risk, Hagen told me that she can only approximate the impact on jobs until the final rule comes out, but here are her estimates: 1,500 full-time slaughter inspectors will be upgraded from GS7 to GS8 and moved off the line to what should be more rewarding and effective inspection activities. This upgrade, of course, would also bring a pay raise.
Why would the bargaining unit object to this?
Because over the total implementation time frame, there would be a reduction of 750-800 positions.
To quote Hagen, however, "this will be done entirely through attrition without backfilling, etc. — no layoffs."
Therein lies the rub. If the bargaining unit loses 800 members out of an estimated 6,500 current members, National Joint Council of Food Inspection Local Unions president Stanley Painter could most likely lose his support and his position, which he has held for many years.
This debate should not be about line speeds. FSIS has 13 years' worth of data about line speeds of up to 175 birds per minute, and the outcomes speak for themselves. It works.
This debate should not be about jobs. Inspectors who desire to improve their position should be able to do so if they have the capabilities needed to move off the line. No one should stand in the way of a food safety improvement just to support inspectors who cannot or will not go through the training.
This debate should not even be about cost reductions, even during this economically tough time.
The debate really should be about whether this is a better way to do meat and poultry inspection to protect the public from foodborne pathogens. The HIMP numbers support Hagen and Almanza.
I wish I had had the intestinal fortitude to tackle this issue when I sat in Hagen's chair, which she assures me is still comfortable, but most of my time as undersecretary was spent trying to implement risk-based inspection and handling two of the largest beef recalls in history. There are only so many days in a week.
For my health and safety, and for yours, too, I wish our food safety leaders well.
They deserve our support in the days ahead because what they seek to accomplish will not be easy to implement.
*Dr. Richard Raymond is a medical doctor by training and a former undersecretary for food safety at the U.S. Department of Agriculture.