MORE can be done at the plant level by inspectors and the U.S. Department of Agriculture's Food Safety & Inspection Service (FSIS) to ensure that the safety of processed pork complies with food safety and humane handling laws, according to a recent USDA Office of Inspector General (OIG) audit of FSIS inspection and enforcement activities.
The review looked at enforcement actions taken against the more than 600 plants that slaughtered swine between 2008 and 2011 and conducted 30 plant site visits of those that had the highest number of violations.
As shown in the Figure, human interpretation of how to handle violations creates a recipe for inconsistency. The FSIS National Humane Handling Enforcement Coordinator noted that inspectors completed a nationwide humane handling training course in January 2012. However, OIG found that in interviews conducted in March 2012, it was "concerned whether the training was effective."
"To ensure consistency, FSIS needs to provide a plan describing how it will minimize reliance on the inspectors' judgment to ensure consistent application and enforcement of (the Humane Methods of Slaughter Act) and related regulations," OIG said.
American Meat Institute (AMI) senior vice president of regulatory affairs and general counsel Mark Dopp countered that OIG's comments, in several instances, reflect an "apparent lack of familiarity with the practicalities of slaughter and processing."
Dopp explained that while the regulations require that all animals must be stunned with a single blow before processing, animal welfare experts say this requirement is simply unachievable 100% of the time.
OIG found that FSIS enforcement policies do not deter repeat violations. During fiscal years 2008-11, FSIS issued 44,128 noncompliance records (NRs) to 616 plants; only 28 plants were suspended, even though some plants had repeat violations such as fecal matter on previously cleaned carcasses.
OIG noted that this occurred because FSIS does not always take progressively stronger enforcement action against repeat violators when warranted. FSIS also doesn't distinguish between serious violations and minor infractions on its NRs. OIG added that FSIS doesn't provide sufficient guidance on what actions to take in specific circumstances.
"Without more incentive to improve compliance, the 616 plants — which process about 110 million swine per year — run a higher risk of providing pork for human consumption that should not enter the food supply," the report states.
In response to the finding, FSIS said it is "developing a strategy for taking progressively stronger enforcement actions against plants with serious or repetitive violations by using regulatory noncompliance to identify establishments that should be prioritized for 'for cause' food safety assessment. FSIS will complete this work and develop a strategy by Jan. 1, 2014."
AMI spokesperson Janet Riley added that the group tends to take a glass-half-full view of the report as millions of animals are inspected without incidence.
Dopp added, in his written statement, that NRs on the approximately 440 million hogs processed during the four-year time period represent just 1/100th of 1%.
"In any industry, ... that level of compliance with the rules is quite remarkable," he said.
OIG found that in eight of the 30 plants visited, inspectors did not always examine the internal organs of carcasses in accordance with FSIS inspection requirements or did not take enforcement actions against plants that violated food safety regulations.
"As a result, there is reduced assurance of FSIS inspectors effectively identifying pork that should not enter the food supply," the report says.
AMI countered that thousands of people, inspectors and company employees do their jobs remarkably well.
"It's also safe to say that executive tasks in a perfectly flawless manner 'that will minimize reliance on inspectors' judgment,' as OIG recommends, is neither possible, nor is it desirable," Dopp said.
OIG recommended that FSIS modify existing criteria to standardize when suspensions and notices of intended enforcement should be applied, as well as define the frequency and specify the time frames of when violations would lead to such enforcement actions.
FSIS said it plans to hire a new humane handling enforcement coordinator. FSIS will also increase review frequency of NRs, suspensions and notices of intended enforcement and develop a database by Aug. 31 to track these reviews.
In 1997, FSIS began a pilot program called the HACCP-based Inspection Models Project (HIMP) for swine, which allowed five large plants to have faster line speeds with fewer FSIS online inspectors. Although the project's goals were to increase food safety and plant efficiency, FSIS could not determine whether these goals were met because it did not adequately oversee the program.
FSIS committed to evaluating HIMP and determining if a permanent program is warranted by March 31, 2014.
Those who decry the eating of meat and treatment of animals at slaughter facilities have said the OIG report solidifies that "FSIS doesn't meaningfully attempt to stop repeat violations of food safety laws" and that USDA "all but ignores its humane slaughter mandate," according to Farm Sanctuary senior advocacy director Bruce Friedrich.