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Dr. Mindy Brashears talks about the new swine slaughter inspection system that has been piloted at five pork processing plants and was developed over many years of research and evaluation.
December 20, 2019
The Hill, a Washington-based news source, recently published a breathless story about the New Swine Slaughter Inspection System (NSIS), an outgrowth of the U.S. Department of Agriculture’s HACCP-Based Inspection Model Project (HIMP) with these warnings: “A new rule … would reduce the number of government food safety inspectors in pork plants by 40% and remove most of the remaining inspectors. In their place, a smaller number of company employees — who are not required to receive any training — would conduct the ‘sorting’ tasks. The rule would allow companies to design their microbiological testing programs to measure food safety rather than requiring companies to meet the same standard.”
The fear-ridden story continued “… the new rule would remove all line speed limits in the plants, allowing companies to speed up their lines with abandon. With fewer government inspectors on the slaughter lines, there would be fewer trained workers watching out for consumer safety.”
Wow! Based on those ominous sentences, most people would banish anything containing pork from their diet forever. Gone with obscurities like scrapple would be hams, prosciutto and deli meats like salami, bologna, headcheese and pate. Buried deep in the basement of culinary history would be breakfast sausages and a long menu of related delicacies like bratwurst, Italian (sweet, mild and hot), cheddarwurst and every other ‘wurst.’ Other meats that will be banished are bacon, bacon bits, wieners, hot dogs and Canadian bacon.
But breathless news stories that feed those fears ignore good science for easy, ‘chicken little’ style reporting. Let me explain.
My first brush with HIMP was more than 20 years ago when it was just in the earliest testing phase. There was a lot of confusion about what it was and how it would destroy food safety. Six years ago, I ran into Al Almanza at the Food Safety Summit in Baltimore, Md. He was a Food Safety & Inspection Service (FSIS) guy who had a lot of hands-on experience with the concept. He patiently explained the limitations behind ‘poke and sniff,’ as the existing method was called, and the scientific advantages of HIMP so that even I could understand.
The limitations were obvious. Poke-and-sniff could find quality control problems, such as carcass bruising and broken bones. But E. coli O157:H7 contamination or any of the other pathogenic bacteria that might be present? That takes a swab and a petri dish. As Almanza said, “Seeing bacteria with the naked eye is damn near impossible.”
But I continued to worry. It seems the great strength of the meat and poultry industry – a singular reliance on ‘the science’ - is also its greatest weakness. Food is an emotional thing and emotion always trumps science. The Hill story ignored 20 years of research and fed the fears of a purely emotional response.
So the old and absurdly inefficient poke-and-sniff system that had been the industry standard after Upton Sinclair wrote “The Jungle” was to be phased out. Worse, line speeds could accelerate, unhindered by the limitations of visual inspection.
Checking for bruising and other visual imperfections can be done quickly and efficiently online by people with reasonably good eyesight. Better to sample and test for contamination in the lab than try to watch for it at even 10 carcasses per minute. FSIS intended to bring food safety practices from its mid-20th century roots to the 21st century, a nearly 60-year leap forward that recognized the tremendous scientific advances made by Louis Pasteur a century-and-a-half ago.
Needing a stiff dose of the facts, I knocked on the door of Dr. Mindy Brashears. She was a professor of food science at Texas Tech University until she was nominated to lead FSIS. Coming into office after almost all the work on HIMP was complete, she had no real skin in the game. She took a fresh look at it, more than ready to veto the program if it didn’t meet some very rigorous scientific standards. She approved.
I posed some questions. She wrote down these answers.
Q. The new swine slaughter inspection system (NSIS) has been piloted at five pork processing plants and was developed over many years of research and evaluation. Would you walk me through that process? What plants were involved, and what was the outcome?
A. Because NSIS was on the horizon when I began with FSIS, I took a special interest in reviewing the proposed rule with an intense focus on the history and data collected to inform the rule. I took a very scientific approach to analyzing the system as I have done with other major tasks in my career. I asked for all of the data collected (not just summary data) and also conducted a thorough review of methodologies, study design, peer reviews and statistical analysis (among other things).
My commitment at FSIS is to make data-driven, science-based decisions and I had to be confident that this new system was the right thing to do. After weeks of reviewing data, visiting plants and having in-depth conversations with our staff, inspectors and even employees at establishments that operated under the new system, I was confident that the move to NSIS was the right thing to do to protect public health and improve food safety.
What is also very important to note is the fact that I also listened to opposing arguments against moving ahead with NSIS. Regardless of the individual or group making a claim or request, I have a high standard for data and science. We can’t make decisions based on emotion, hearsay or anecdotes because lives are at stake. Not one single opposing group was able to provide any genuine data to indicate we should not move forward with NSIS on any point of contention related to public health. It is important that the facts are the facts so we can make our food supply safe and move forward to protect the American citizen from foodborne illness.
I’m happy to walk you through our scientific approach to modernizing swine inspection on a high level because there is a large amount of information and data that went into making this deliberative and thoughtful decision. The research did not begin overnight and actually stretches back to the late 1990s after the transition to Hazard Analysis & Critical Control Points (HACCP)-based systems in meat and poultry processing plants. As you already know, FSIS adjusted the overall processes and sanitation in federal establishments to focus on pathogen prevention by implementing HACCP/Pathogen Reduction (PR) regulations and Sanitation Standard Operating Procedures (SSOP).
In 1997, FSIS initiated the HACCP-Based Inspection Models Project (HIMP) pilot in 30 volunteer slaughter establishments (20 young chicken, five turkey, and five market hog) to determine whether new slaughter inspection procedures, along with new plant responsibilities could improve food safety—while simultaneously increasing consumer protection. These facilities have been successfully operating under this system for more than 20 years and data collected in these facilities has informed decisions for New Swine Inspection Systems (NSIS) and New Poultry Inspection Systems (Implemented a few years ago).
The five comparable market hog slaughter establishments listed below volunteered for the HIMP pilot:
Clemens Food Group, LLC in Hatfield, Pa.
Quality Pork Processors in Austin, Minn.
Smithfield Packaged Meats in Vernon, Calif.
Swift Pork Company in Beardstown, Ill.
WholeStone Farms Cooperative, Inc. in Fremont, Neb.
More than 20 years later and with significant experience and data in hand, FSIS issued the Modernization of Swine Slaughter Inspection proposed rule in 2018. This rule was formed by pathogen data collected in the facilities as well as data collected on inspection tasks. Summaries of the data are in the presentation. Most people do not know that the Agency prioritizes inspection tasks that are directly related to pathogen presence and public health. As you would expect, inspection tasks related to HACCP and Sanitation rank high when it comes to food safety.
In the HIMP systems, the inspection tasks directly related to food safety and public health were increased. The agency also initiated a full risk assessment, including a response to peer review comments, that can be reviewed on the FSIS website. The bottom line of the risk assessment was that more than 2500 Salmonella illnesses each year would be prevented when moving to the modernized system.
The final rule was published in September 2019 and is comprised of two parts:
All official swine slaughter establishments are required to develop, implement and maintain in their HACCP 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. These procedures will include sampling and analysis for microbial organisms to monitor process control for enteric pathogens, as well as written procedures to prevent visible fecal material, ingesta and milk contamination.
An important aspect of this that never gets mentioned in the media is the fact that now the establishments must test for indicator bacteria in two locations for process control to determine if the process is preventing contamination. These requirements are for all swine facilities.
The New Swine Slaughter Inspection System (NSIS) which establishments can choose to operate under or they can remain under the traditional slaughter inspection system. NSIS does NOT delegate any inspection authority to the plant. FSIS inspectors perform all inspection tasks and there is still 100% ante-mortem and post-mortem inspection.
There is a reduction in the total number of inspectors. Those under NSIS will not have food inspectors present in the plant. They will have Consumer Safety Inspectors (CSI) and our DVM inspectors. The CSIs have more experience and training in food safety, HACCP and Sanitation tasks and will be performing the online and off-line inspection tasks.
Establishments choosing to operate under the new system are required to sort and remove unfit animals before FSIS ante-mortem inspection and to trim and identify defects on carcasses and parts before FSIS post-mortem inspection. In a traditional inspection system, the inspector would see a defect (bruise, fecal contamination, etc.) and then direct the plant employee to remove it.
Now the plant employees are allowed to do that before it reaches the inspector, so the carcasses are cleaner when inspection occurs. If a defect is found by an inspector, then the plant must still go back and take corrective actions. As already stated, FSIS is still conducting 100% carcass-by-carcass inspection as required by law but now the plants are responsible for only presenting product that will pass inspection. This allows FSIS inspectors to focus more on food safety issues and less on quality defects.
Again, and I can’t emphasize this enough, USDA inspectors will continue to conduct inspection of all animals at ante-mortem and all carcasses and parts on post-mortem as mandated by Congress.
Q. What input did you get from industry resources like the National Pork Board and the National Pork Producers Council? How about the general public?
A. The proposed rule received over 83,000 public comments, which were reviewed and addressed in the final rule. The agency received overwhelming positive support from industry groups like the National Pork Board and the National Pork Producers Council due to FSIS’ desire to bring innovation to the inspection process, while still producing safe and wholesome pork products for consumers.
It is important to remember that five companies were already operating under this system for more than 20 years so the industry was very familiar with the successes and benefits of this program. In some regards this is also about leveling the playing field so that all of industry can operate in this inspection system and innovate like their five counterparts above.
Other comments received from the general public may be read, along with the agency’s response, in the final rule. Each and every comment was considered and a response was given categorically.
Q. NSIS is an outgrowth of the HIMP program, of course, which dates back to 1997. Will its adoption lead to similar programs – sooner or later? And will it take 20+ years to test and begin to implement?
A. The agency has a mission to ensure that everyone’s meat, poultry and processed egg products are safe. Government inspection must keep pace with the scientific world. It is our obligation to the consumer to allow for the implementation of innovative solutions and new technologies as well as systems that protect public health. It is a challenge because generally people do not like change and are opposed to innovation. Think about all of the safety and scientific advances over the last 30 years such as airbags, smartphones and here we are doing inspection the same way we were 50-60 years ago.
Unfortunately, many groups want us to stay stuck in the past. We will not. We are committed to improving food safety. This means that the modernization of inspection and policies is necessary in order to protect public health. As a scientist, I’ve seen pathogens constantly adapt to their environment, so we must continually modernize our approach to stay ahead of their impact on our food supply.
For poultry, FSIS published a final rule for the New Poultry Inspection System (NPIS) on Aug. 24, 2014, which serves as an optional inspection system for young chicken and all turkey slaughter establishments. NPIS also reduces the risk of foodborne illness by focusing FSIS inspection activities on those tasks that reduce contamination on chicken and turkey products. As of Dec. 17, 2019, there are 126 USDA poultry slaughter establishments operating under NPIS and it has been a successful transition. It is important to note a trend towards improved food safety because, after a year of collecting data, 89% of the plants under NSIS are meeting performance standards for Salmonella. We will continue to monitor this.
Under NPIS, one federal inspector is assigned to each evisceration line to conduct postmortem inspection of each carcass and one off-line inspector for each evisceration line to conduct food safety and other verification inspection tasks. FSIS recently conducted an analysis to determine whether specific off-line inspection tasks were performed more frequently after an establishment’s conversion to NPIS. The analysis includes 72 formerly non-HIMP establishments that converted to NPIS, using Public Health Information System (PHIS) inspection task data from May 2015 to April 2019.
The analysis illustrates that:
Inspectors consistently completed a higher number of selected food safety-related offline inspection tasks, including the new NPIS inspection tasks after NPIS implementation.
The new NPIS Zero Tolerance Food Safety Verification task is being performed at or near four times more often after NPIS conversion as compared to the pre-NPIS Poultry Zero Tolerance Verification task.
The rate of noncompliance records (NRs) documented for these zero tolerance verification tasks more than tripled in conjunction with the increase in tasks performed.
This indicates that NPIS is working as intended and continues to ensure food safety. Please click here to read the final rule, risk assessments, status on the number of poultry plants that have converted to the NPIS, and the recent analysis.
FSIS leadership and I have been very public about our intentions to modernize all components of inspection. The agency mentioned beef modernization at numerous food safety and stakeholder conferences and even held two roundtables in May of 2018 to gather feedback and ideas on how the agency could modernize its approach to inspecting beef. It is FSIS’s statutory duty to protect public health by ensuring we modernize our inspection systems, policies and use scientific approaches and we will be committed to overseeing beef modernization. Initially, this will be done on a case-by-case basis using a waiver system. Those operating under the waiver will be assessed and data collected will be used to inform the future of beef modernization.
In 2020 we also plan to announce modernization of egg products inspection. For egg products, we will move to a HACCP-based system as we have already done in meat and poultry operations.
Q. The plan was endorsed by the National Association of Federal Veterinarians, a strong note of approval from a very well-respected organization. Several other groups strongly object, citing the end of online inspection, faster line speeds, and the ability of a plant to ‘set its own rules’ as dangerous and detrimental to food safety. How do you respond to their fears?
A. Let me be clear: FSIS has not delegated any of its authority. There is much misinformation out there. Online inspection has not ended at all.
There are key differences between NSIS and traditional inspection:
Under traditional inspection, market hog establishments voluntarily segregate animals before FSIS inspection. Under NSIS, this sorting process will be mandatory.
Under NSIS, if establishment employees do not properly sort animals for food safety conditions before FSIS inspection, the establishment will receive a non-compliance record (NR). They do not receive NRs under traditional inspection. This is a motivation factor for plants to do things correctly.
As already stated, under the final rule, FSIS inspectors will continue to conduct 100% carcass-by-carcass inspection; the plant employees will prepare and present the carcasses and parts to FSIS inspectors for inspection. Also, FSIS inspectors will continue to slow and stop the line to ensure food safety and inspection are achieved. The inspector always has the right to do this even when the plant is operating at increased line speeds.
In the HIMP studies, there was little difference in line speeds. It is not as if the lines will be running out of control (see the presentation for details). A couple of practical things I want to point out:
1. The plant will still be bound by cooler space and the number of carcasses that can be put in a cooler.
2. Line speeds are ONLY in slaughter areas because they are set for inspection.
If needed, our inspectors can slow the line. There has never been a line speed limit in fabrication or other downstream processing areas. The most important thing to note about line speeds is the fact that you can stop the line and observe an entire carcass, and you will never see Salmonella, Campylobacter or any other pathogen. We must focus on HACCP, sanitation and implementation of food safety technologies to keep the product safe. Our modernized inspection systems are the next phase of HACCP implementation as we focus inspection resources on off-line tasks related directly to food safety.
The final rule also allows FSIS inspectors to complete more offline food safety and humane handling verification tasks to monitor compliance. These offline inspection tasks have a more direct impact on food safety and animal welfare.
I hear all of the fears cited by these special interest groups, but as a scientist, I can’t rely on anecdotes. I tell all of these critics and groups “bring me the data” and yet none of them can. At the end of the day, I can only assume this is a basic fear of change or some ulterior motive that is causing them to spread misinformation and fear.
Q. Pork plants have the option of working the new program into their in-plant processes or standing pat with their current program. Won’t trying the blend the old with the new create industry and public confusion?
A. No, the process is very straightforward. The final rule gives market hog establishments the choice to operate under NSIS or to continue to operate under the traditional slaughter inspection system. All market establishments will initially have six months from the date of publication in the Federal Register to notify their district office of their intent to operate under NSIS. Establishments that do not notify their district office of their intent to transition during this time will be deemed to have chosen to continue to operate under traditional inspection. Market hog establishments that decide that they would like to convert to NSIS after the initial notification date may notify their district office of their intent at any time after that date.
FSIS will then implement NSIS in the additional establishments that intend to convert on a schedule consistent with the availability of agency resources and establishment readiness.
As previously noted, some aspects are required for all establishments.
Q. The rollout has just begun. How is it going? Who’s onboard? What are some of the objections and ‘attaboys’ you’ve heard?
A. Some establishments have contacted their FSIS district office expressing interest in converting to NSIS. However, to date, the agency has not received a written commitment with a proposed conversion date from any swine slaughter establishment. The final rule published in the Federal Register on Oct. 1, 2019 and establishments have until April 1, 2020 to notify their FSIS district office of their intent to operate under NSIS. As we begin to roll out the system, I will be happy to follow up with additional information.
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