Myths and Facts about the Modernization of Poultry Inspection System
For the Chicken Industry:Myth:The proposed rule would “privatize” chicken inspection. Fact: The chicken industry remains one of the most heavily regulated industries in the United States. Under the modernization and in the HIMP pilot program, USDA remains in its oversight role and USDA inspectors will still be in every plant, looking at each carcass to ensure the safety of chicken products and providing them with the USDA seal of approval for wholesomeness. The proportion of them doing critical food safety-related tasks will actually increase. Specifically, a USDA poultry inspector will be stationed further down the evisceration line and just before the chiller to ensure that birds have been properly processed. The facility will now be in charge of its own quality assurance program by training sorters to remove any quality defects from carcasses thereby allowing FSIS inspectors to focus more on food safety-related parameters and not visible defects.
For our WorkforceMyth: The proposed rule is likely to prove harmful for worker safety. Fact: There is no evidence in the pilot program over the past 18 years to substantiate the assertion that increased line speeds will increase injuries. In fact, the safety record in all poultry plants has improved dramatically. Bureau of Labor Statistics’ data show the industry has had an 82 percent decrease in its worker injury and illness rates since 1994, falling to 4.2 cases per 100 full-time workers in 2016 from 22.7 in 1994.
The total recordable poultry processing illness and injury rate of 4.2 is at an all-time low and lower than the rate of 4.7 for the entire food manufacturing sector. To put the rate of 4.2 into perspective, it is lower than the rate for similar animal slaughter industries (6.9), soft drink manufacturing (7.4), cheese manufacturing (4.8) and bakeries and tortilla manufacturing (4.3). Furthermore the more than five-fold decrease in injury rates in the poultry industry from 1994-2015 coincided with a period of substantial increases in line speeds, bird size, and automation. Technological improvements in processing tend to correspond to safer workplaces.
In addition, FSIS accounts for worker safety in the current line speed regulation by including a provision requiring plants to comply with federal worker safety requirements. The provision makes clear that all plants, regardless of the line speed at which they operate, must provide workers with a workplace free from recognized hazards that are likely to cause death or serious physical harm and to comply with all Occupational Safety and Health Administration (OSHA) standards.
Myth: The proposed rule calls for less federal oversight, effectively incentivizing companies to cheat federal rules and doing so would endanger workers.
Fact: Each establishment participating in NPIS is required to submit an annual attestation to FSIS stating that the establishment maintains a program to monitor and document any work-related conditions of establishment workers. This program must include the following elements: a) policies to encourage early reporting of symptoms of injuries and illnesses, and assurance that the plant has no policies or programs in place that would discourage the reporting of injuries and illnesses; (b) notification to employees of the nature and early symptoms of occupational illnesses and injuries; and (c) monitoring of injury and illness logs, as well as nurse or medical office logs, workers’ compensation data, and any other injury or illness information available. The proposed rule would not affect any of this attestation requirement.
Myth:With line speed increases, poultry plant workers will be forced to work with knives and other sharp objects at a frenetic, chaotic pace, with little to no way to slow down the process.
Fact: The line speed increases only pertain to the middle part of the production line, known as the evisceration line. The evisceration line is the part of the plant where the birds’ organs are removed, the carcass is cleaned and inspected. This part of the process is highly automated and it is not the part of the plant where the birds are killed, or where workers cut up the chicken for packaging.
FSIS itself noted in the preamble to the NPIS proposed rule that there is an important distinction between line speed and work pace. A worker’s exposure to musculoskeletal disorder (MSD) risk factors, such as repetitive or prolonged hand activity, is affected by his or her work pace. Work pace, in turn, is the product of many factors, one of which is line speed. Other factors affecting work pace include staffing levels, plant layout and product flow, factors which FSIS does not regulate but that establishments may adjust as appropriate to ensure that line speeds do not jeopardize worker safety. In addition, FSIS inspectors are required to slow down or stop the line if process control is not maintained. Further, USDA has a memorandum of understanding (MOU) with the Occupational Safety and Health Administration (OSHA) requiring both OSHA and FSIS inspectors to confidentially report workplace hazards affecting plant employees.
Myth: Studies that looked at traditional poultry plants where line speeds were 70 to 91 birds per minute, found that 59 percent of workers had definite or possible carpal tunnel syndrome (CTS). Modernization would increase the percentage of workers with CTS and other repetitive motion injuries.
Fact: These studies actually focused on plant activities outside of the slaughtering process and thus are unrelated to the activities covered in the proposed rule. In terms of worker safety, the part of the line (evisceration) that deals with the speed increase is almost entirely automated. Second processing lines, where workers debone and cut up chicken parts, would remain one-fifth of the speed as the evisceration line. At the same time the industry has been increasing line speeds over the past 20 years, the poultry industry’ injury and illness rate has fallen 82 percent, according to the Department of Labor. Furthermore, much of the process under which line speeds would increase due to waivers requested by NCC in the NPIS is automated, therefore would have little effect on workers’ repetitive motion injuries.
For Food Safety
Myth:The proposal would likely increase the rates of ‘defects’ for birds going down the processing line, allowing each plant to decide the appropriate level of ‘defects,’ which can include blisters, bruises, scabs, feathers, bile, ingesta, and a variety of poultry-specific diseases.
Fact: Science-based evidence demonstrates that there is no correlation between visible defects and food-borne illness. Additionally, under the proposed rule, industry must comply with current Ready-to-Cook regulatory standards, which addresses ‘defects’ for poultry products. From a common sense viewpoint, a company would harm the marketability and demand for their product if they allowed visible ‘defects’ on their products. Also, though it is left unspecified how industry is to go about complying with performance standards on bird defects, it is ultimately FSIS that establishes and enforces those performance standards. Therefore, the result is the same in either case, but it takes less agency resources under NPIS to achieve the same result in terms of bird ‘defects.’
Myth: A single government inspector would have only one-third of a second to examine each chicken carcass for food safety and other problems.
Fact: You can’t see Salmonella no matter how fast or slow the line speed moves. A person cannot visually inspect a bird and point out which ones have Salmonella on them or not. Visual inspection is only one of several other scientifically-validated measures to protect food from contamination and to reduce bacteria levels at dozens of different points during the entire production process. While visual inspection will remain a vital part of the inspection process, it will be coupled with additional pathogen detection capabilities performed offline. The number of these offline inspections has quadrupled under NPIS, according to an October 2017 presentation released by FSIS. Ultimately, no less visual inspection will occur under NPIS than occurred under the traditional inspection system. By having industry employees perform more cosmetic inspection (done by visual inspection), FSIS inspectors can be used at the end of the line as a final judge and off-line doing many other tasks to ensure a safe and wholesome chicken product.
Myth: When birds arrive at the inspector, they’re often covered in fecal matter or were improperly killed, leading to greater risk of diseases like septicemia or toxemia.
Fact: The data show that as a result of industry practices, such as carcass sorting activities, very few adulterated poultry carcasses are presented to inspectors stationed at the end of the slaughter line in HIMP establishments, according to a 2016 Government Accountability Office (GAO) report. The number of carcasses with septicemia, toxemia, or fecal material that arrive at the online carcass inspector location is very low (less than 8 carcasses with infectious conditions per million carcasses processed and less than 0.8 carcasses with fecal contamination per 1,000 carcasses). These levels are less than those found in non-HIMP plants. The carcass inspector further reduces the number of carcasses with septicemia/toxemia or visible fecal contamination, according to the data. For septicemia/toxemia, the carcass inspector detected affected carcasses at a rate of 0.000004% or 4 per 100 million carcasses slaughtered. For visible fecal contamination, the CI detected affected carcasses at a rate of 0.0009% or 9 per million carcasses slaughtered. These data demonstrate that carcasses affected with these diseases and fecal contamination are detected and condemned in HIMP establishments before entering the chiller. This data shows that the online inspectors in HIMP plants are performing in a manner that enables them to properly inspect each carcass and, therefore, make the necessary inspection to adequately identify adulterated carcasses.
Myth: With less government inspectors on the line, rates of food-borne diseases like Salmonella and Campylobacter will increase.
Fact: Under the new inspection system, rates of these diseases have fallen by half of traditional inspection rates. According to an October 2017 presentation released by FSIS providing updated NPIS food safety information from data on 176 chicken and 41 turkey slaughter plants, Salmonella positive rates in chicken fell to 1.56 percent from 3.01 percent. In HIMP-converted plants, this rate fell to 2.9 percent from 8.9 percent for chicken carcasses, while the rate for chicken parts remained basically flat. These data show that the prevalence of these diseases decreases when more offline inspection is done by FSIS, while visual inspection to detect bird ‘defects’ can be done by industry personnel. In this arrangement, precious agency resources are stewarded more wisely all while ensuring a safer and more wholesome product for the American public.
“A landmark study demonstrated that plants with higher line speeds met or exceeded FSIS food safety standards,” wrote Doug Collins, Congressman from Georgia’s Ninth District, for The Hill in October of 2017. “Among other successes, FSIS (that is, the government inspectors) saw the percentages of unacceptable samples for E. coli fall from 3.9 percent to 0.7 percent while the plants were able to operate at increased speeds. The rates of Salmonella and Campylobacter bacteria further show that these have food safety outcomes as good as or better than traditionally-run plants, whose line speeds are capped at an arbitrary 140 bpm.”