Source: Julie Larson Bricher, MEATINGPLACE, 2/1/18


On Jan. 19, USDA’s Food Safety and Inspection Service (FSIS) announced its proposed rule to modernize swine inspection systems. USDA is proposing to amend the federal meat inspection regulations to establish a new voluntary inspection system for market hog slaughter establishments called the New Swine Slaughter Inspection System (NSIS), while also requiring additional pathogen sampling for all swine slaughter establishments.

Meatingplace had the opportunity to find out more about the proposed rule from Carmen Rottenberg, USDA Acting Deputy Under Secretary for Food Safety, and Paul Kiecker, Acting Administrator of FSIS, at the International Production and Processing Expo (IPPE) in Atlanta.

Meatingplace: What are the main drivers that prompted FSIS to draft this new proposed rule to modernize swine inspection?
ROTTENBERG: The drivers really began in the mid-1990s with regulatory reform in the agency when USDA FSIS moved away from a command-and-control approach and adopted the Hazard Analysis and Critical Control Point (HACCP) system. This change meant that the responsibility for process and plant management decisions moved from the inspection personnel to the plant personnel. Under HACCP, the government inspector’s task is to verify that the establishment is doing what they say they are going to do in their HACCP plans, following their sanitation standard operating procedures (SSOPs), and performing humane handling tasks. However, when we moved to the HACCP system, we did not update the inspection method. The proposed rule is about right-sizing the inspection method utilizing HACCP principles.

After the implementation of HACCP the agency began a pilot project involving 20 young chicken establishments and five hog establishments where the plant employees had the responsibility for sorting out carcasses that they did not want to present for inspection for various reasons. For market hogs ante-mortem, the reasons frequently have to do with size and weight but they also might be that some carcasses are outliers from the production standard. At the point of slaughter, pilot plant employees would trim off bruises, abscesses or any kind of defect that didn’t have food safety implications but were quality issues before sending them to the government inspectors for verification. At the same time, the government inspectors conducted carcass-by-carcass inspections on 100 percent of the carcasses. The idea of a new swine inspection system is based on what we’ve learned in the 15 years of data collected from this pilot project.

Meatingplace: In its January announcement of the proposed rule, FSIS highlighted the need for increased focus on food safety-related tasks in pork plant inspections. Can you tell our readers more about the New Swine Slaughter Inspection System (NSIS) and its potential impact on food safety improvements?
ROTTENBERG: In the current traditional inspection system, the inspector points out the carcass defects and then the company employee trims them. NSIS, the proposed new swine inspection system, is a voluntary system for market hog slaughter establishments that allows the company employee to identify and trim the defects before the carcass goes to the government inspector and so you can potentially have a faster, more efficient process. The inspector then focuses on verifying that the establishment is identifying those CCPs and that they are doing what they wrote in their HACCP plan to prevent potential hazards.

The new system creates a situation where we still have inspectors inspecting every carcass but we don’t necessarily need as many inspectors on the line, and as a result, we’re able to position those inspectors in other areas of the plant to do other food safety verification tasks that do have a direct impact on public health. You know we can’t see pathogens during carcass-by-carcass inspection; you’re strictly looking for animal disease while the carcass, head and viscera are going by. So, we’re able to place inspectors in higher graded positions where they are doing real food safety and public health work, as well as humane handling tasks.

KIECKER: We’re still going to be doing 100 percent inspection by government inspectors on every carcass, every head, every set of viscera. There is no change to that whatsoever. But what it does allow us to do is have more time that inspectors spend offline verifying sanitary dressing, humane handling and other things that are directly related to food safety.

Meatingplace: Why is NSIS optional?
ROTTENBERG: We’re making it optional because we believe that for low-volume producers and small and very small establishments, traditional inspection is sufficient. They are running at slower line speeds and they are less automated. 

Meatingplace: What are the benefits to those establishments that opt in, and how many facilities does FSIS anticipate will do so?  
ROTTENBERG: There is some cost to industry that comes along with mandatory requirements but there also are potential cost-savings for market hog establishments. It’s important to note that while there are over 600 swine establishments in the U.S., 40 are high-volume market hog establishments that produce over 90 percent of the product. We expect that about 40 will opt in to the new swine inspection system. The proposed voluntary inspection system gives additional flexibility to establishments to potentially make capital investments into food safety technologies and processing. It allows for innovation without being so prescriptive in the way that we are going to position our inspection personnel and it allows establishments to do some things with line configuration and introduce some new interventions that have a direct impact on public health. 

KIECKER: In terms of line configuration, the proposed rule gives establishments the opportunity to present products for inspection differently than they currently do. For example, in the pilot study plants, only after employees incised the lymph nodes was the product inspected. The inspector would then just verify the lymph nodes after they were cut, rather than have to do the work of cutting them and then looking at them. If the plant sees anything that would prevent that product from being labeled as ready-to-cook (RTC), we would expect them to take control of it at that point. So the inspector should receive only product that the plant has already determined will meet the RTC requirements.

One of the benefits for the plant is that they have the employees who are identifying quality control or processing issues and they should be able to correct for those issues more quickly if they do not have to go to the inspector and say, “Hey, can you take a look at this?” 

Meatingplace: A big component of the rule is requiring additional pathogen sampling for all swine slaughter establishments, whether they’ve opted into NSIS or not. What new compliance actions are involved in terms of the mandatory sampling?
ROTTENBERG: The proposed rule requires more from plants in terms of sampling. We are proposing mandatory sampling at two points on the line and the establishments get to pick what they’re sampling for because they are in the best position to determine what is going to show their process control. In addition, there would be new mandatory requirements for all swine slaughter establishments to implement appropriate measures to prevent contamination throughout the entire production process in their HACCP plans, SSOPs and other prerequisite programs. The new requirements would ensure that both USDA and the establishment have the documentation they need to verify the effectiveness of these measures on an ongoing basis.

KIECKER: Under the proposed rule, plants must have in their HACCP system both pre-evisceration and post-chill sampling to demonstrate that they have process control. They would decide what indicator organism is the best for their operation to demonstrate process control. In this way we get away from the mandatory E. coli testing that is in place now, because there is a lot of concern as to whether it is the best organism to show process control. It is also now mandatory that establishments include product contact surface sampling prior to the beginning of production in their HACCP programs.

Meatingplace: Critics of the proposed rule say that allowances for faster line speeds may increase on-the-job worker injuries. Is there a case for concern?
ROTTENBERG: Line speeds are really old work metrics. Under the command-and-control approach there was a perceived need for uniformity among all federal establishments. But uniformity does not allow for any innovation in the industry. Line speeds were established due to old work metrics involving how many steps it takes from one sorting activity to another sorting activity, and it is completely arbitrary in today’s modern plants that are wanting to configure and wanting to innovate. So these arguments about worker safety are mischaracterized and misaligned because line speeds have nothing to do with how safe the work environment is and everything to do with the rate at which our inspectors can conduct food safety tasks. So a line speed cap of 175 birds per minute in poultry plants, for example, is based on the rate at which an inspector can look at and make a critical appraisal of a carcass. There is a whole government agency that is responsible for worker safety and to the extent that they find that issues with worker safety in these plants they may look to do something about that. Our purview is food safety. 
For hogs, we’ve requested comment on it but currently in our pilot project there is no plant that’s been able to produce product at a line speed faster than our inspectors can view it so we haven’t proposed a line speed cap in this instance.

Editor’s note: There will be a 60-day period for comment once the rule is published in the Federal Register. To view the proposed rule and for information on how to comment on the rule, visit the FSIS website. 

For more stories, go to  www.meatingplace.com