What’s behind the New Swine Slaughter Inspection System?


By Chuck Jolley, Food Safety News by Marler Clark

January 10, 2020


Q&A Analysis


The Hill, a Washington-based news publication, recently published a story about the New Swine Slaughter Inspection System (NSIS), an outgrowth of the U.S. Department of Agriculture’s Food Safety Inspection Service (FSIS) 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 percent 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 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.”


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 takes a swab and a petri dish.


The USDA believed 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. Their research was designed to bring food safety practices from its mid-20th century roots to the 21st century, a nearly 60-year leap forward.


Still, the FSIS plan met with considerable controversy. To learn the facts as FSIS saw them, I called on Mindy Brashears. She was a professor of food science at Texas Tech University until she was nominated by President Trump to lead the FSIS.


Coming on to the scene 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. I asked her some questions about the program and her reactions to it.


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?


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 ... 


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? ...


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? ...


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?   ...


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? ...


Q. The rollout has just begun. How is it going? Who’s onboard? What are some of the objections and “attaboys” you’ve heard? ...


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