Food safety and information safety revisited

In Food safety, information safety I reacted to Tim Eberly’s newspaper article on food safety which, I said, didn’t acknowledge an important primary source, Elisabeth Hagen’s blog post, which states the rationale for the poultry inspection policy changes that were the subject of the article.

I’ve since spoken to Tim Eberly about how he researched and wrote that story. He had, in fact, seen Elisabeth Hagen’s blog post, along with many other documents, some of which I’ll cite and link to here. And the rationale she presented, which I complained was missing from the article, is in fact there, albeit in a more diluted form.

In theory the article could have used quotes from Hagen’s blog, or from a HuffPo blog by her boss Alfred Almanza. But in practice, as Tim Eberly points out, these are blogs in name only, effectively they are press releases, and a reporter wants to advance the story beyond that. Unfortunately FSIS declined to be interviewed for the story.

All that said, I was still left wondering about the crux of the story. A decade ago the FSIS began a pilot program that would shift responsibility for direct inspection of slaughtered chickens from FSIS workers to poultry-plant workers. On the face of it, that sounds like a terrible idea, and there’s been lots of criticism ever since. But the FSIS rationale — that its resources are better spent assuring all-up compliance with safety standards, to prevent upstream contamination so less needs to be found downstream — sounds credible too.

Now the pilot program is slated to expand. What should we think about that? You’ll have to decide for yourself. Here are some sources I’ve rounded up that may help.

• The proposed rule: Modernization of Poultry Slaughter Inspection

  http://www.fsis.usda.gov/OPPDE/rdad/FRPubs/2011-0012E.htm, 4/26/2012

• Comments on the rule

  http://www.regulations.gov/#!searchResults;rpp=25;po=2250;s=FSIS-2011-0012, April-May 2012, total of 2260 comments

• Alfred Almanza, FSIS administrator: blog post / news release

  http://www.fsis.usda.gov/News_&_Events/NR_041312_01/index.asp, 4/26/2012 (also http://www.huffingtonpost.com/alfred-v-almanza/chicken-inspection-new-policy_b_1424136.html, 4/13/2012)

  “We have more than a decade of experience slaughter running at 175 bpm, the proposed maximum line speed in the rule. And the data is clear that in these plants, the poultry produced has lower rates of Salmonella, a pathogen that sickens more than 1 million people in the U.S. every year. These plants also maintain superior performance on removing the visual and quality defects that don’t make people sick. Those are the facts, based on the data.”

• FSIS Self-evaluation of HACCP Inspection Models Project (HIMP)

  http://www.fsis.usda.gov/PDF/Evaluation_HACCP_HIMP.pdf, Aug 2011

  “Because fewer inspectors are required to conduct online carcass inspection in HIMP establishments, FSIS is able to conduct more offline food safety related inspection activities. HIMP establishments have higher compliance with SSOP and HACCP prevention practice regulations and lower levels of non-food safety defects, fecal defect rates, and Salmonella verification testing positive rates than non-HIMP establishments. These data indicate that HIMP inspection provides improvements in food safety and other consumer protections.”

• Independent review of the HACCP-Based Inspection Models Project by the National Alliance for Food Safety Technical Team

  http://www.fsis.usda.gov/OPPDE/nacmpi/Nov2002/Papers/NAFS97.pdf, 2002

  Conclusions

  1. The authors urge continued FSIS oversight and continuous re-evaluation as HIMP is more broadly implemented.

  2. At this time, no convincing arguments were identified which indicate that adoption of the modified system, under regulatory supervision, would increase risk.

  3. More importantly, the authors find that there are several lines of evidence that strongly argue process improvements from the consumer perspective as related to adoption of the HIMP system

• GAO report: Weaknesses in Meat and Poultry Inspection Pilot Should Be Addressed Before Implementation, 2001

  http://www.gao.gov/assets/240/233016.pdf

  “It is questionable whether the data generated by the project are indicative of how all of the chicken plants’ inspection systems would perform if modified inspections were adopted nationwide. First, the chicken pilot that USDA designed lacks a control group — a critical design flaw that precludes a comparison between the performance of the inspection systems at those plants that volunteered to participate in the pilot and that of plants that did not participate. Without a control group, USDA cannot determine whether changes in inspections systems are due to personnel changes or other possible explanations, such as the addition of chlorine rinses.”

That last item helps me contextualize the story, which ends like this:

At least one elected official wants FSIS to put the brakes on its proposal.

U.S. Sen. Kirsten Gillibrand, D-New York, asked GAO to conduct another audit of FSIS’s pilot program. The agency said it will do so soon. She then sent a letter to Vilsack, asking him to delay the changes.

“I do not believe USDA should yield inspection responsibilities to plant personnel that have an inherent conflict of interest unless [the pilot program] can be independently verified to be safe and effective,” Gillibrand wrote.

Vilsack wrote back to Gillibrand in a letter filled with FSIS’s talking points on the issue. But more notable is what’s missing: Vilsack doesn’t address the senator’s request.

Reading between the lines, advocates say, that doesn’t spell good news.

I’m now inclined to agree. It sounds like there should be an independent audit of the pilot, and better analysis of the tradeoffs between using FSIS inspectors to monitor plants for all-up compliance with safety standards versus using them side-by-side with plant inspectors looking at birds.

To get to this point, though, I had to work pretty hard to find and evaluate the reporter’s sources, and understand his process. I’m grateful to Tim Eberly for taking the time to help me. I sure wish, though, that journalistic convention permitted him to cite and link to the sources he used.