Record Statement of: Joshua E. Neiman Food and Allied Service Trades, AFL-CIO To: Subcommittee on Oversight of Government Management On: U.S. Department of Agriculture Poultry Inspection System MR. CHAIRMAN AND MEMBERS OF THIS DISTINGUISHED SUBCOMMITTEE, LET ME CONGRATULATE YOU FOR HOLDING HEARINGS ON SUCH AN IMPORTANT ISSUE. MY NAME IS JOSH NEIMAN AND I AM A LEGISLATIVE REPRESENTATIVE WITH THE FOOD AND ALLIED SERVICE TRADES DEPARTMENT OF THE AFL-CIO. FAST REPRESENTS 16 UNIONS AND APPROXIMATELY 3.5 MILLION WORKERS IN THE RAPIDLY GROWING SERVICE ECONOMY. THE ISSUE OF POULTRY INSPECTION IS NOT NEW TO FAST OR ANY OF ITS AFFILIATES. THE LABOR MOVEMENT HAS LONG PROMOTED LEGISLATION THAT PROTECTS WORKERS AND CONSUMERS FROM CONTAMINATED MEAT. NOW THERE IS GOOD REASON FOR REVIVED CONCERN. SOME OF THE PEOPLE WHO HAVE TESTIFIED BEFORE THIS COMMITTEE WOULD LIKE YOU TO BELIEVE THAT VISUAL INSPECTION IS USELESS: BIRDS DON'T SUFFER FROM VISUALLY-DETECTABLE DISEASES, AND ALL DISEASES THAT BIRDS NOW SUFFER FROM CAN BE DETECTED WITH MICROBIOLOGICAL TESTS. IT'S TRUE THAT THE VISUAL INSPECTION SYSTEM WE NOW HAVE CAN'T DETECT SALMONELLA, BUT CAN THE PROPOSED MICROBIOLOGICAL TESTS DETECT A CANCEROUS TUMOR? WE NEED TO USE OUR HUMAN RESOURCES IN THE MOST EFFICIENT WAY TO DETECT DISEASE IN FOOD. HOWEVER THERE IS NO EVIDENCE THAT MICROBIOLOGICAL TESTS ALONE ARE AN EFFICIENT WAY TO DETECT THE MOST COMMON DISEASES IN POULTRY. SOME DISEASES ARE MOST EFFICIENTLY DETECTED VISUALLY, AND SOME DISEASES ARE MOST EFFICIENTLY DETECTED MICROBIOLOGICALLY. BUT BEYOND THIS, THOSE MICROBIOLOGICAL TESTS SIMPLY HAVEN'T BEEN DEVELOPED YET. -2 THE VISUAL INSPECTION SYSTEM WAS INTRODUCED FOR A REASON, AND WE CONTINUE TO NEED IT FOR THE SAME REASON--IT DETECTS DISEASE. THE NATION'S PRESENT INSPECTION SYSTEM IS NOT ADEQUATELY PROTECTING EITHER WORKERS OR CONSUMERS. BUT THE PROPOSED INSPECTION SYSTEM, HEAVILY WEIGHTED TOWARD AND DEPENDENT ON SCIENCE, IS NOT TECHNOLOGICALLY READY TO BE PUT INTO USE. (NAS) ACCORDING TO THE RECENT NATIONAL ACADEMY OF SCIENCES REPORT ON POULTRY INSPECTION, THE PROPOSED SPOT CHECK, BASED ON RISK ASSESSMENT IS A GOOD PROGRAM BUT ONLY IN THEORY. THE MACHINERY, TECHNOLOGY, AND FORMULA ARE NOT YET READY FOR MASS USE. THE REPORT SAYS: MINIMIZING MICROBIAL CONTAMINATION ON POULTRY IS A WORTHWHILE OBJECTIVE, BUT IT IS PREMATURE TO ESTABLISH FORMAL ACCEPTABLE OR UNACCEPTABLE. DATA REQUIRED THE NAS REPORT DOES OFFER A PROMISE OF INCREASED SAFETY FOR US ALL. BUT THAT SAFETY IS AT LEAST TEN YEARS DOWN THE ROAD. GOVERNMENT-REGULATED INSPECTION MEANS THAT MOST BAD POULTRY NEVER GETS TO THE CONSUMER, BECAUSE IT IS POSSIBLE TO DETECT GROSS PHYSICAL DISORDERS WITH A BIRD-BY-BIRD SYSTEM OF INSPECTION. Food and Allied Service Trades Department, AFL-CIO -3 MANY PRODUCERS FEEL THAT GETTING RID OF VISUAL INSPECTION WILL REDUCE UNIT COSTS AND RETAIL PRICES OF THEIR PRODUCT. YET, THE NAS REPORT GIVES US NO ASSURANCE THAT MICROBIAL INSPECTION WILL ACTUALLY DETECT MORE CONTAMINATED POULTRY. SO WHAT PROGRESS DOES THIS PROPOSED INNOVATION REALLY ACHIEVE? PROBLEMS WITH BIRD-BY-BIRD INSPECTION INCREASED WHEN PRODUCERS INTRODUCED NEW MACHINES TO SPEED UP PRODUCTION, WITHOUT CONSIDERING THE EFFECTS THEY WOULD HAVE ON MICROBIAL CONTAMINATION. THE MECHANICAL EVISCERATOR IS A PERFECT EXAMPLE. THIS MACHINE IS MUCH MORE LIKELY TO PUNCTURE THE INTESTINE, SPREADING FECAL MATTER AND CONTAMINATING THE MEAT. ANOTHER EXAMPLE IS THE DE-FEATHERING MACHINE. BECAUSE THE LINE IS FORCED TO OPERATE AT SUCH A RAPID PACE, MACHINES BECOME CLOGGED WITH DIRT AND BACTERIA. THERE IS NO TIME TO CLEAN THE MACHINES, SO BACTERIA IS LITERALLY PUSHED THROUGH THE SKIN OF THE BIRD AND INTO THE FLESH. STILL ANOTHER EXAMPLE OF HOW SPEEDING UP THE CHAIN HAS INCREASED THE RISK OF CONTAMINATION IS THE SIMPLE FACT THAT WATER USED TO RINSE THE CARCASSES IS NOT CHANGED OFTEN ENOUGH TO ASSURE CLEAN BIRDS. IT ONLY TAKES ONE BAD BIRD TO CONTAMINATE THE WHOLE DAY'S PRODUCTION WHEN FILTHY WATER IS USED OVER AND OVER. IRONICALLY, IF WE RADICALLY CHANGE THE PRESENT INSPECTION SYSTEM, WE MAY IN FACT BE INVITING UNSCRUPULOUS PRODUCERS TO PASS EVEN MORE CONTAMINATED MEAT ON TO THE CONSUMER BECAUSE THE CHAIN SPEED WILL RACE ALONG UNCHECKED. Food and Allied Service Trades Department, AFL-CIO WITHOUT BIRD-BY-BIRD INSPECTION BY GOVERNMENT EMPLOYEES, MORE POULTRY THAT IS ON THE BORDERLINE BETWEEN EDIBLE AND NON-EDIBLE WILL BE SHIPPED TO STORES FOR CONSUMPTION. HOW MANY TIMES HAVE WE ALL FELT A SMALL STOMACH ACHE OR THE "24 HOUR BUG?" THE SICKNESS IS OFTEN THE RESULT OF A MILD CASE OF FOOD POISONING THAT CAN BE CAUSED BY EATING CONTAMINATED POULTRY. USUALLY THE ILLNESS ONLY LASTS A SHORT TIME. SOMETIMES, HOWEVER, IT CAN KILL. LAST YEAR APPROXIMATELY 2,000 PEOPLE DIED AS A RESULT OF SALMONELLA POISONING. INDUSTRY REPRESENTATIVES INSIST THAT MOST PRODUCERS ARE HONEST AND SELL ONLY QUALITY PRODUCT BECAUSE THEIR SALES DEPEND ON CONSUMER CONFIDENCE. UNFORTUNATELY, THE CONSUMER DOESN'T KNOW WHO TO BLAME WHEN HE OR SHE GETS MILD FOOD POISONING. PEOPLE COULDN'T TELL THAT MEAT WASN'T SAFE IN THE 1910S, UNTIL UPTON SINCLAIR TOLD THEM THAT IT WAS PRODUCED UNDER DISGUSTING CONDITIONS. WE SIMPLY CANT TELL HOW MANY CASES OF FOOD POISONING ARE CAUSED BY CONTAMINATED MEAT. THERE MAY BE AN ENORMOUS NUMBER OF CASES OF MILD FOOD POISONING WHICH ARE NEVER REPORTED. IT'S NOT POSSIBLE TO PROVE WHERE THE MEAT SPOILED WAS IT PROCESSED UNDER BAD CONDITIONS, OR WAS GOOD MEAT HANDLED POORLY BY SHIPPERS, RETAILERS, OR EVEN CONSUMERS? THE MOST EFFECTIVE WAY TO PROTECT THE PUBLIC AND CERTAINLY THE WORKER, IS TO ENFORCE COMPREHENSIVE INSPECTION IN PROCESSING PLANTS. Food and Allied Service Trades Department, AFL-CIO -5 I DO NOT MEAN TO SUGGEST THAT THE INDUSTRY DOES NOT CARE ABOUT CONSUMER HEALTH. IN FACT MOST PRODUCERS PROBABLY HOLD CONSUMER SAFETY IN THE HIGHEST REGARD. BUT IT IS FOOLISH TO RELY UPON A COMPANY TO BE BOTH PRODUCER AND WATCHMAN. THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) HAS RECENTLY LEARNED THIS LESSON AS IT UNCOVERS CASE AFTER CASE OF FRAUDULENT INJURY AND ILLNESS RECORDKEEPING A SYSTEM OF EMPLOYER SELF-REGULATION DESIGNED AS A WAY FOR THE GOVERNMENT TO SAVE MONEY. WE NEED A METHOD TO KEEP THE FEW UNSCRUPULOUS PRODUCERS IN CHECK. WE ARE IN DIRE NEED OF AN INSPECTION SYSTEM THAT PROTECTS THE CONSUMER AS WELL AS THE WORKER. YES, THE CURRENT SYSTEM NEEDS CHANGES, BUT WE CANNOT RESPONSIBLY ELIMINATE BIRD-BY-BIRD INSPECTION UNTIL WE HAVE A PROVEN SYSTEM TO PUT IN ITS PLACE. FAST SUGGESTS THAT THE DE-FEATHERING MACHINES BE CLEANED AT REGULAR INTERVALS DURING A SHIFT THEREBY PREVENTING THE INJECTION OF BACTERIAL CONTAMINATION THROUGH THE CLEANING PROCESS. FAST RECOMMENDS THAT THE CHILLING WATER, THE SO-CALLED FECAL SOUP BE CLEANED DURING THE SHIFTS AND THAT IT BE DISPOSED OF OUTSIDE OF THE PLANT. FOOD SAFETY INSPECTION SERVICE (FSIS) ALREADY REGULATES LINE SPEEDS TO FACILITATE INSPECTION. FAST PROPOSES THAT ONE WAY TO IMPROVE THE SAFETY OF POULTRY PRODUCTS IS TO MANDATE A LINE SPEED FOR ALL POULTRY PRODUCERS THAT IS SLOW ENOUGH SO THAT NO INTESTINES ARE PUNCTURED. Food and Allied Service Trades Department, AFL-CIO |