but it does not tie him to a bird by bird ante-mortem and post-mortem type examination developed 50 years ago for red-meat animals.

On the basis of past experience of poultry industry and inspection officials working together to bring about more efficient methods along with being economical, it would appear to be highly desirable to leave to the discretion of the Secretary the circumstances which ante-mortem inspection should be made under in view of the greatly increased cost which would be entailed by such inspection and the lack of a definite knowledge as to its benefit.

Sixth, S. 3588 gives ample time for plants to qualify for compulsory inspection. Any plant that cannot be ready by July 1, 1958, to meet regulations pertaining to inspection, for wholesomeness, will never be ready. We feel that this is ample time.

Seventh, S. 3588 prevents overlapping and dual functions between agencies, in the same manner in which overlapping functions are prevented by Federal Food and Drug Act and Meat and Inspection Act.

Under S. 3588 the Secretary of Agriculture has certain jurisdiction relating to the inspection and processing level and the Food and Drug Administration would have jurisdiction and responsibility for the product after processing operations have been completed.

S. 3983 does not spell out the authority of each agency and consequently there would develop an intolerable duplication of functions and endless cost and confusion.

Eighth, S. 3588 provides for cooperation between Federal and State governments in inspection programs, which we in the Southwestern Association want in an inspection program.

We hope the Senate committee will recognize our industry recommendations.

We are the people that pioneered inspection of poultry for wholesomeness, and paid the bill for the many employees of the inspection branch of Agricultural Marketing Service, United States Department of Agriculture, who have developed an inspection program that gives the consumer a good wholesome product.

S. 3588 provides for those things experience has taught us are needed, such as:

One, dignity to program of inspection, headed up by our own Secretary of Agriculture.

Two, flexibility, to use new improved techniques that are now efficient, as well as economical.

Three, kept in a department that knows the problems of the poultry processes.

Four, explains the responsibility of each administration with which we have to work.

Five, gives us opportunity to work with Federal Government on State grading programs so we may have Federal-State grading programs in poultry products.

Six, not to hasten effective date which could create expensive problems to both producer and consumer.

Any plant should be given a reasonable time to become equipped for compulsory inspection.

None of the above is found in S. 3983 which shows the impracticability of the proposals contained therein.

Again we express our appreciation to the committee for affording the Southwestern Association this opportunity to present its views on these two bills.

Senator CLEMENTS. Mr. Kumpe, have you had an opportunity to look at the suggested amendments to S. 3588 that were made by the Department of Agriculture?

Mr. KUMPE. I have not.

Senator CLEMENTS. If you desire, or those others in your group, who desire to examine the suggested amendments to 3588 that were made by the Department of Agriculture, and I can assure you there are many of them, why, if you desire to submit a supplementary statement commenting on those suggested amendments, the committee will be glad to have them if you can give it to us within the next 5 or 6 days. Copies of those suggested amendments are here, and if you would, perhaps not only you but anyone else who is here today, who would wish copies of the amendments to the bill that were suggested by the Department of Agriculture, you can get them from the clerk of the committee at any time during the day, and if any of you would like to revise your recommendations after you have seen the departmental suggestions, you may do so.

Mr. KUMPE. Thank you, sir.

Senator CLEMENTS. I see you have another person representing this Southwestern Association, Mr. Youngblood.

Are we going to receive testimony from people representing the same association?

Mr. KUMPE. I was to read the brief, and Mr. Youngblood

Senator CLEMENTS. I was going to ask Mr. Youngblood if he desired to state for the record a concurrence in the statement that has been made by Mr. Kumpe this morning?

STATEMENT OF OVID YOUNGBLOOD, YOUNGBLOOD POULTRY, WACO, TEX., REPRESENTING THE SOUTHWESTERN ASSOCIATION

Mr. YOUNGBLOOD. Yes.

Senator CLEMENTS. For the record, this is Mr. Youngblood representing the Southwestern Association, is that correct?

Mr. YOUNGBLOOD. That is correct.

Senator CLEMENTS. Do you desire to make a statement? The committee will be glad to hear you.

Mr. YOUNGBLOOD. No other than concurrence with Mr .Kumpe's statement.

Senator CLEMENTS. Thank you very much, Mr. Youngblood.

Before Dr. Carpenter presents his views, I would like to say to the representative of the Department of Agriculture, who is here, you heard at the last hearing a number of criticisms of the operation of the voluntary system. If the Department would like to present some statement to the committee with reference to those criticisms, the committee would be very glad to have them, and I take it that if you desire to present a brief on those criticisms you could certainly do it in the next few days.

Mr. NATHAN KOENIG. The Department would be glad to comply with the subcommittee's request.

SUPPLEMENTARY STATEMENT FILED BY THE UNITED STATES DEPARTMENT OF AGRICULTURE WITH REFERENCE TO CERTAIN TESTIMONY OF WITNESSES CONCERNING THE USDA POULTRY INSPECTION SERVICE

(1) Existing poultry inspection programs are not administered by qualified veterinarians.-These are the facts: (a) The Chief of the Poultry Inspection Branch, Agricultural Marketing Service, is a graduate veterinarian. He has four key assistants, each of whom is also a graduate veterinarian.

(b) The poultry inspection service maintains four area offices-Philadelphia, Pa; Chicago, Ill.; Des Moines, Iowa, and San Francisco, Calif. Each area office is in charge of an area supervisor and designated assistant, both of whom are graduate veterinarians.

(c) Circuit supervisors supervise the activities of a group of plants within regions of an area. There are 9 circuit supervisors in the poultry inspection service each of whom is a graduate veterinarian.

(d) There are also 234 graduate veterinary inspectors in charge at poultry processing plants throughout the United States.

(e) There are 125 civil servant lay inspectors who are supervised closely by graduate veterinarians.

(2) AMS licenses company employees.-The Agricultural Marketing Service uses licensed company employees who are responsible for sanitation in plants producing dressed poultry. Poultry produced in these plants does not bear the inspection legend. These licensees operate under the direction of a civil service supervisor. Whenever an application is received for the sanitation service, the plant is visited by the Federal area supervisor who inspects the plant facilities and operating procedures. Unless the plant complies with the strict sanitary requirements of the Department's regulations the application for service is rejected. If the plant qualifies, however, and there is an experienced qualified employee in the plant, he is designated, i. e., licensed, as the one person in the plant who will be held primarily responsible for sanitary conditions and procedures in such plant. The sanitary conditions and precedures are also closely checked by a civil servant area supervisor who visits the plant at least once and often several times a month. The periodic check by area supervisors conforms to the practice followed in supervising food establishments by local governments or the supervising of the manufacture of biologicals for human use by the Public Health Service. In such cases a governmental employee is not stationed at all times in a particular plant, but the plant's facilities and procedures are first determined to be acceptable and thereafter frequent checks are made to see that the acceptable conditions are maintained. Under the Department's program, in addition to such official checks, a responsible company employee is designated to supervise the continuous maintenance of proper sanitary conditions at all times. The so-called licensing of such an employee is for the dual purpose of clothing him with official authority to direct the immediate elimination of any insanitary conditions which might develop and to have someone upon whom responsibility may be fixed in the event of violations. The subject was discussed with a Public Health Industry Advisory Committee on August 3, 1951, and this committee indicated that results are more important than type of employment. However, because the purpose of licensing company employees has become widely misunderstood, the Department is following a policy of transferring responsibilities from licensed company employees to civil servant employees as rapidly as possible. The effectuation of this policy has been retarded by the magnitude of the sanitation program and the difficulty in obtaining qualified personnel willing to accept civil service appointments of uncertain tenure in view of the intermittent nature of the work.

(3) AMS transfers inspectors upon industry request. It was testified that "** ** should a company want to have an inspector transferred and request same, and be willing to pay the cost of his transportation and the cost of the new inspector's transportation to the plant, it may achieve such result." This statement is not correct. The decision to move inspection personnel is at the sole discretion of the Department of Agriculture. The Agricultural Marketing Service regulations requiring companies to pay the cost of moving inspection personnel at their request was to discourage such requests. The language may have been ill advised, but no company has ever paid such costs, and no employee would be transferred just because a company requested it.

(4) Aspersions on the integrity of the Poultry Division.-Testimony refers to the Agricultural Research Service as an agency with integrity and a desire to protect the public. The Department agrees with this statement but thoroughly

disagrees with the charge that such is not the case with respect to the Poultry Division. The integrity of the Poultry Division has been demonstrated time and again in its inspection work as evidenced by the almost universal acceptance of its inspection marks as proof of wholesomeness.

(5) Conflict between the inspection service and other services and failure to protect the consumer.-The charge is made that AMS is not concerned with the protection of the consumer, that a conflict of interest exists in the inspection, grading, and sanitation programs, and that attempts to improve the inspection service have been penalized. These charges are not warranted by the facts. All services are refused or suspended from plants for failure to comply with sanitary requirements. There is a very close relationship between the inspection program and the sanitation and grading programs in poultry processing plants. The sanitary requirements are prerequisites to inspection and also to grading where it is used. In plants using the inspection service, but not grading, the veterinary inspector-in-charge has the responsibility for sanitation as well as inspection for wholesomeness. In plants that also use the grading service the responsibility for sanitation is upon both the inspector and the grader. This is done in order to provide more complete supervision in the various processing rooms of the plant. However, the veterinary inspector-in-charge of the plant has overall responsibility for complete compliance with all sanitary regulations. The Department does not discourage, but actively invites and welcomes, suggestions from employees for the improvement of the services.

(6) Army has no confidence in the Poultry Inspection Service.-The Department of Defense has used the AMS poultry inspection service as a basis for buying ready-to-cook poultry in the same manner as it uses the red meat inspection service of the Agricultural Research Service. All procurement specifications used by the Armed Forces for obtaining poultry products require inspection for wholesomeness by the poultry inspection service of AMS or by the Veterinary Corps of the Department of Defense, the latter performing_inspections only in plants where AMS poultry inspection service is not used. Billions of pounds of poultry have been accepted by the Armed Forces on the basis of certification by the Department of Agriculture's poultry inspection service.

(7) Poultry processed in AMS-approved plants has been seized.-Some poultry processed in plants operating under the poultry inspection program has been seized by Federal, State, or local authorities. This is not unique with poultry. It happens with other foods which are not handled properly after leaving the processing plant. No food inspection program can guarantee that product may not become contaminated or go out of condition after it leaves the processing plant-particularly when a perishable product is being produced. Poultry seizure instances cited in the testimony are, in fact, isolated cases. With respect

to the inspection for wholesomeness program, seizures are extremely rare when consideration is given to the fact that over a billion pounds of ready-to-cook poultry is eviscerated each year under this inspection program. This product consists of many small units since the average weight of each unit in the case of poultry is relatively small-fryers averaging perhaps about 2 to 2%1⁄2 pounds and turkeys averaging 10 to 11 pounds. Testimony pointed up one incident in which the Department was notified concerning poultry from a plant in Virginia which had the Department's inspection service. In keeping with practice, the Department did take immediate corrective action. This vigilance is one of the reasons why the Department's poultry inspection service compares favorably with any other food inspection service. Its record is especially commendable, considering the fact that it is purely a voluntary program without penal sanctions.

(8) Speed of the eviscerating line is too fast for adequate inspection.—Testimony charges the Agricultural Marketing Service with attempting to speed eviscerating lines. The speed of the eviscerating lines is under the control of the veterinary inspector in-charge at the plant. It is his responsibility and he is under instructions to see that speeds are not in excess of those needed to permit a proper inspection of each bird in compliance with the requirements of the regulations.

(9) Antemortem inspections.-This Department favors authority to require antemortem inspection. The Department's regulations under which the voluntary poultry inspection program is conducted provide authority for the Department to require antemortem inspection at the discretion of the Department, and this has been required where conditions warrant. However, it should be pointed out that many of the things which testimony indicated might be accomplished through antemortem inspections are subject to question. For example, the possibility of

discovering carriers of viruses such as ornithosis (psittacosis) through antemortem inspection has not been established. Birds carrying this condition may appear completely healthy when alive. Yet, upon post-mortem examination lesions and conditions of the viscera clearly indicate the presence of a systemic disturbance. The same is true of many other diseases of poultry. This Department is sponsoring a research project which is presently in the developmental stage which will be conducted to determine the type of antemortem inspection procedures and methods which will be most effective in making such inspections. (10) Allegation that people become ill from eating poultry products.-Testimony to the effect that humans became ill from eating poultry need clarification. Such occurrences would not be eliminated as a result of compulsory poultry inspection. Investigations of cases of food poisoning, including many of those cited at the hearing, reveal that most food poisoning results from mishandling the product after it leaves the processing plant and is usually the result of mishandling in the home or in public eating establishments. Since compulsory poultry inspection under the proposed legislation would apply only to the plants processing poultry for interstate commerce, a large quantity in intrastate commerce would be uninspected. Moreover, inspection, no matter how rigid, cannot guard against the mishandling or contamination which may occur after the product has left the plant where is was inspected. Other regulatory authorities have jurisdiction in this field, and there is no means except through education to insure proper handling to protect the product after it reaches the ultimate consumer.

(11) Extent of coverage questioned.-From the testimony the inference might be drawn that the merchandising of unwholesome poultry would be completely eliminated through the operation of a compulsory poultry inspection program under Federal law. Such a law, of course, would have little impact on poultry moving in intrastate commerce. This area of regulation will remain the primary responsibility of local authorities.

(12) AMS permits intermittent inspection.-Section 70.15 of the Department's poultry inspetcion regulations issued by the Agricultural Marketing Service governs the extent of inspection required in official plants. Its wording is as follows:

"All dressed poultry that is eviscerated in an official plant where inspection service is maintained shall be processed in a sanitary manner. Dressed poultry may be eviscerated in such plant without inspection for condition and wholesomeness but uninspected and inspected operations may not be carried on simultaneously except in plants where processing rooms including packing rooms' are separate or when by other acceptable means effective segregation of inspected and uninspected product is maintained. Evisceration without inspection may be conducted only if an inspector or governmentally employed grader is on duty at all times when such operations are carried on for the purpose of (a) effecting adequate segregation of inspected and uninspected products, (b) control of official inspection marks and grade marks, and (c) supervision of sanitation in the official plant."

It should be kept in mind that the present poultry inspection program is a voluntary program, the only type for which the Department has any statutory authority. It should be pointed out that even under compulsory poultry inspection covering the interstate movement, the same brand name could appear on the inspected product as could appear on an uninspected product which could move in intrastate commerce. There is nothing in any poultry inspection bill before Congress at this time which would prohibit a processor packing a product in a plant not under inspection for intrastate sales from using the same brand name as he would use in a packing plant under inspection required for interstate sales.

(13) Consumers are misled by the sanitation mark.-The sanitation identification label is used only on bulk containers. It cannot be used on individual poultry carcasses offered to consumers and, therefore, could not possibly mislead them. The label plainly states that the product has not been inspected for wholesomeness or graded for quality. The Food and Drug Administration reviewed this label and the conditions under which it is permitted to be used and that agency voiced no objections.

(14) AMS does not cooperate with State and local health authorities.—The Poultry Division of the Agricultural Marketing Service has a long history of cooperation with State and local health authorities and various agencies. Any important proposals for changes in the poultry inspection regulations are circulated, among others, to State and local health authorities and their comments are solicited. Also, the same mailing list is used to give notice concerning any