and other persons shipping or receiving poultry to make records showing the movement of poultry in commerce available to the Department on his request. It also further provides that evidence obtained from any person shall not be used in a criminal prosecution against such person. It further exempts carriers from other provisions of the act which to us seems a most desirable provision. provisions of section 10 in the bill give the Secretary of Agriculture the same authority as is given to the Food and Drug Administration under the Food and Drug Act and, therefore, seems to us to be the most desirable provision.

The

Now, on page 12, section 12, under penalties, the proposed amendment of the Department which would change the period of maximum penalties from 6 months to 1 year and from 1 year to 2 years and the increase in the maximum fine as recommended by the Department amendment would bring the penalties in line with the Meat Inspection Act and the Food and Drug Act which, while we believe they are unnecessarily severe, we would not interpose objection.

We do, however, seriously question the necessity or desirability of the new provision beginning on line 13 which would purport to make the employer criminally liable for an act of an employee regardless of whether the employer had any knowledge or part in such violation. No such provision is contained in either the Meat Inspection Act or the Food and Drug Act and we do not believe such a drastic provision is necessary for the efficient administration of this proposed legislation. Therefore, we would strongly recommend its deletion.

Those are our basic comments, Senator Clements, on the amendments as proposed by the Department of Agriculture. I would like to offer for the record one of the sections that I briefed, which perhaps I should not, because in the processing industries throughout the United States which we represent so broadly, we published several years ago, in 1952, a manual on poultry-plant sanitation which I would like to offer for the record.

Senator CLEMENTS. What is the length of it, Doctor?

Dr. CARPENTER. It can be taken from the covers, you see.
Senator CLEMENTS. What is the length of it?

Dr. CARPENTER. I don't wish to read it.

Senator CLEMENTS. It is 10 or 12 pages?

Dr. CARPENTER. About 15 pages.

Senator CLEMENTS. It will be placed in the record at this point. (The manual referred to is as follows:)

POULTRY PLANT SANITATION

Institute of American Poultry Industries

MEET JOE SMITH

Suppose you didn't keep your processing, packaging, and merchandising operations up to date. You wouldn't be in business very long, would you?

But how about your plant sanitation? Is is up to date too? Or didn't you think it would be worth the bother? Or have you just been too busy to give it much thought?

If so isn't it time to do something about it? You can't afford to put it off too long.

For one thing-clean wholesome food sells better-consumers prefer it.

For another as a food processor, you're serving the public-and you have a responsibility to consumers.

And then there are city, State, and Federal regulations that make it illegal to operate an unsanitary food establishment.

So you really need good, up-to-date sanitation-don't you-the same as you need modern processing methods?

And just what does it take to keep a plant clean? To have a clean operation? To turn out clean products? This story of Joe Smith's operation tells what it takes. It tells how one poultry processor-we call him Joe Smith-keeps his plant, his operations, and his products clean and sanitary.

You can use Joe's operation to check up on your own practices. You can put some of Joe's ideas to work in your own plant. You can make the same improvements Joe has made.

Not that he claims his operation is the last word-there may be other operations better than his. But he's doing a good job on sanitation. You can do as well or better. Just don't get discouraged when you start. If you can't do everything at once-take a few steps at a time. But take them. They'll pay off for you. And you'll like the results.

New developments in processing and sanitation will be coming along from time to time-and Joe will be keeping pace with them. As he makes these changes and improvements, we plan to add some new chapters to this story.

And if and when Joe builds a new plant-or does some major remodeling on his old one-we'll add a special chapter on building good sanitation into new construction.

This story could not have been written without the fact supplied by the institute's research committee and its special subcommittee-people with considerable training and experience in practical, effective plant sanitation. For their excellent help, we are particularly indebted to J. L. Cherry, O. H. Davis, T. L. Hugé, R. W. Kline, C. H. Koonz, J. R. Kurtz, W. C. Loy, W. W. Moss, H. B. Richie, R. W. Schultz, and A. J. Steffen, Jane Wasmuth, editor.

YOUR FIRST IMPRESSION

As you drive up to Joe's plant you think to yourself, "If he keeps the inside of his plant as neat and clean as he keeps the outside he must turn out a good, clean product."

You look at the grounds around the plant. They're neat and orderly. The grass is cut. You don't see any tall weeds. You don't see any old equipment or trash. And you have a feeling Joe must be a pretty smart businessman. Obviously, he isn't keeping his premises well groomed just for fun. He must know first impressions count a lot. And he must know he can't do a good job of controlling inspects and rodents if he's got a lot of weeds and junk in his yard. Of course, he's probably pretty proud of the way things look, too. And he's got a right to be.

You wonder what Joe's doing about drainage. He must have a good system. You don't see any water standing around the plant. No public nuisance or health hazard here. Joe's used crushed rock to fill in some low areas (he could have used cinders instead, of course, or some other material that would do the same job). And he's put black top on areas that have to stand a lot of traffic. Concrete would do the same trick, of course.

You sniff the air. It smells clean and fresh. Joe's licked any problem of objectionable odors from sewage all right. He must be getting rid of his liquid and solid wastes so they don't accumulate and create a public nuisance or health hazard. So he doesn't have to worry about meeting local regulations on waste disposal. And you see he's using covered metal containers for feathers, blood, and other wastes. This prevents fly breeding. It discourages rodents. And you don't have to hold your nose.

Another thing, Joe's hard-surfaced his driveways-to help keep dust out of his plant. Here again, he could have gotten the same results by oiling them or by using calcium chloride whenever they started to get dusty. You can keep calcium chloride from corroding trucks and other equipment by adding an inhibitor-like Banox.

And what about the plant itself? As you'd expect, it looks neat and clean, too. The outside is in good repair. You can tell the wooden structures are painted regularly. The docks are solid and substantial. They're clean and free from refuse. You look under the dock, thinking maybe Joe missed one. But no, sir, it's clean as a whistle, too-no waste paper-no broken bottles-no weeds.

Joe's glad to see you.

NOW STEP INSIDE

In fact he can hardly wait until you get your coat off before he starts showing you around.

As you take off on your tour of Joe's plant, you notice a lot of things. The floors first.-In the rooms where Joe processes or stores poultry products, he's made his floors out of materials he can clean easily. They're smooth and they're clean. There aren't any puddles around, and all of his drains are trapped. He showed us where he'd taken out all the wooden molding from the floors and walls, and calked all the cracks up tight. "Couldn't really get these rooms clean before," he explained. "That white traffic border isn't absolutely necessary, but it's a big help. Lightens up the corners." He pointed to a white strip about 12 inches wide around the edge of the floor and 12 inches high around the walls. And the walls and ceilings. In rooms where he handles or stores poultry products Joe's made a special point of building the walls, ceilings, partitions, posts, doors, and all other parts of the room structure, with materials and finishes he can clean easily and thoroughly. Here, too, Joe has all the cracks and crevices calked and sealed up so insects and rodents can't hide out in them.

Outside openings.-Joe's doors, windows, skylights, transoms, ventilators, and other openings are tight fitting and free of holes. He uses screens, fans, and other suitable devices on the outside openings, to keep insects from coming in. His outside doors are self-closing. That is, except for receiving and shipping platforms. When the outside doors are closed they don't clear the walls or floors more than one-fourth inch. His screens fit tight, and his screen doors swing out-not in. The doorways that stay open a good part of the time aren't one bit larger than they have to be. And he uses fly fans.

The window sills and door casings are flush with the walls—at least they are on the inside. That way the walls are easier to clean, and the sills don't provide such an inviting home for insects.

On some of his outside doors Joe has metal flashing 8 inches or more high on the outside. "We feel it helps keep rodents from ruining those doors when they try to get in," Joe explained.

These built-in controls are particularly important in the feeding station and receiving room, Joe pointed out, because other rodent and insect controls just won't do the job in those places.

Lighting. You don't have to strain your eyes to see things in Joe's plant. He believes in providing plenty of light, especially for his poultry handling operations. And he keeps his light fixtures in good repair. "The State law calls for good lighting," said Joe. "Besides, it makes for better working conditions and we need it for our housekeeping inspection."

Ventilation.-Joe controls the ventilation in each room-with plenty of fresh air coming in and a good exhaust system taking out the old air. But he doesn't have the ventilation system in his feeding station connected with the ventilation system in his processing rooms. "If I did," said Joe," I might as well be processing in the feeding station-and pack the feathers and dust right in with the finished birds." On his forced-air intake system, Joe uses a filter to keep outside dirt outside. "We keep our ventilating equipment cleaned just like we do other equipment," Joe added, "so we don't spread dust and soot around instead of fresh air."

Product protection.-Joe has his different operations located and organized so his finished products-as well as equipment that's been cleaned-are protected from contamination. He's careful about using only insecticides and rodenticides approved for food-handling departments. And when he uses them he sees that they don't contaminate his poultry products or handling equipment. Whenever he treats surfaces that come in contact with poultry products, with insecticides or rodenticides, he washes the surfaces free of residues before he uses them again.

"We've learned to handle containers and equipment that come in contact with our edible products so they don't contaminate those products either," Joe said. "In fact," be added, "it's easier to be careful every step of the way. Then we don't have to try and make up for carelessness some place along the line." Joe stores the containers and apparatus he uses for his edible products entirely separate from the batteries, coops, and other equipment he uses for live poultry and inedible products.

The room where he receives his live birds is separate from his processing operations. And he's seen to it that both the receiving room and the processing room are large enough to provide plenty of space for his employees and the

equipment and products they work with. Tight-fitting, self-closing doors into processing, handling and storage areas help him protect his products from contamination too.

And he has his buildings laid out and his equipment located so he doesn't have a lot of traffic through the areas where he's handling or storing poultry products so his products are protected or out of the way where there's employee traffic-and so he can keep his finished products away from his hanging and killing operations.

"If we didn't keep insects, rodents, pets, and birds-sparrows and pigeons for example out of the plant," said Joe, "we'd be worrying all the time about their contaminating our packaging materials, our equipment, and our finished products. That's against the law. And it would certainly hurt our sales. We wouldn't want to offer the public any food we wouldn't feel like eating ourselves."

There's a lot of truth in that old saying, "An ounce of prevention is worth a pound of cure." Joe does use traps and baits for rats-and space and residual sprays for insecticides. But he's found he can't depend on them alone. If he had a lot of holes and cracks in his building-traps, baits and insecticides wouldn't do him much good. Or he'd have to use them so often he'd soon run out of money.

So Joe's processing and supply storage buildings have been thoroughly rodentproofed. All the holes in foundations have been bricked up or filled with concrete-a 1:5 mix (1 part cement to 5 parts sand). All ventilation openings are protected with %-inch galvanized wire mesh, or sheet metal with-inch perforations. Joe's used heavy sheet metal, masonry, or concrete to seal up holes and cracks under doors, around windows and chutes, and around pipes that pass through the outside building wall. Most outside doors are self-closing. And he has 8-inch strips of metal flashing along the bottom. A rat or mouse can get through an opening that isn't any larger than its head.

Joe's gotten rid of double walls and false partitions. "In my case it's cheaper," he told us, "than trying to keep hollow places like that free of insects and rodents."

"We don't leave any garbage scattered around, either," he said, "we'd be asking for trouble if we did. A stray orange peel or two and an empty pop bottle could undo a good day's work in short order. And they'd look pretty messy. We wouldn't think of doing things like that in our own homes. It's even more important here."

Joe stores his poultry products and supplies-except heavy drums at least 8 inches off the floor and 18 inches from the wall. "We need that much room to get in there when we clean," said Joe.

Where it isn't possible to screen openings where insects might get in, Joe uses a good fly fan, directed outward. If he used "electric screens" he'd back them up with 16 mesh screening-since common insects can get through openings larger than 16 mesh.

Keeping stored feed free from infestation takes extra care. Joe checks the feed itself and the whole area where he keeps it, regularly. If he finds any infested feed he removes it and then treats the source of harborage, by using insecticides and sealing any cracks or crevices. If this didn't do the trick, he might have to call in a trained fumigator.

"I haven't time to look after all these details myself," said Joe, "so I've put Bob Baker in charge. He's directly responsible for our good housekeeping-or sanitation, if you prefer. And he does a good job too. He's had training in this sort of work, and he keeps up with new products and new methods through his reading and through contacts with specialists. He gets a lot of help from State officials. And we sent him to the sanitation school the Institute of American Poultry Industries held for plant employees. He's so sold on the value of good housekeeping himself—that he's made the rest of the employees more conscious of it too. If I hadn't been sold on it a long time ago, I'd bet he would have sold me too."

Toilet facilities and dressing rooms.--None of the toilet rooms in Joe's plant open directly into any room where pouutry products are in the open. He has self-closing doors for the toilet rooms and dressing rooms. And he has outside ventilation for both. He installed toilets according to the number requirements set up in his local and State laws. And we could see right away that these toilet and dressing rooms were kept clean, in good repair, and free from insects and rodents. "One of Bob's pet peeves is a messy, dirty toilet or dressing room," said Joe, "and he goes out of his way to keep things in here just as clean and

neat as possible. The employees appreciate it-in fact, I don't think they'd be very happy any other way-and they do their part too. Not that a few of them don't slip once in awhile. But they soon hear about it from the others and it usually works out."

We noticed there were plenty of containers for refuse-cigarette butts, candy wrappers, pop bottles and the like. And we saw plain, neat signs up here and there, reminding employees to wash their hands before they went back to work. Looking inside one locker after another proved Joe was right about the employees doing their part-we didn't find a single one cluttered up with old clothes or trash. All lockers are raised up high enough so the floor can be cleaned under

neath.

All of the toilets in Joe's plant are inside. If he'd had any outside toilets on the premises, he'd have to keep them in good condition too, to meet State health regulations.

Hand-washing facilities.-Joe has lavatory basins at convenient spots, with both hot and cold running water. He prefers either foot pedals or elbow or knee controls for these. And each basin has a soap dispenser with plenty of soap in it. There are sanitary towels in towel dispensers, and suitable tilttop containers for used towels. "We don't allow employees to use a common towel," Joe said, "and we don't let them return from a toilet to a room where we're handling poultry products without first washing their hands in the lavatory basin. One of our supervisors is responsible for seeing that this sanitation measure is carried out."

Potable water supply.-Joe's water supply is ample for his uses he doesn't try to skimp on water, even though he doesn't let it go to waste either. And the water he uses is clean. And it's potable except for the water used in his condensers. He's checked with his municipal officials to be sure it's acceptable. Thanks to good planning, Joe has plenty of water available at the various spots it's needed throughout the plant. And it's protected against contamination and pollution.

There are no cross-connections between the potable and nonpotable water supply lines. Supply lines are plainly labeled so they're easy to identify.

At convenient spots throughout the plant Joe has hose connections with steam and water mixing valves—or hot water hose connections. And his water pressure is strong enough to put real force into his hosing operations. "No sense in having our hose trail from one end of the plant to the other," said Joe, "and a little trickle of water is just about as bad as no water at all."

Receiving room.-The platform used to unload live birds coming into the plant is completely separate from the rooms where Joe is handling or storing poultry products. The receiving and unloading area is built so the workers can do their jobs without being crowded. And it's built for "easy" housekeeping. Joe said the receiving room has to be checked and cleaned several times a day. His batteries and coops are cleaned after each use. And the scale pits are kept clean. Dead birds are dropped into covered metal containers marked "Inedible." Feeding station.-Some people throw up their hands when it comes to trying to keep a feeding station clean. It isn't the easiest thing in the world, but Joe feels his system is satisfactory. And he's convinced it cuts down his good housekeeping chores in the rest of the plant, especially because it controls the dust from feed and feathers. He dry cleans the floors and uses lime when necessary to keep them more sanitary and help control odors. His walls and ceilings are free from cobwebs, dust and other dirt. He uses residual and space sprays to control insects. His batteries are lined up in straight rows. Feeding troughs are filled carefully so they don't spill over. His feed mixer, trucks, buckets, and other feeding station equipment are cleaned every day. The batteries, feed pans, and water pans are thoroughly cleaned after each use-and oftener if it takes more frequent cleaning to keep the birds from standing in manure. Bags of feed are kept in neat piles-at least 8 inches off the floor and 18 inches from the wall. Refuse from the feeding station is removed every day. Metal refuse barrels are kept covered. Batteries are kept in good repair so the birds don't come in contact with droppings. Joe is gradually getting rid of his old wooden batteries-whenever he needs a new one he buys a metal one.

Battery-washing room.-Joe has a separate, partitioned enclosure where the batteries are washed, so this operation isn't directly connected with his processing operation. This room has plenty of hot and cold water and good drainage. Some people prefer to use steam and cold water instead. It does just as well, as long as they have enough of it available. Joe has a special steam and water mixing unit that steps up his pressure. This device can deliver from 60 to 250