2. This program can best be administered by the present USDA Poultry Branch which has trained personnel and has had 28 years of experience on a voluntary basis and has done a good job. The production, disease, distribution, and marketing problems are substantially different between poultry and red meat animals.

3. A compulsory poultry inspection program must be practical and built to suit the needs of the poultry industry. Licensed lay inspectors should be used. In our State very few veterinarians have any knowledge of poultry diseases, and this will apply to the majority of the States. In the past poultry disease and poultry health problems have been serviced by hatcherymen and feed dealers. This group, plus the average poultry producer, has more knowledge regarding poultry diseases and knows more about the wholesomeness of poultry, either live or dressed, than the majority of veterinarians in this country. Poultry inspection must be done visually, and it would not be practical to have a laboratory inspection on every questioned bird.

4. We strongly endorse the resolution adopted at the annual meeting of the American Farm Bureau Federation, which is:

"Mandatory inspection of red meat at livestock slaughtering establishments as presently financed and administered by the USDA has helped to assure the wholesomeness of meat sold in interstate commerce. We urge extension of this service to include poultry meat sold in interstate commerce, with provision, where necessary, for the use of lay inspectors under the supervision of veterinarians."

The consuming public is entitled to be assured that the poultry they purchase is free from disease and has been processed and handled under the most sanitary and refrigerated conditions. But it should not have to be done under a program of scare or under the guise of health. People do not become ill from eating poultry which is diseased or which has been processed or handled under unsanitary conditions. No one would think of eating raw poultry, but would insist on it being well done. This is not true with red meats, which, in many cases, is eaten in the semiraw or nearly raw state. People become ill from eating many kinds of foods which have not been given proper care after having been cooked. People can contract some diseases from handling live or dressed poultry, but no mandatory inspection program will solve that problem. Caution should be used that the requirements set up are not so expensive that the organizations and companies with plenty of finances are the only ones that will be able to operate. You can have the most modern of kitchens and still have the sloppiest of housekeeping.

The opportunity of expressing the views of the Hamilton Farm Bureau Cooperative, Inc., on this issue is appreciated.

Mr. JOSEPH O. PARKER,

Washington, D. C.

EASTPORT, LONG ISLAND, N. Y.,
June 22, 1956.

DEAR JOE: I had fully intended to be in Washington on June 26, to appear as an industry witness in support of bill S. 3588 scheduled to be heard by the Senate Agricultural Subcommittee. I find, however, that it is impossible for me to be there on the above date, and would very much like to have you submit this letter at the hearing, stating my views in this matter.

I am certainly in favor of establishing mandatory inspection as applied to poultry and poultry products, and I am attaching herewith and making a part of this letter a recent article published in the Butchers' Advocate, in the issue of June 13, 1956, entitled "Quality Control Emphasized by Duck Processor”. In my experience in working with the Department of Agriculture for the past 21 years, where the services of the Department of Agriculture's Poultry Branch has provided controls to be accepted by processors on a vountary basis, my company was one of the first to subscribe to this inspection service for the industry. During the 28 years the Department of Agriculture has been working on these problems they have created not only experience within the Department, but also a relationship with the industry that would be of tremendous value in administering a mandatory program.

There is no question in my mind that had there been a mandatory program administered by the Department of Agriculture before this, these hearings regarding tighter controls would not be needed. Certainly the experience of the

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personnel in the Poultry Branch of the Department of Agriculture should not be overlooked by the committee in evaluating opposition to this bill.

I feel that I am well enough qualified and recognized in all phases of industry to make the above statements.

Very truly yours,

C. J. CONN,

President, Long Island Duck Packing Corp.

[From the Butchers' Advocate, June 13, 1956]

QUALITY CONTROL EMPHASIZED BY DUCK PROCESSOR

The Long Island Duck Packing Corp.'s modern and efficient processing and quick-freezing plant in Eastport, N. Y., truly sets "the quality standard of the industry." The firm's internationally known Farmers' FCH brand quick-frozen, ready-to-cook ducklings are widely recognized as being the finest obtainable anywhere.

Chester J. Conn, founder and president of LIDPC, has devoted his extraordinary organizational and engineering talents to the processing of superior products since he established the firm in cooperation with Russell Hallock, president of Farmers Commission House, New York City, in 1935. Mr. Conn's outstanding contribution to industry and Government have received national recognition and are currently attested by his appointment to the international trade development committee of the Institute of American Poultry Industries and by the several important. boards of directors upon which he serves, including those of Merchants Refrigerating Co., New York City, the Central Islip National Bank, Long Island, and the National Association of Frozen Food Packers.

Prior to the firm's establishment in 1935, most of the ducklings that were grown on Long Island were shipped to New York City in the fresh state. This, of course, limited sales to within a 200 mile radius of that city and denied most Americans the opportunity to serve this tender delicacy. Fortunately for consumers, the LIDPC pilot-plant operation proved the feasibility and immense value to the industry of processing and quick-freezing ducklings for national and year-around distribution. During World War II, most of the processed ducklings were pre-empted by the Armed Forces. Since the end of that conflict, both the company and the industry have achieved a tremendous expansion in production and marketing until, today, this multimillion dollar industry can boast of quality standards and a finished product that have earned international

renown.

Quality control begins on the farms, of course, and most of the farms are wholly integrated units which represent the expenditure of several hundred thousands of dollars each. The farms largely produce and select their own breeding stock, hatch the eggs in modern electric incubators, raise the ducklings on a carefully standardized diet, and dress them at marketing age in their own modern dressing plants.

Because of its superior qualities in flavor, tenderness and body conformation, the Pekin duck has been grown and marketed almost exclusively by the Long Island growers since its importation from China in 1873. These outstanding qualities have been further refined by careful breeding, a program which has been enhanced in recent years by the inauguration of trap-nesting, and the feed`ing of a scientifically balanced diet which assures that the ducklings will be plump and meaty with the lowest possible fat content at their marketing age of 8 weeks. Th's scientific diet is subject to constant research and improvement at the Long Island Duck Research Cooperative, Inc., which was established in Eastport by the growers in 1950 in full realization of the fact that the type of food a duckling eats will affect the flavor, quality, and even the color of the meat. The laboratory, which is housed in a large modern building and equipped with every modern facility for scientific nutritional and disease research, is headed by Dr. Ellsworth Dougherty III of Cornell University.

Upon maturity of the ducklings, they are slaughtered and defeathered in the growers' modern dressing plants. These plants are completely equipped with the latest automatic picking machinery and are invariably operated on a continuous conveyor-line basis. Quality of product and plant sanitation are closely supervised by United States Department of Agriculture graders who comprise an integral part of the industry's voluntary Government inspection program.

Following the exacting dressing operation, the ducklings are thoroughly chilled in ice-water vats before transfer to iced shipping tanks.

All growers supplying ducks to the Long Island Duck Packing Corp. are members of the Long Island Duck Ranchers Cooperative which is headed by John Leary of East Moriches, N. Y. The cooperative furnishes aid to its members on problems relating to the growing of ducks and acts as marketing agent for its members' product.

Quality control is strongly emphasized at each stage of the processing operations.

Upon receipt of the ice tanks of ducks at the Long Island Duck Packing Corp.'s plant, the birds are graded by a USDA grader and held in a cold storage room before processing soon thereafter. While hanging the birds on the eviscerating-line shackles, plant employees size and regrade the ducklings in order to make absolutely certain that only ducklings of the finest quality are included in the finished product.

Thorough inspection made

Once having passed these preliminary tests, each duckling and its viscera is subjected to a close on-the-line inspection by a USDA veterinary inspector after the duckling is drawn. Following completion of the eviscerating process, and just prior to packaging, the ducklings receive a final inspection and grading by highly skilled plant and Government inspectors. The voluntary Goverument inspection program entitles the company to display the official inspection and grading legend of the USDA on its packaged product.

The processing operations are conducted in a brightly lighted, ceramic-tiled room by well-trained operators who are thoroughly screened and tested by the plant's personnel department before placement. Each operator is required to wear a white butcher coat, a hair-guard, and a plastic apron. Two men on each shift are detailed to continuous cleanup duties and keep the rooms spick and span at all times. This heavy emphasis on training and cleanliness has resulted not only in the production of a superior product but, also, in a favorable safety record which is, in turn, reflected in a very substantial experience-rated credit premium for workmen's compensation insurance.

Following evisceration, final inspection, and grading, the ducklings are packaged in either individual cartons or Cry-O-Vac bags. The "carton ducks" are wrapped in moisture-proof cellophane before being enclosed in a waxed carton and are quick-frozen in plate frosters at -50° F. before being cased for shipment. The very short freezing period of only 2 hours that is required for this type of package magnificently preserves the farm-fresh flavor and color of the tender young duckling in its prime.

Classified by weight

"Cry-O-Vac ducks" are vacuum-packaged in plastic bags which are sealed with metal clips. The ducklings are then classified by weight into S-head special corrugated cases, which afford double tops and bottoms for added protection, before being quick-frozen in a blast freezer at -50° F. After freezing, the cases of ducklings are moved directly into the freezer-storage room which is held at -20° F.

Identical weight ducklings in either type of package are packed in 8-head cases which weigh to the even pound or half-pound. This is a tremendous advantage to stores and restaurants in marking prices and computing the cost of portions and also aids distributors in manifesting and billing. Standard weight cases of varying size ducklings are packaged to order in 30, 34, and 38 pound net weight cases for customers using IBM systems of inventorying and billing.

LIDPC's final arbiter in its extensive quality-control program is its research laboratory-kitchen which the company maintains for conducting cooking tests on finished products, including the firm's extensive annual vegetable pack, and performing basic research on new products. Research has proved duck meat to possess large amounts of protein, calcium, potassium, and iron, and the vitamins thiamin, riboflavin, and niacin plus valuable amino acids—all of which are vital to human health and growth. The cooking tests are designed to insure that the tender sweetness which is characteristic of these famous ducklings remains unaltered.

Farmers' Commission House, Inc., with offices at Eastport and in New York City, serves as the sole marketing agency for Farmers' brand eviscerated and quick-frozen ducklings. The president of FCH is Russell W. Hallock who

established the firm in 1915 and has guided its progress to its position of eminence in the industry today.

From its offices and warehouse at 501 West 16th Street, New York City, FCH wholesales Farmers' brand eviscerated and quick-frozen ducklings packaged in individual cartons or Cry-O-Vac bags. New York dressed ducklings—fresh or quick frozen-in boxes or barrels, and fresh or quick-frozen turkeys and fresh squabs to customers in the metropolitan area.

National and international sales and distribution are made from the offices and warehouse at Eastport, N. Y., by Donald Druckemiller, sales director of Long Island Duck Packing Corp.

Large quantities of ducklings are custom-packed annually by LIDPC for selected private brands and are subjected to the same rigorous quality standardswhich have been established for Farmers' FCH brand.

Senator WILLIAMS. Now, have we missed calling anyone whose name was not on the witness list, or have we overlooked anyone who came here to testify or file a statement?

If not, the meeting will stand adjourned, and we repeat-if any of you gentlemen who have testified this morning, after examining the committee print of bill S. 3588, which embraces certain recommendations for amendments by the Department of Agriculture, has any further comments or suggestions to give to the committee, we would appreciate the benefit of receiving them as a supplementary statement.. These will be incorporated in the record.

The meeting is adjourned.

(Whereupon, at 1:25 p. m., the committee adjourned.)

(Additional statements filed for the record are as follows:)

DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE,
Washington, July 6, 1956.

Hon. EARLE C. CLEMENTS,

United States Senate.

DEAR SENATOR CLEMENTS: Responsive to your request, a study has been made of committee print of June 1956 on S. 3588, a bill to provide for the compulsory inspection by the United States Department of Agriculture of poultry and poultry products. Our comment follows:

Sections 2, 3, and 4: Because of indications of the likelihood of serious conflict with the inspection services and food and drug enforcement provisions in the various States, we feel that the committee will wish to explore most thoroughly the wisdom of undertaking to include within the scope of this Federal law exclusive jurisdiction by the Secretary of Agriculture over poultry which is entirely intrastate.

Section 5: Concern has been expressed over the power granted in this section to the Secretary to conduct ante mortem and post mortem inspection as he deems necessary of poultry and poultry products. Since there have been expressed opinions by veterinarians of the Department of Agriculture who are now concerned with poultry inspection not in accord with the idea of at least a visual inspection of each bird prior to slaughter there is a concern that such ante mortem inspection as the Secretary deems necessary may be interpreted to exclude from any preslaughtering inspection some or all of the poultry passing through processing plants. It is the view of the vast majority of experts in the field that ante mortem inspection should be interpreted to constitute a look at all birds while alive by a competent veterinarian with individual examination of each bird wherever there is any evidence of illness or unfitness. The initial "look at" could be on the basis of a crate at a time, but no birds should be passed without being seen by inspectors before slaughter. Perhaps the possibilities of ambiguity could be overcome by striking out the word "such" on line 8, page 4, inserting as the first word in line 9, page 4, the word "both," striking out the words "as he determines necessary" in lines 10 and 11 and inserting in line 11 the word "all" before the word "poultry” in both places where that word occurs in the line.

Section 6, page 5: It is provided that sanitary practices as are required and approved by the Secretary shall be followed. We suggest that lines 10 and 11 on page 5 be changed by deleting the words "and approved" and by the insertion

after the word "required" in line 10 of the words "by regulations promulgated." This would serve to definitely place such conditions of approval by the Secretary in the range of review under the Administrative Procedure Act and remove the possibility of complaint about arbitrariness.

Section 7. This section implies that wholesomness shall be the only criterion which must be met before official inspection marks and labeling are applied to poultry. Since the bill as revised uses both the term "unwholesome" and the term "adulterated" to define unfit poultry we would suggest that there be inserted on line 18, on page 5, following the word "wholesome" the words and not adulterated." In the same section and page, at line 22, the last word is "or." We suggest striking the word "or" and substitute the word "and." This would make it mandatory that the name and address of the packer be contained in the labeling and conform with the general requirements of the Federal Food, Drug, and Cosmetic Act with regard to foods. As presently worded a number having no significance to the consuming public could be used in lieu of the name and address of the person responsible for integrity of the food article.

We suggest the same change on page 6, line 6; strike the word "or" and substitute "and."

For the same reasons we would recommend striking the word "provided” in line 8, page 6, through the word "packed" on line 14, page 6.

On line 13, page 6, we suggest striking the word "such" and substituting the word "any" and striking the word "as" and the words to the end of the sentence and substituting "not in conflict with the Federal Food, Drug, and Cosmetic Act." As presently drawn the bill would permit the Secretary of Agriculture to grant any variations in labeling requirements that he deems practicable and this might readily lead to provisions for poultry which would result in their being misbranded when they actually enter the channels of interstate commerce. We suggest in line 17, page 6, after the word "misleading" that there be inserted "in any particular" and the same insertion after the word "misleading," in line 1, page 7.

Since all this refers to branding and misbranding it seems evident that the language and the requirements should conform to the provisions of the Federal Food, Drug, and Cosmetic Act which are applicable to all foods.

We would suggest striking the words "knowingly and" in line 12, page 8, and the word "knowingly" in line 17 and line 20, page 8, and in line 1, page 9, and line 5, page 9.

We would suggest striking the word "false" on page 8, line 12, and substituting the word "falsely" capitalized:

It seems well settled policy as exemplified by Federal Food, Drug, and Cosmetic Act that in laws of this nature which impose strict requirements upon the manufacturer as the most effective means of public protection that awareness of wrongdoing should not be included as an element of misdemeanor against the law. For that reason we would strike the terms that require knowledge on the part of the offender in the prohibited acts.

On page 10, line 11, we suggest striking the period at the end of the sentence and substituting a comma and the words "not inconsistent with the provisions of the Federal Food, Drug, and Cosmetic Act."

Since there are specific statutory provisions and exemptions for exported shipments generally understood and recognized by foreign nations and this country desirability of maintaining uniformity prompts this suggestion.

In section 12, page 12, line 4, we recommend that the word "willfully" be deleted. This would bring the conditions of violations in line with the Federal Food, Drug, and Cosmetic Act, would be more consistent with the Meat Inspection Act, and would remove the almost insurmountable difficulty of proving intent to violate. We repeat our earlier comment that the penalties of violation should be consistent with those of the Federal Food, Drug, and Cosmetic Act or the Meat Inspection Act and preferably the latter.

We recommend the insertion of the word "minor" following the word "proceedings" on line 4, page 13. This would remove the suggestion of the possibility of an uneven enforcement and would bring the section in line with the Federal Food, Drug, and Cosmetic Act which grants similar discretion to the Secretary but only in the case of minor violations.

Section 16: We recommend the word "knowing" in line 15 be deleted and that the word "that" in line 16 and the words "and are intended for human consumption" in line 17 be deleted. We suggest that there be substituted for the words "knowing that" the word "when" and that there be inserted after the word "unwholesomeness" in line 16 the words "or adulterated or misbranded."