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State health authorities to go back to this type of archaic situation whereby because we don't want to harm a small milk producer-we would allow this producer to milk four cows and put the milk in a can, put the can on a stove in his kitchen and light the fire and heat it up and mix it with a spoon and then clean the bottles and then pour it in and then take a cap and put it on and say this is pasteurized milk. They don't even go for that themselves. They want to be sure that their milk product is properly prepared. In order to have their milk properly prepared, you need a certain type of equipment. There is no doubt about it.

I want it to be on record that our group realizes that in order to do a proper job of poultry inspection and processing, you do in fact have to have certain equipment. There will come a point at which a‍man who doesn't have or cannot afford that type of equipment will have to go out of business. He won't have to kill himself, he will just have to have this product custom slaughtered as is done in other areas or he will have to sell it to another man who has the equipment, which is the same thing that obtained when we were trying to get rid of all the typhoid epidemics, streptococcal throats, and disease outbreaks in the milk business and which we have in health work eventually licked.

We would not be able to lick these problems unless we took the stand that, we are sorry, but if a man doesn't have the equipment it is tough but he has to get out of it. So there is a stand which will have to be taken and public health authorities are prepared to take that stand. It will just have to be done.

Mr. REIDY. You didn't mean he would have to get out of the business. As you said before, he would just have to work out a system whereby

Dr. SUSSMAN. He would sell to someone else who has the facilities. As the Farmers Union group mentioned, I think actually there is a legitimate way to work this thing out, and it can be worked out. There is not going to be any cutting of anyone's throat. I think perhaps there is a legitimate complaint because of the fact that maybe this can't be put into operation on January 1, 1957, as this bill calls for, but it most certainly can be put into operation sooner than the nonexistent time to which exemption will be allowed in S. 3588. I would like to go into that bill S. 3588 a little later and show you, if I may, that there is some reason on the part of this committee really to worry about of what 3588 says, since you are the public-health committee of the Senate.

There is another point in which I think health authorities and State public health veterinarians are interested, and that is the industrial health hazards both to the veterinarians who are inspecting poultry and to the people who are working in the plants. If you have proper inspection there really isn't much hazard at all to the consumer. I would like to get that point across: The consumer need not be frightened of poultry which has been properly inspected. I think it is important to realize that with proper inspection you can eliminate the major hazards to the consumer by means of food inspection.

However, there is a continuing hazard to the working man and to the veterinarian who inspects at the plant. This is something which can be somewhat obviated by good industrial hygiene tech

niques in the plant such as air screen, pollution elimination, air ventilation, proper channeling of the waste products and proper handling of water sprays and also proper medical examination of the birds prior to the time they are killed. There are times when by antemortem inspection you can actually prevent birds from coming into the plant and contaminating the plant and making people sick.

Therefore I think this is one very important reason that antemortem inspections should be allowed of a permissive nature at the very minimum by whoever administers the program. It certainly should not be that antemortem may be on a wishy washy basis. I think it should actually be done somewhat in the same manner as 3176 provides.

Mr. REIDY. On that point, Doctor, I raised the question with the last witness, would it be possible to set up a system involving antemortem inspection if this program were on the State level rather than on the Federal level?

Dr. SUSSMAN. I was going to take that point up later but I think I should touch on it right now. That question comes to the point that State departments of health, the State authorities in our organizaion, don't want anybody to cry in their beer, if I may use the expression, for our prerogatives. We don't want to be in a position whereby my system is approved by the Department of Agriculture or Department of Health and I may send my birds in to New York. We would rather be protected equally by the fact that New Jersey's system and Virginia's system and West Virginia's system are all the same, administered by the Federal Government, because we know-and there is no reason to mince words about it-there are too many situations where political pressure on the local basis may produce a tremendous amount of pressure on the exporting State. Whereas if the importing State had been given permission to the exporting State to send their material out, according to the provisions of 3588 the importing State would be precluded from refusing to accept it in spite of the fact that I might call up a friend of mine in my position in Virginia, for example, and he would tell me very clearly, "Look, we are not inspecting this stuff. We can't inspect it. We are just in the plant."

That is just imaginary conversation, but it has happened. We do not really want any one to protect us other than from interstate shipments and by live Federal inspectors paid by the Federal Government. We don't want to have, as in 3588, the possibility that if the Secretary of Agriculture's men think that the man in Virginia or Texas or wherever he is, is a good guy and they can get along with him and drink with him and so on down the line, his inspection may come in. There is too much chance in that. We would rather have one clearcut definition that any poultry crossing the State line, other than that owned by the farmer who raised it, must have been inspected by a veterinarian under the supervision of and paid by the Federal Government.

That is clear cut as far as what we want. That doesn't mean we will

get it.

Mr. REIDY. It is a very clear statement. I think we should correct one misimpression perhaps. I am sure the conversation you had with the gentleman from Virginia was about a situation that arose in some States other than Virginia which shall go nameless.

Dr. SUSSMAN. That is right.

I see our time is running out, Mr. Reidy.

Mr. REIDY. You said you intended later to give us an analysis from your point of view, and the point of view of your organization, of the other bill. I think it might prove more valuable to the committee if we had that in writing rather than orally.

Dr. SUSSMAN. If I might just conclude, the Bureau of the Budget was investigating this situation about inspection in 1951. I was fortunate enough to work with the Bureau of the Budget at the time, as were a number of other people. I would just like to quote for you, if I may, two paragraphs from the Bureau of the Budget report. I think it might tie up my particular testimony today. The Bureau of the Budget stated:

The practice of permitting an employee of a poultry concern to grade poultry belonging to his employer and to use a USDA stamp also has been questioned. The bond purchased by the employer is not regarded as a guaranty of complete objectivity on the part of a grader whose economic welfare and principal loyalty belongs to the owner of the poultry he is grading.

This is what they said with regard to grading. Our association says the same thing obtains with regard to sanitary inspection of the plant. I understand from the Chief Veterinarian of the Poultry Branch of the United States Department of Agriculture that in April of this year, after 3176 was put in, there was a new pronouncement that came out which said that no one who has a financial interest in the firm or is paid by the firm may be a sanitarian under the poultry sanitation program. It was explained to me yesterday that there are still men paid by the firm, who actually are paid by the firm and have a financial interest in it. They are attempting to relieve them of it. I think it is significant that until there was a lot of pressure from health groups and until this bill went in there was really no affirmative action. Such action could have been taken in two shakes of a lamb's tail to eliminate that particular procedure.

I think the committee should also realize one further thing: That word "sanitarian" has been used very promiscuously by the Department of Agriculture. The term "sanitarian" as it uses it should not be construed to include those people who have gone to college and who have studied bacteriology and have studied sanitation or sanitary engineering. There are people who may or may not have graduated from high school, who may or may not have had any formal training, who may, as in the case of the owner of a firm, be merely a partner in a firm. These are the type of people who are licensed. Also there are no real provisions made, so far as I know, whereby any particular type of education is demanded of a sanitarian. I think from the standpoint of those people, who are registered sanitarians and spending their entire lives in the practice of sanitary engineering or the profession of sanitary work and health work, that they should not be placed in the same category as a new group who are given diplomas, so to speak, by the Department of Agriculture without actually having earned the right to be called same.

Mr. REIDY. Does the Department, so far as you know, have any official set of standards which must be met before a man can be called a sanitarian?

Dr. SUSSMAN. It may have. There was a discussion of that and it may at the moment have them, but at the time we were discussing it I don't know whether it ever concluded what that was. Up until yes

terday however, in New Jersey a licensed company had a high-school graduate working in a Federal plant as a sanitarian.

I would like to conclude by saying that the Bureau of the Budget said it very succinctly when it stated there were extensive pressures in the poultry industry which could push the PMA organizations around. It stated that

Practices in the poultry industry have been justfied on the grounds that inspecton is less important for poultry because many diseases of poultry are not communicable to humans and the industry is so highly competitive and decentralized among many small concerns that elaborate and costly inspection methods and equipment are not feasible.

I conclude by offering for the record this last piece that I have. Then I am through, Mr. Reidy, and thank you very much.

That indicates that there is no real need for having inspection, according to USDA at the time that the Bureau of the Budget did this in 1951. Further, that it was a highly competitive thing and you would logically have to assume that even if there was a need you would have to be easy on it because of the fact that it was highly competitive.

To my mind, when a person dies with psittacosis it is quite unimportant as to whether the bird cost a penny more or a penny less because of the cost of inspection. It is equally unimportant as to whether an administrator thinks it was or wasn't important. He is dead. He is very dead. You just die once.

Mr. REIDY. You don't think the purpose of free competition is meant to eliminate human beings from all competition?

Dr. SUSSMAN. I don't think so. I would like to put this in the record and I am through. That is that Dr. William H. Feldman, speaking at the Association of Food and Drug Officials meeting in New York, at the 50th anniversary, at which they were very happy because of the fact that the Federal Meat Inspection Act had been in existence for 50 years, that the Food and Drug Act has been there and that they have had the possibility of helping the public-he stated

that

Poultry sold to the American consumer should be above suspicion. Not all poultry sold is in this category.

The article goes on. This man from the Mayo Clinic, an eminent scientist, goes on to state in his article, which I think the committee can get in the future, that there are diseases which people do get from poultry and that authorities such as those in the Mayo Clinic know that and they feel that there is a need for compulsory poultry inspection.

Mr. REIDY. Thank you, Dr. Sussman. That was a very strong statement, very strongly presented. We appreciate the help you have given us.

(Dr. Sussman submitted the following to accompany his statement:)

[From the New York Times, May 8, 1956]

PATHOLOGIST ASKS UNITED STATES POULTRY LAW-"NOT ALL SOLD TO CONSUMER ABOVE SUSPICION," FELDMAN TELLS FOOD OFFICIALS

Poultry in interstate commerce should come under Federal control, a Mayo Foundation pathologist said yesterday. Dr. William H. Feldman urged legislation to specify for poultry the same compulsory inspection established 50 years ago for meat from cattle, swine, and goats.

"Poultry sold to the American consumer should be above suspicion," he said. "Not all poultry sold is in this category."

The scientist from Rochester, Minn., was addressing the Association of Food and Drug Officials of the United States in the New Yorker Hotel.

Dr. Feldman declined afterward to comment specifically on a bill to make Federal inspection of poultry in interstate commerce compulsory. It was introduced in the Senate in February.

Edwin Ludewig, director of the bureau of food and drugs of the city's health department, said Commissioner Leona Baumgartner supported the bill. He declared that all eviscerated and processed poultry sold in the city came from plants with substantially the same standards of inspection. Plucked chickens on sale here are inspected only sporadically, Mr. Ludewig said, for wholesomeness and absence of disease.

This years program of the association commemorates the 50th anniversary of the signing of the Federal Food and Drug Act and the Meat Inspection Act by President Theodore Roosevelt on June 30, 1906.

Dr. Baumgartner said President Roosevelt had become acquainted with sanitary problems 10 years earlier when he sat on the Board of Health here as head of the New York Police Board.

Yesterday's conference showed no traces of the controversy that stirred the Nation in 1906 when Upton Sinclair's novel The Jungle exposed in realistic detail the conditions then existing in the Chicago meatpacking industry.

Dr. A. R. Miller, who heads the Meat Inspection Branch of the Agricultural Marketing Service of the United States Department of Agriculture, spoke of the "understandable reluctance" of the industry to accept restriction at that time. To illustrate the cooperation that has developed, he noted that 18 billion pounds of meat were processed and inspected annually.

John T. Knowles, vice president of Libby, McNeil & Libby, Chicago packing concern, and chairman of the scientific research committee of the National Canners Association, spoke for industry. He said it had been "pushed gently down this path of progress" by the 1906 act.

Eugene H. Holeman, State chemist of Tennessee and president of the association, presided at the confeernce. A thousand members are registered for the 5-day meeting.

[From the American Journal of Public Health, March 1956]

SOME IMPORTANT LESSONS FROM THE LANCASTER, PA., PARATYPHOID FEVER

EPIDEMIC

It is heartening indeed to realize how unusual the recent milk-borne epidemic of paratyphoid B in Lancaster, Pa., seems to us today. Even a decade ago such an outbreak would not have evinced either surprise or particular interest. Now there is almost an air of nostalgia surrounding the outbreak as we realize that "it can still happen here!"

The epidemic was fortunately mild insofar as clinical manifestations were concerned. It was, however, numerically extensive with over 200 symptomatic cases reported and another 40 to 50 less-manifest infections being uncovered through epidemiologic investigation. The age distribution, in the classic milkborne epidemic pattern, was heavily weighted in the earlier years, the effect being emphasized by the fact that the dairy involved served most of the local schools. The chronological characteristics of the epidemic curve exhibited a rapid irse in the numbers of cases according to date of onset, a modal period of 4 days during which a considerable number of new cases was occurring, and then a more gradual falling off of case incidence.

It is interesting to note that the value of local full-time public-health supervision was again demonstrated, for the State district medical director in Lancaster mobilized and directed the investigation of the outbreak with commendable speed; the first aggregation of cases was reported on Monday, the preliminary field investigations of 17 households had been completed by late Tuesday evening, with the data indicating the probable involvement of 1 dairy, and on Wednesday that dairy was persuaded to cease operations. Of course this meant utilizing other trained public-health personnel. And the second lesson to be learned is the old one of the need for a multidisciplined team approach, in any epidemic study. Public-health nurses, laboratory technicians, sanitarians, a public-health veterinarian, and a public-health educator all supplemented the work of the public-health physician directing the investigation. And each of the disciplines contributed significantly toward the control and solution of the problem.

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