VERGENNES, VT. Senator WINSTON PROUTY, Washington, D.C. DEAR SENATOR PROUTY: The Vermont Turkey industry is deeply concerned about the pending legislation to amend the Poultry Products Inspection Act. We are not in disagreement with what is trying to be accomplished by S2846, namely, the assurance of proper sanitation and wholesomeness of the products which we produce. If some individuals in our industry are not now cognizant of the importance of producing sanitary, wholesome products we want the situation corrected. However, it should be pointed out that the Vermont Turkey industry and indeed the Turkey industry of the Northeast is founded on many small businesses. We are small operators when compared to the large integral complexes in other areas. It should also be pointed out that our production costs are higher. Invesment in the land and buildings is high, feed and labor costs and other costs are high making direct marketing of our product essential if we are to realize a profit. We are serving a market which would go unserved if we could not exist. In fact we were several thousand birds short for local demand last year. Most of our business is dependent upon a premium market for fresh-killed unfrozen turkey and a relatively large amount of service provided by the producer-processor. It has been our experience that consumers are willing to pay premium prices for our products. They buy our products because they want the fresh dressed and prepared products which we offer and not because they feel sorry for us or want to support our inefficiencies, nor because they understand our higher costs and are willing to support them. The majority of our producers grow and market a few hundred or a few thousand turkeys each year. The family operation is typical. We serve customers in our immediate areas for the most part. We are close to the consumer. In fact many of them come to the farm to purchase their turkeys and personally inspect our facilities. Our industry is willing to comply with further practical regulations which will permit us to remain in business. However, our fear is that if we are made to comply with regulations designed for the large processor our turkey industry will be eliminated. The cost of meeting the specifications as outlined in the Poultry Products Inspection Act would be prohibitive. We believe that practical regulations can be arranged which, while not exempting us from proper supervision to assure consumer protection, need not at the same time eliminate an economic agricultural enterprise in Vermont and the Northeast. It is hoped that our situation will not be overlooked as S2846 is considered. Sincerely yours, GEORGE N. KNEESHAW, President, Vermont Turkey Growers Association. Hon. ROMAN L. HRUSKA, DEPARTMENT OF AGRICULTURE, STATE OF NEBRASKA, Lincoln, Nebr., April 11, 1968. Washington, D.C. DEAR SENATOR HRUSKA: This is in follow-up to your correspondence to us regarding the above-named matter. Word has reached us that the full committee of the House has now acted favorably on the Purcell Bill, H.R. 16363. Therefore, we presume the Senate Committee on Agriculture and Forestry will be considering poultry and poultry products inspection in the near future. We shall appreciate your inserting the following statement of position into the Committee record at the time hearings are conducted: S. 2486 This bill simply provides for the extension of Federal inspection to all poultry and poultry products for human consumption. We oppose this kind of legislation on the grounds that it usurps the power of the State to regulate within its own borders, and, thereby, is contrary to the Constitutional rights of the States as sovereign powers. Furthermore, the Federal Inspection Service would have to spread itself too thin to accomplish a satisfactory job of inspection on all plants within a State; and to attempt this would mean expending unprecedented amounts of money. A State-Federal program of inspection is a much more logical and practical approach. S. 2932-H.R. 16363 This proposed legislation is a "carbon copy" of the Wholesome Meat Act, except for appropriate changes in language to accommodate poultry and poultry products and to provide editorial changes. Therefore, we have the same objections as were voiced with respect to the meat inspection legislation voted out by the Senate and the final conference version which was signed into law. Section 5 of S. 2932 embodies a serious violation of the Constitutional rights of the States to control commerce within their own boundaries. This is a dangerous precedent to set in the field of regulatory supervision and is wholly foreign to the accepted procedures in food and agriculture areas involving the Federal and State governments. The climate created by statute in the past has been conducive to creating and maintaining a harmonious and cooperative working relationship between the U.S. Department of Agriculture and the States. In fact, under many programs, the U.S. Department of Agriculture officials serving in a given State have done so "at the pleasure" of the State. The provisions of S. 2932, on the contrary, provide for a very radical change by setting up the U.S. Secretary of Agriculture with dictatorial authority. It is serious enough when (as has happened in other areas of activity) the Federal government offers funds to a State, the use of which is severely restricted with stipulations; the provisions of S. 2932 allow the U.S. Secretary of Agriculture to override State participation completely, if he is not satisfied with its action. Furthermore, this type of legislation is not in the long-run best interest of the persons whom it is supposedly designed to protect, by assuring clean and wholesome products. The interest of wholesomeness and sanitation with respect to poultry and poultry products, as with meat and meat products, can best be served by joint State-Federal cooperative programs. Under such arrangement, the Federal government can provide the necessary coordination, assurance of uniformity, and lead the way in employee training and other similar areas, while the States can assume primary operational jurisdiction for the program. The language of the bills which the Senate Committee will consider encourages the States to leave the entire inspection job up to the Federal government. Such action would result in a very expensive program for the taxpayers to shoulder and one which would not produce the most effective results. Specifically, we recommend the following deletions to S. 2932: (1) Beginning with the word "In" on line 22, page 14, through line 2, page 15. (2) Beginning with line 16, page 16, and continuing through line 22, page 19. (3) Beginning with the word "not" in line 24, page 19, and continuing to the "comma" in line 1, page 20. (4) Strike out the phrase "burdening of commerce" or the phrase "burdensome effect upon commerce" wherever this phraseology occurs in the proposed language. The proposed legislation has important bearing on the State, and we appreciate your attention to the best interests of Nebraska. Sincerely, Hon. EVERETT B. JORDAN, B. H. (BILL) JONES, AMERICAN FEDERATION OF LABOR Chairman, Subcommittee on Agricultural Research and General Legislation, Committee on Agriculture, U.S. Senate, Washington, D.C. DEAR MR. CHAIRMAN: In behalf of the American Federation of Labor and Congress of Industrial Organizations, I am writing to you in support of needed amendments to the Poultry Products Inspection Act of 1957. Immediately following the successful enactment of the Wholesome Meat Act of 1967, the AFL-CIO Convention expressed the hope, in its Policy Resolution on Consumer Protection, that the new meat inspection law would be the "harbinger of needed Federal legislation to provide effective inspection of poultry and fish and additional measures to protect the consuming public." 96-351-68-18 We are very pleased that your subcommittee is proceeding to the immediate consideration of H.R. 16363, which was passed by the House of Representatives on June 13 and also several measures introduced in the Senate: S. 2846, S. 2932, and S. 3383 (Title I). The problems in poultry inspection are parallel to those presented by the old meat inspection law. Although 87 percent of the over 12 billion pounds of poultry and poultry products are federally inspected, over 13 percent, or approximately 1.6 billion pounds, receives no federal inspection because it does not cross state lines. State poultry inspection programs are either non-existent or inadequate. Only 4 or 5 states are generally considered to have reasonably effective mandatory inspection programs, and even these have shortcomings as to coverage or enforcement or both. Over 400 million pounds of poultry processed in federally inspected plants is rejected because it is diseased or contaminated. How much greater must be the proportion of diseased and contaminated products reaching the public from uninspected plants, where no check exists to prevent it. Assistant Secretary of Agriculture George Mehren has reported that a check made last January of poultry products in retail stores showed that one in every five carcasses from plants now under federal inspection "should have been condemned as unwholesome." Only 18 percent of those checked were fully satisfactory. We urge that the strongest possible poultry inspection bill be reported out and speedily enacted into law. The most desirable solution is mandatory federal inspection of all poultry slaughter and processing operations, together with comprehensive modernization of the federal act itself. Direct federal inspection provisions are included in S. 2846 and S. 3383. We believe, however, that H.R. 16363, as passed by the House, represents a good, workable approach, along the lines of the Wholesome Meat Act of 1967. It is an improved version of the Administration bill, represented in the Senate by S. 2932, but it does contain certain damaging features which should be corrected in the bill to be reported by your subcommittee. The chief damaging amendment made in the House was to provide that violations must be "knowingly" made in order for penalties to apply. To penalize violations only if intent can be proved is to vitiate the entire enforcement of the law. We cannot urge too strongly that this word be dropped throughout Section 9 of the bill. Such provision does not appear either in the Wholesome Meat Act or in the Food and Drug Act. The House also approved an exemption of all plants which handle less than $15,000 worth of poultry in a year. This exemption should be dropped or modified. Finally it would be desirable for the bill to include a provision permitting states that do not intend to set up poultry inspection programs of their own to come under the federal program immediately if they wish rather than waiting out the two-year period given them for establishing their own inspection system. We hope that your subcommittee will act favorably and promptly on a strong poultry inspection bill and respectfully ask that this letter be included in the hearing record. I trust you will make this communication part of the hearings record on this legislation. Sincerely yours, ANDREW J. BIEMILLER, Director, Department of Legislation. U.S. SENATE, Hon. EVERETT JORDAN, COMMITTEE ON AGRICULTURE AND FORESTRY, Chairman, Subcommittee on Agricultural Research, DEAR EVERETT: I hereby submit for inclusion in the Record of the hearings on the various poultry and egg measures a copy of the article from the New England Journal of Medicine to which Dr. Sussman referred in his testimony. Salmonella isolations were found in both plants. However, the article argues this calls for expanded monitoring efforts, not for abolition of inspection programs. The evidence on contaminated eggs also should be noticed. With warmest regards. Sincerely, WALTER F. MONDALE. [From the New England Journal of Medicine, June 30, 19661 ISOLATION OF SALMONELLA FROM POULTRY1 POULTRY PRODUCTS AND POULTRY PROCESSING PLANTS IN MASSACHUSETTS (By Arthur N. Wilder, D.V.M., and Robert A. MacCready, M.D.3-Boston, Massachusetts, and Atlanta, Georgia) The number of cases of salmonellosis reported in the United States has increased dramatically over the last twenty years. Much of this has been due to a greater awareness of the disease, a better utilization of existing laboratory facilities and intensified epidemiologic investigations. However, real increases in the incidence of salmonellosis have been documented as well. They undoubtedly may be explained by changing patterns of food consumption, and particularly by greater centralization and mechanization of food processing and production. These changes cause more people to be exposed at any one time to possible sources of salmonella contamination. A vivid example of such a large outbreak, made possible by large-scale processing and distribution, is described by Lundbeck et al. To gain a better understanding of the disease and improve the methods of prevention, it is necessary to know the source of infection and its means of spread. One approach to this problem is the survey method, whereby data are compiled to reveal both the reservoirs of salmonella organisms through the sampling of various foods and the distributions of salmonella serotypes in these reservoirs. 8 Poultry and poultry products are the sources most often incriminated in outbreaks of salmonellosis that are food borne.", It has been postulated that one of the means by which poultry become infected with salmonellas is through processing under conditions whereby presumably noninfected birds acquire salmonella organisms from a contaminated environment. Galton et al., during studies in Florida, found salmonellas to be absent from apparently normal birds entering the processing plant, but the organisms could be isolated from the processing environment, iced poultry carcasses after processing and edible viscera. Schneider and Gunderson 10 reported 4 salmonella serotypes on the skin of 4.4 percent of 1014 eviscerated chickens, and concluded that customary methods of sanitation in the plant did not eliminate the organisms. Morris and Ayers isolated salmonellas from one third of the eviscerated carcasses examined during 2 studies in Iowa. Isolations were also made from final rinse water and drainage from chilled giblets. Sadler and his coworkers 12 recovered salmonella organisms from 3 per cent of the birds examined in California plants. Walker observed that the total bacterial counts from the skins of birds rose during processing, but nevertheless found no salmonellas in a study of 6 processing plants. 13 11 To determine the level of salmonellas in poultry reaching the consumer, various authors have examined dressed poultry carcasses from retail markets. Wood1 From the Institute of Laboratories, Massachusetts Department of Public Health, Boston, and the Communicable Disease Center, Atlanta. Assisted by a training grant (A1-221) from the National Institutes of Health. 2 Formerly, Epidemic Intelligence Service Officer, Communicable Disease Center (present address, Scarsdale, New York). 3 Director, Diagnostic Laboratories, Institute of Laboratories, Massachusetts Department of Public Health; lecturer on applied microbiology, Harvard School of Public Health. 4 Annual Summary 1963. Communicable Disease Center Salmonella Surveillance Report No. 19 pp. Atlanta, Georgia: United States Public Health Service, November 13, 1964. 5 MacCready, R. A., Reardon, J. P., and Saphra, I. Salmonellosis in Massachusetts: sixteen-year experience. New Eng. J. Med. 256 :1121-1128, 1957. 6 Lundbeck, H., Plazikowski, U., and Silverstople, L. Swedish salmonella outbreak of 1953. J. Appl. Bact. 18:535-548, 1955. 7 Quist, K. D. Salmonellosis in poultry. Pub. Health Rep. 78:1071-1073, 1963. 8 United States Department of Health, Education, and Welfare. Public Health Service, National Office of Vital Statistics. Vital Statistics of the United States. Vol. 12. Morbidity and Mortality Weekly Report. Washington, D.C.: Government Printing Office, October 25, 1963. P. 348. Galton, M. M., Mackel, D. C., Lewis, A. L.. Haire, W. C., and Hardy, A. V. Salmonellosis in poultry and poultry processing plants in Florida. Am. J. Vet. Research 16:132-137, 1955. 10 Schneider, M. D., and Gunderson, M. F. Investigators shed more light on salmonella problem. United States Egg & Poultry Magazine 55:10, 1922. 11 Morris, T. G., and Ayres, J. C. Incidence of salmonella on commercially processed poultry. Poultry Sc. 39:1131-1135, 1960. 12 Sadler, W. W., Yamamoto, R., Adler, H. E., and Stewart, G. F. Survey of market poultry for Salmonella infection. Appl. Microbiol. 9:72-76, 1961. 13 Walker, H. W., and Ayres, J. C. Incidence and kinds of microorganisms associated with commercially dressed poultry. Appl. Microbiol. 4:345-349, 1956. burn" found 27 per cent of 264 dressed carcasses to be salmonella positive in a survey of 19 retail stores. Wilson and his associates 15 noted 24 per cent of chicken giblets and 13 to 21 per cent of chicken parts to be salmonella positive. Felsenfeld et al.16 reported that 5 per cent of poultry purchased during 1943-1949 in Chicago markets were positive for salmonellas. In addition to poultry as a source of salmonella, eggs, particularly in the bulk, frozen form, have frequently been implicated in outbreaks of food-borne salmonellosis.17 17 18 Ager 19 stated that 24 per cent of 1758 samples of frozen eggs contained the organisms. A total of 21 different serotypes were recovered. The Utah State Health Department " reported 7.8 per cent of 166 samples of frozen egg to be contaminated. Thatcher and Montford 20 found 27 of 114 frozen whole eggs to contain salmonellas in Canada. To determine the level of salmonella contamination in poultry and poultry products in Massachusetts, a study was designed to examine dressed poultry from retail markets and the processing procedures that these birds undergo before reaching the market. Furthermore, a survey was conducted to detect the presence of salmonellas in canned frozen eggs used in commercial food preparation. The majority of these frozen eggs were from out-of-state packers. To study the processing procedures for poultry, 2 plants were chosen. One was under the United States Department of Agriculture's poultry inspection program; the other was not under any active inspection. Our purpose was to determine the following points: the level of salmonella contamination within the 2 plants; whether the salmonellas were being introduced regularly through the feces of carrier birds; the level of salmonella contamination in dressed birds going to the retail markets after processing; whether the organisms persisted and multiplied within the plants after introduction; and whether the federal inspection program altered the level of contamination within the plants. Samples were obtained from the 2 plants at various intervals over a twelve-month period, December 23, 1963, to January 4, 1965. Dressed poultry of the broiler-fryer type were purchased from 8 retail markets from January 11 to May 6, 1965, and included birds from 9 processing plants. Samples of frozen eggs were obtained from 7 cold-storage warehouses from December 3, 1963, to November 17, 1965, and included products from 8 eggbreaking firms. The samples studied were obtained in co-operation with the Division of Food and Drugs of the Massachusetts Department of Public Health and the United States Food and Drug Administration, Boston, Massachusetts. PLANT DESCRIPTION Uninspected Plan A was the smaller of the 2 facilities, having half the floor space of inspected Plant B. The processing equipment was crowded together and frequently inaccessible for proper sanitizing and cleaning during processing. The processing line was often understaffed and at times moved too rapidly. When this occurred, birds often fell off the line, or if improperly processed by an undermanned station, were removed from the line and stacked on the floor by an employee of the next station. The birds remained there, sometimes up to an hour, until someone was available to replace them on the line for reprocessing. The birds then continued with the others through the remaining processing stations. It is obvious that these birds were likely to become contaminated while on the floor, and could go on to contaminate both machinery and employees' hands, from which uninfected birds could acquire the salmonella organisms via mechanical transfer. 14 Woodburn, M. Incidence of Salmonella in dressed broiler-fryer chickens. Appl. Microbiol. 12:492, 1964. 15 Wilson, E., Paffenbarger, R. S., Jr., Foter, M. J., and Lewis, K. H. Prevalence of Salmonellae in meat and poultry products, J. Infect. Dis. v09: 166-171, 1961. 16 Felsenfeld, O., Young, V. M., and Yoshimura, T. Survey of salmonella organisms in market meat, eggs, and milk. J. Am. Vet. M. A. 116: 17-21, 1950. 17 Newman, E., Jenkins, A. A., Howard, P. N., and Goldsby, J. B. Outbreak of gastroenteritis due to Salmonella heidelberg. Communicable Disease Center Salmonella Surveillance Report No. 28, 17 pp. Washington, D.C.: Government Printing Office, August 21, 1964. Pp. 3-6. 18 Communicable Disease Center Salmonella Surveillance Report No. 29, 17 pp. Washington, D.C.: Government Printing Office, September 28, 1964. P. 16. 19 Ager, E. A. Follow up of report of outbreak of salmonellosis occurring in college in Washington. Communicable Disease Center Salmonella Surveillance Report No. 20. 15 pp. Atlanta, Georgia: United States Public Health Service, January 6, 1964. Pp. 9-11. 20 Thatcher, F. S., and Montford, J. Egg-products as source of Salmonellae in processed foods. Canad. J. Pub. Health 53: 61-69, 1962. |