Translating the New Swine Inspection System

The New Swine Inspection System

The U.S. Department of Agriculture (USDA) has proposed a new food safety inspection program called the New Swine Inspection System. If finalized, this new system would privatize inspections in hog slaughter plants, decreasing the number of USDA inspectors and replacing them with company employees to do key food safety inspection tasks. It would also allow these plants to increase their line speed.

This type of company self-inspection has been used in five hog slaughter plants participating in a pilot program established in 1998 called the HACCP-based Inspection Model Project (HIMP). A 2013 USDA Inspector General audit found that after 15 years of the pilot program’s existence, USDA could not determine whether the goals of the program were met because of inadequate oversight.

Food & Water requested food safety performance data from the USDA under the Freedom of Information Act (FOIA) for the five hog HIMP plants as well as five comparably-sized hog plants operating under traditional inspection, for the period from January 1, 2012 through November 30, 2016.

We analyzed the regulatory violations filed over this nearly five-year period in these 10 plants and found that:

-   While five HIMP plants received slightly less than half of the total non-compliance reports filed by USDA inspectors in the 10 plants, the types of violations more commonly reported in HIMP plants were significant.

-   HIMP plants received 84% of the non-compliance reports filed for problems with food safety plans; 73% of the reports filed for carcass contamination with feces, bile, hair or dirt; 65% of the reports filed for general carcass contamination; and 61% of the reports filed for equipment sanitation.   

-   Over the five-year period, there were 32 instances – all occurring in the HIMP plants – in which a USDA on-line inspector discovered that a plant employee failed to identify a carcass so infected that consumption of the meat could cause food poisoning.

-   The 3,562 non-compliance reports filed in HIMP plants included 7,169 regulatory violations.

A small sample of reports from each HIMP plant is included in the downloadable pdf.

The plants covered by the FOIA request were:

Source: “FSIS Nationwide Market Hogs Microbiological Baseline Data Collection Program:  Study Design for Technical Consultation,” October 2011.

Regulatory Requirements Under The Federal Meat Inspection Act

9 CFR 417.2 (c) (4) - Hazard Analysis and HACCP Plan.

(c) The contents of the HACCP plan. The HACCP plan shall, at a minimum:

(4) List the procedures, and the frequency with which those procedures will be performed, that will be used to monitor each of the critical control points to ensure compliance with the critical limits;

9 CFR 310.18 (a) (b) - Contamination of carcasses, organs, or other parts.

 (a) Carcasses, organs, and other parts shall be handled in a sanitary manner to prevent contamination with fecal material, urine, bile, hair, dirt, or foreign matter; however, if contamination occurs, it shall be promptly removed in a manner satisfactory to the inspector.

(b) Brains, cheek meat, and head trimmings from animals stunned by lead, sponge iron, or frangible bullets shall not be saved for use as human food but shall be handled as described in § 314.1 or § 314.3 of this subchapter.

9 CFR 416.3 (a) - Equipment and utensils.

 (a) Equipment and utensils used for processing or otherwise handling edible product or ingredients must be of such material and construction to facilitate thorough cleaning and to ensure that their use will not cause the adulteration of product during processing, handling, or storage. Equipment and utensils must be maintained in sanitary condition so as not to adulterate product.

9 CFR 416.5 (a) - Employee hygiene.

 (a) Cleanliness. All persons working in contact with product, food-contact surfaces, and product-packaging materials must adhere to hygienic practices while on duty to prevent adulteration of product and the creation of insanitary conditions.

9 CFR 416.4 (a) (b) - Sanitary operations.

 (a) All food-contact surfaces, including food-contact surfaces of utensils and equipment, must be cleaned and sanitized as frequently as necessary to prevent the creation of insanitary conditions and the adulteration of product.

(b) Non-food-contact surfaces of facilities, equipment, and utensils used in the operation of the establishment must be cleaned and sanitized as frequently as necessary to prevent the creation of insanitary conditions and the adulteration of product.

9 CFR 416.13 (c) - Implementation of SOP's.

(c) Each official establishment shall monitor daily the implementation of the procedures in the Sanitation SOP's.

9 CFR 311.16 -  Carcasses so infected that consumption of the meat may cause food poisoning.

(a) All carcasses of animals so infected that consumption of the products thereof may give rise to food poisoning shall be condemned. This includes all carcasses showing signs of:

(1) Acute inflammation of the lungs, pleura, pericardium, peritoneum, or meninges.

(2) Septicemia or pyemia, whether puerperal, traumatic, or without any evident cause.

(3) Gangrenous or severe hemorrhagic enteritis or gastritis.

(4) Acute diffuse metritis or mammitis.

(5) Phlebitis of the umbilical veins.

(6) Septic or purulent traumatic pericarditis.

(7) Any acute inflammation, abscess, or suppurating sore, if associated with acute nephritis, fatty and degenerated liver, swollen soft spleen, marked pulmonary hyperemia, general swelling of lymph nodes, diffuse redness of the skin, cachexia, icteric discoloration of the carcass or similar condition, either singly or in combination.

(8) Salmonellosis.

(b) Implements contaminated by contact with carcasses affected with any of the disease conditions mentioned in this section shall be thoroughly cleaned and sanitized as prescribed inpart 308 of this subchapter. The equipment used in the dressing of such carcasses, such as viscera trucks or inspection tables, shall be sanitized with hot water having a minimum temperature of 180 °F. Carcasses or parts of carcasses contaminated by contact with such diseased carcasses shall be condemned unless all contaminated tissues are removed within 2 hours.