Sometimes a frank airing of differences of opinion can lead to better understanding among differing parties and can ultimately lead to some sort of compromise. The U.S. boiler industry has significant areas of disagreement with USDA FSIS’ Salmonella Initiative Program (SIP) and these were discussed at USPOULTRY’s Processor Workshop held recently in Atlanta, Ga.
Dr. Petit Ewing, director of veterinary services, Koch Foods, presented what he called “his views” of current FSIS initiatives, including SIP. After Ewing’s talk, Dr. Ailing Yancy, vice president, food safety and production programs, U.S. Poultry and Egg Association, said to the USDA representatives at the Workshop, “The broiler industry is almost universally opposed to SIP as it is currently proposed.”
SIP appeared in the Federal Register in January of 2008, and according to Ewing, it was introduced with numerous logistical problems. He said that most of these problems were presented and discussed with FSIS by trade industry associations the previous fall, and it was thought that agreement had been reached. Yet, when SIP was introduced it was done without addressing industry’s concerns. “Industry and FSIS had settled on a workable program. When SIP was released, all of the industry’s concerns and input were completely ignored,” Ewing said.
Since SIP is a voluntary program, the agency could bypass many of its own regulations and practices for implementing a program that has such broad implications for the industry. Ewing said, “By tying SIP to Online Reprocessing (OLR) and HACCP Inspections Model Project (HIMP) waivers, FSIS was assured that about 99% of the industry would have to volunteer.”
Despite this, Ewing said that some companies looked to see if they could give up OLR and not participate in SIP, and no broiler plants had volunteered for SIP by late May of this year.
Dr. Isabel Arrington, scientific advisor to the Policy Development Division of FSIS, said that cases of human salmonellosis per 100,000 people in the U.S. are not declining and that the country will likely not meet its healthy people 2010 objective of 6.8 or fewer cases of salmonellosis per 10,000 people. In 2007, the salmonellosis rate was 14.92 cases for 10,000 people which is higher than the 1997 rate of 13.7. Arrington noted an adverse upward trend in the number of salmonella positive chickens found in the agency’s salmonella verification tests in the years of 2002 to 2005. Salmonella verification test results have shown a reduced incidence of salmonella from 2006 till the present time.
SIP is one of FSIS’ initiatives launched to try and bring salmonella incidence on carcasses to lower levels. Ultimately, it is hoped that reducing salmonella numbers on poultry carcasses will reduce the rate of human salmonellosis cases.
The approach that FSIS has taken to SIP is indicative of the type of “incentives” the agency has given to industry over the last few years to innovate and change, according to Ewing. He cited the publication of the names of plants in Category 2 and 3 on salmonella test sets as an example of encouragement given to the poultry industry to improve its performance in controlling salmonella. Another example occurred at a meeting of the National Advisory Committee on Meat and Poultry Inspection, where, according to Ewing, the then under secretary for food safety Dr. Richard Raymond, said, “We don’t know how to control salmonella, but if we make it cost enough money, you’ll find a way.”
Ewing said that the agency’s carrot and stick approach has relied much more heavily on the stick lately. For instance, FSIS appears to be using Food Safety Assessments (FSA) as a means of influencing processors decisions. Ewing quoted Dr. Dan Engeljohn, Office of Policy and Program Development, FSIS, as saying “FSIS is taking the approach to just conduct an FSA and issue NOIEs because we have found that companies are much more cooperative while under and NOIE.” Ewing posed the question to the audience, “Is it extortion for FSIS to say you will get an FSA if you don’t do something?”
Bad policy decisions
Ewing said that the perception of FSIS within the industry is that policy is being made by people with limited plant experience. Regulation has become more punitive instead of protective of the public. “The agency is trying to regulate in broader areas, where it has no expertise of its own (like in live production) and little patience with those that do,” Ewing said.
When making policy decisions FSIS needs to listen to experts in all areas, according to Ewing. “These experts may be in other government agencies, universities, allied industry experts, the poultry industry itself or from the FSIS field operations staff at or below the district level. Seeking input from all these sources can help prevent problems with implementation,” he said.
Ewing said that when forming policy, FSIS needs to look at all of the scientific data available, including field trials. He said that the agency needs to look at the science first and form the policy second.
Ewing added that FSIS has to realize that resources are limited for industry and the agency, this means money, time and laboratory testing. Saying that “there is no price on food safety” does not excuse FSIS from rational decision making. Wise allocation of resources may mean discarding inefficient policies and not wasting resources on punitive measures.
“Everyone needs to accept scientific limitations, they are not excuses. Zero tolerance for salmonella on ready-to-cook poultry products is not a realistic goal,” Ewing said.
Ewing said that an industry committee was formed with direct communication with FSIS. As a result of these discussions, industry has committed to take some actions for salmonella reduction, but industry needs time to do this, according to Ewing.
Arrington said that in the next Federal Register notice FSIS will clarify when OLR and HIMP waivers will come under SIP and what will happen if plants don’t participate. She said that there will be a comment period when the notice appears.
“Vilifying each other implicates both,” Ewing said. “If we are the greedy industry that has the answers to all these problems but just won’t spend the money to solve them, that doesn’t look good. Or, if they (FSIS) are the bumbling bureaucrats that have no idea what they are doing, that doesn’t do the industry any good. We both need to partner-up and actually solve some problems.”