June 5, 2012
A few years ago, I had the opportunity to tour a poultry processing plant in Salisbury, Maryland. Our visit was eye-opening and overwhelming in many ways; to me, the most shocking aspect of the operation was its speed. Two USDA inspectors sat by a mechanized assembly line. Every fraction of a second, a robotic arm presented one of the inspectors with the viscera (guts) of a chicken carcass. The inspectors handled the viscera and took a quick glance at each carcass, checking for tumors, fecal contamination and other obvious signs that the carcass might pose a food safety risk to consumers. Occasionally, one of the inspectors would pluck a chicken off the line and toss it in an orange bin marked “USDA REJECT.”
As part of the newly proposed Modernization of Poultry Slaughter Inspection rule, the USDA would raise the maximum rate at which birds could be slaughtered from 140 to 175 birds per minute, cut the number of inspectors per line to one, reduce the number of viscera inspections and allow plant employees to help identify unsuitable carcasses.
The poultry processing industry is already faced with challenges presented by its speed, scale and lack of testing and oversight. The proposed rule would make it faster and larger, and it would drastically alter the manner in which carcasses are inspected. While the USDA defends the proposed changes as part of several important measures to “modernize” food safety protection in the U.S., as my colleagues and I stated in a recent public comment, we have a range of concerns as to how these changes might negatively impact food safety, worker health and community health.
Increased opportunities for cross-contamination
A hallmark of industrial food animal production is the drive toward achieving greater economies of scale. For the poultry processing industry, this means finding ways to slaughter more birds, in less time and at lower costs. The proposed increase in line speeds would allow plants to process a greater number of birds over the course of an operating shift.
Between routine cleanings of equipment, pathogens introduced by infected and colonized birds can spread throughout a processing facility, contaminating surfaces, equipment and workers’ gear. With more carcasses processed in each facility per shift, the likelihood of introducing pathogens to the processing environment becomes greater. In addition, the increase in line speed means that a greater number of carcasses could become cross-contaminated following the introduction of an infected or colonized bird. As a greater number of contaminated poultry products enter our food supply, consumers are at greater risk for exposure to foodborne pathogens.
Occupational and community health risks
Processing plant workers are in constant contact with potentially contaminated carcasses and machinery. They are at a higher risk of sustaining an infection with dangerous pathogens, including methicillin-resistant Staphylococcus aureus (MRSA) and other drug-resistant bacteria. With a greater volume of carcasses processed in each facility per shift, the likelihood of introducing pathogens to the processing environment becomes even greater.
The Occupational Safety and Health Administration is among several organizations that have called for a reduction in line speeds, on the assumption that faster speeds increase the risk of injury among plant workers. In addition to the direct physical consequences of injury, employees who incur cuts, burns, scrapes or abrasions on the job are even more susceptible to the infections describe above.
The health risks of increased line speeds are not limited to workers. Infected or colonized workers may carry pathogens into their homes and communities, particularly if they go to the clinic or hospital to seek treatment for work-related infections or illnesses. Pathogens may migrate and persist in health care settings and other environments, where vulnerable populations may be subsequently exposed. While none of this is new in the current understanding of how food animal processing may impact occupational and public health, all of these problems could be amplified by the proposed rule.
Changes in inspection
The new rule proposes to shift responsibility for the initial screening of carcasses from government inspectors to plant employees. In the current system, although USDA line inspectors perform only brief physical inspections, they serve the important function of keeping the most dubious carcasses from entering our food supply.
Perhaps even more importantly, USDA inspectors help keep overtly-contaminated carcasses from continuing down the assembly line, where they can rapidly spread pathogens to equipment, workers and other carcasses. These widespread cross-contamination events are undetectable to the naked eye, and are of great concern to food safety and the protection of public health.
The proposed changes are meant to enable inspectors to focus on other duties, such as testing for pathogens and overseeing sanitation procedures. These changes may go to some lengths toward enhancing food safety, and we support placing a greater emphasis on these aspects of inspection. It is a potentially dangerous move, however, to place responsibility for line inspection on slaughter plant workers, who lack the level of training as USDA inspectors (many have doctorates in veterinary medicine), and who must judge and screen each bird while engaged in other critical tasks.
The Center’s response
The Johns Hopkins Center for a Livable Future, alongside the American Public Health Association, United Food & Commercial Workers International Union and countless other individuals and organizations that work in the realms of occupational and public health, have urged the USDA not to implement the proposed rule. In particular, we urged the agency not to increase the maximum allowable line speeds, and not to change inspection policies before the potential impacts have been properly evaluated and reviewed. The agency responsible for food safety inspections in poultry processing plants may be chronically understaffed and underfunded, but this does not justify changes that may increase risks to workers, their communities and the public at large.