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CHAPTER 2 POULTRY INSPECTION IN THE UNITED STATES: HISTORY AND CURRENT PROCEDURES The current U.S. poultry inspection system can be traced to needs that first became apparent around the turn of the century. In the early l900s, the poultry industry in the United States was little more than a sideline to farmers who raised fowl for personal consumption and sold some to bring their families a few extra dollars. Chickens and turkeys were mainly produced on small farms and sold, live or slaughtered, to local customers or transported to markets in the n~r".c:t r' ~1 ~.c: b':~rm~r.c: ~nn~h:~"n h~t:~h-d Once hrnnd~d thn1 r Own a% a_ ~~ ~ ~ ~ ___ . ~ ~_~w _ ~ ~ ~.~ ~~ _. ~ . ,., ~~.~% ~ . ~~ a_ ~~ ~,.~ __ ~ a., _ _ , , _ ~ . ~ . ~ _ ~ ~ . ~ ~ . ~ cricks using nome-grown reeds and an assortment or remedies ror disease. There were no standard poultry-raising methods, and the quality and quantity of poultry varied greatly from farm to farm. Furthermore, there were no government regulations to ensure the quality of poultry or other food products. In 1906 the Meat Inspection Act was passed, but this legislation did not cover poultry. At that time and for a while afterward, poultry was a mi nor meat product, being regarded merely as a Sunday dinner speciality. Thus, small - scale production of poultry by independent farmers was adequate to meet public needs (USI)A, 19 84b ~ . Most poultry was purchased by the consumer either live from the farmer-producer or a produce house or as a New York-dressed carcass (only blood and feathers removed). The housewife eviscerated and finally Prepared the product _ . , ~ , ~ _ ~ ~ _ l. tor cooking, observing rlrst-nanu whether there were annormatltles, spoilage, or evidence of unwholesomeness (Libby, 1975~. As poultry production slowly increased, purchasers began to demand government inspection of live and slaughtered poultry. In the 1920s, there was an outbreak of avian influenza in New York CitY, which served as the major poultry distribution point. This incident led to an increased awareness of the need for ensuring product wholesomeness. As a result, cities, counties, and states began establishing their own inspection programs (USDA, 19 84b ~ O In 1926, the Federal Poultry Inspection Service (FPIS ~ was established to assist localities in their inspection programs. In the beginning, FPIS inspected live poultry at railroad terminals and poultry markets in and around New York City. This voluntary 12

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13 inspection was conducted under an agreement between the U.S. Department of Agriculture (USDA) and two cooperating agencies--the New York Live Poultry Commission Merchants Association and the Greater New York Live Poultry Chamber of Commerce (USDA, 1984b). FPIS was also authorized to conduct its own voluntary postmortem inspection. Eviscerated poultry inspection was initiated by FPIS at the request of purchasers. Processors of canned goods containing poultry were frequently required by certain foreign and local governments to include FPIS wholesomeness certificates in all shipments of canned poultry products coming into their jurisdiction. Before 1940, most poultry was slaughtered and plucked in dressing plants and then shipped as New York-dressed poultry. Inspection was done at the point of delivery, if at all. Military needs greatly increased the demand for poultry products during World War II, and military purchasing agents called on USDA to supply the inspection and certification services necessary for processors to meet military purchase specifications (USDA, 1984b). As military and consumer demand shifted from a preference for live poultry to New York-dressed poultry and then to ready-to-cook poultry, and as the industry attempted to accommodate these changes in demand, the USDA modified its inspection and certification program. Point-of-delivery inspection was not satisfactory for further processed products, such as ready-to-cook poultry, since the conditions of slaughtering and dressing would not be known by the consumer. For this reason, the military met its wartime poultry needs by purchasing only from plants that had been surveyed and found to meet military sanitation requirements. Soon thereafter, USDA required that evisceration and canning plants process New York-dressed poultry purchased only from plants that met USDA sanitation requirements. USDA also established procedures for conducting antemortem inspections at the dressing plants. The formalization of these procedures accelerated a trend toward consolidating dressing and eviscerating activities within a single plant. During this period, inspection of poultry served two purposes: ensuring the wholesomeness of the poultry product and promoting sales by enabling processors to ship their product into jurisdictions that required certification. This dual role served to guide the federal government's voluntary poultry inspection program and provided the basis for passage of the Poultry Products Inspection Act (PPIA) in 1957 (USDA, 1984b). PPIA required several kinds of inspection for poultry products destined for interstate commerce (USDA, 1984b): · inspection of birds prior to slaughter · inspection of each bird carcass after slaughter and before processing labeling inspection of plant facilities to ensure sanitary conditions inspection of all slaughtering and processing operations verification of the truthfulness and accuracy of product · inspection of imported poultry products at the pa int of entry

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14 This act also made mandatory the inspection of all poultry products intended for interstate commerce and thus subject to federal control. It required both antemortem inspection (to the extent deemed necessary by the USDA Secretary) and postmortem inspection of all birds slaughtered for such shipments, and sanitation inspection of al l plants processing such products (USDA, 1984b). The enactment of PPIA was not a response to perceived defects in the inspection system but, rather, a reaction to changes in consumer perceptions and marketing patterns. Poultry inspection activities during World War II increased consumer awareness of inspection. This in turn led to an increase in sales of poultry products bearing the FPIS certification mark. The fact that USDA certification was manditory in order to market products in certain localities further stimulated industry interest in a broader federal inspection program. The substantial growth in the poultry industry during and immediately after the War had transformed i t from one with primarily local markets to one with nationwide markets that could be effectively served only by uniform national inspection procedures and standards (USDA, 1984b). The responsibility for implementing PPIA remained with the USDA's Agricultural Marketing Service (AMS), which had administered the voluntary poultry inspection program in effect before the Act was passed. AMS was strongly oriented toward facilitating the industry's abili ty to market agricultural commodities. Congress expressly recognized in its preamble to the PPIA the importance of marketing obj ectives as a basis for federal inspection, stating that : Unwholesome, adulterated, or misbranded poultry products impair the effective regulation of poultry products in interstate or foreign commerce 9 are injurious to the public welfare, destroy markets for wholesome, not adulterated, and properly labeled and packaged poultry products, and result in sundry losses to poultry producers and processors of poultry and poultry products, as well as injury to consumers (USC, 1983a, p. 833~. The Wholesome Poultry Products Act (WPPA) of 1968 required inspection of virtually all poultry sold to consumers . Previously, 16% of the chickens processed In the United States were not inspected by USDA because they were not transported across states lines and 31 states had no program of their own to cover the inspection of such poultry. The goal of the 1968 Act was to bring this uninspected poultry under an inspection program, whether state or federally operated (USDA, 1984b). The Act established federal-state cooperative programs of inspection closely paralleling those established under the Wholesome Meat Act passed a year earlier. The federal government supplied technical assistance and up to 50% of the funding for state-approved inspection programs. To gain such support, state programs had to establish requirements at least equal to those of the

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15 federal inspection program. The 1968 Act also required USDA to take over the inspection programs of states that did not develop an acceptable program within a specified period (USDA, 1984b). Although WPPA ammended the 1957 PPIA, no significant changes were made in federal antemortem or postmortem inspection processes. Antemortem inspections continued on samples obtained from flocks, whereas pos tmortem inspection of each bird remained mandatory . No major changes have been made in the poultry inspection laws since 1968 (USDA, 1984b), despite the more than tripling of the pounds of poultry inspected (see Table 2-1~. TABLE 2-1. Hi story of Inspected Plantsa Live Weight Number of Birds Inspected Year of Plants (billions of pounds 1927 1 Not available 1928 7 0.0032 1940 35 0.076 1954 260 1.0 1958 468 2.0 1964 201 6.6 197S 154 13.7 1981 371 20.0 aFrom USDA, 1984b. POULTRY INSPECTION ACTIVITIES To meet its statutory requirements under PPIA, the USDA administers at least eight public health-related inspection activities: antemortem inspection postmortem inspection condemnation and final disposition sanitary slaughter and dressing poultry chilling plant sanitation carcass reinspection residue monitoring Brief descriptions of each public health-related activity specified by PPIA are provided in the following paragraphs: l

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16 Antemortem Inspection According to the PPIA, The Secretary shall, where and to the extent considered by him necessary, cause to be made by inspectors antemortem inspection of poultry in each official establishment processing poultry or poultry products for commerce.~..(USC, 1983b, pO 838~. Antemortem inspection (USDA, 1984b) refers to the examination of live poultry to detect signs of disease. The USDA inspector observes the flocks between the time they arrive at the slaughtering plant and the time birds are hung on the slaughtering lines Because antemortem inspection is discretionary, it is conducted not bird by bird but on samples selected from flocks or groups of birds in their crates. At times, however, the inspector may examine individual birds to investigate clinical signs and to judge body temperature, fleshing and state of hydration. Antemortem inspection may result in a bird being passed for subsequent delivery to the consumer, condemned, or designated as suspect. A bird is condemned if it plainly shows evidence of any disease or condition that would cause condemnation of its carcass during postmortem inspection. Birds that have already died are automatically condemned. Condemned birds may not be processed further, nor may they be conveyed into any area of the plant where other poultry or poultry products are held or prepared. They must be disposed of in a prescribed manner (USDA, 1984b). A bird is designated as suspect if it appears to be affected with any condition that may cause condemnation during postmortem inspection. Birds so classified are segregated from other poultry and held for separate slaughter, evisceration, and postmortem inspection (USDA, 1984b~o Most producers augment the USDA process with their own antemortem inspection programs, primarily to provide the plant with early data on probable flock condemnation rates. At present, antemortem inspection accounts for less than 1% of a USDA inspector's inspection activities (USDA, 1984b). Pos tmortem Inspection Bird-by-bird postmortem inspection of carcasses is required for all poultry slaughtered in a federally inspected establishment. Inspectors observe the carcass exterior; open the body cavity and examine inner surfaces and organs, including the liver, heart, spleen, and Other viscera ; and instruct a trimmer (a plant employee) on the disposition of each carcass. This inspection is designed to ensure that each bird is free from readily apparent disease (such as leukosis, septicemia

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17 toxemia, air sacculitis, tumors, and parasites), that it is not badly bruised or otherwise damaged, and that it did not die from any cause other than slaughter (USDA, 1984b). Following is a list of the manual operations required for the traditional method of postmortem inspection as described by Libby and Humphreys (1975~: Right-hand operation: Grasp one leg, run hand down leg to determine indication of bone disease. Open body cavity to view internal surfaces. Turn body to view outside of bird (including head) for disease, abnormalities, and dressing imperfections. Left-hand operation: Place hand over liver to feel for consistency, texture, and lesions, viewing simultaneously. Slip fingers around liver and grasp the spleen between thumb and finger, rolling spleen to determine texture and presence of abnormal condition. In case of fryers and broilers it is not necessary to roll spleen. Simultaneously view other viscera while checking spleen. A differing opening cut (i.e., along back) may require slight modifications in this procedure (Libby and Humphreys, 1975, pp. 170-171~. To facilitate inspection and prevent contamination of edible tissues, PPIA requires that the carcass be presented in such a way that the entire carcass, including the internal and external body surfaces and all the internal organs, can be thoroughly inspected (Libby and Humphreys, 1975~. Hocks must be cut in preparation for inspection so that the telltale exudates of infectious synovitis in tendon sheaths and joint capsules can be detected. The feet are removed just before the inspection and, in all cases, after the carcasses have passed the last washer unit. Washing the carcass after cutting of the hocks would of course interfere with this inspection. The heads of young chickens can be removed prior to inspection. The heads of mature chickens may be removed before postmortem inspection, provided the inspector in charge has determined at antemortem inspection that such removal will not affect postmortem disposition. Permission to remove the heads from a particular group or lot of mature chickens may be rescinded by the inspector in charge, or a designee, if the the heads are needed to make a proper disposition. Plants are also required to provide certain facilities at the inspection station. For example, a switch or button control must be

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18 accessible to the inspector, who can then stop or start the processing line in connection with postmortem and sanitation control. In addition, adequate lighting of uniform intensity must be provided at all working levels. Plants are also required to separate double lines of carcasses with dividers to prevent confusion and to ensure that each carcass will receive the inspector's attention. Visceral organs must be placed near the carcass from which they have been removed. Hand-washing facilities must be adequate and properly located at both operating and inspecting positions (Libby and Humphreys, 1975)0 A trained company employee called a trimmer must be assigned to each inspector to perform such functions as plucking feathers, trimming bruises, moving condemned birds from the shackles into condemned cans, placing suspect birds on the hang-back rack for more detailed inspection by the Veterinary Medical Officer (VMO), marking the condemnation record sheet, and generally assisting the inspector in routines related to the inspection procedures. Production lines must be adequately staffed with properly trained employees functioning under effective supervision (Libby and Humphreys, 19751. Condemnation and Final Disposition On the basis of the inspector's postmortem examination, birds are passed, trimmed and passed, retained for disposition by the VMO, or condemned for any of 11 different reasons (see Table 2-21. The inspector has only 2 to 3 seconds to examine each bird and to decide its disposition (USDA, 1984b). In this manner more than 4.7 billion birds were inspected in fiscal year 1984 (USDA, 1985)0 Sanitary Slaughter and Dressing The principal objective of sanitary dressing is to defeather the bird and to remove its gastrointestinal tract and other internal organs with minimal contamination of edible tissues. In many cases localized or generalized diseases, infections, or contaminations are not detected until the dressing operation has been partially or entirely completed. Preventing fecal contamination of the carcass from spillage of gastrointestinal contents or smearing of external fecal matter on outer skin surfaces is the single most important aspect of sanitary slaughter and dressing. Ideally, slaughter and dressing should be designed to reduce or preferably eliminate contamination from this source. Poultry Chilling After inspection, ready-to-cook poultry is promptly chilled or frozen at temperatures that inhibit microbial growth. All slaughtered and eviscerated birds are chilled to an internal temperature of 40°F (4°C) or less within 4 hours (for a 4-lbe bird) , 6 hours (for a 4- to 8-lb. bird), or 8 hours (for a carcass heavier than 8 lbso ~ unless they

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19 TABLE 2-20 Number and Percentage of Young Chickens (Broilers) Condemned during Postmortem Inspection, by Cause, in Fiscal Year 1984a Percent of Cause of Number Total Condemnation Condemned Inspectedb Tuberculosis O O Leukosis 2,056,872 0.05 Septicemia 15,111,696 0.36 Air sacculitis 8,087,665 0.19 Synovitis 267, 528 0.01 Tremors 1, 394, 009 0 . 03 Bruises 735, 353 0.02 Cadaver 1, 544, 661 0 . 04 Contamination 2, 371, 952 0.06 Overscald 528, 282 O.01 Other _1. 496 .702 0. 04 TOTAL 33,594,720 0.81 aFrom USDA, 1985. bIn FY1984, 4, 203 ,133, 000 broilers were inspected. This represents 89% of all poultry slaughtered (4,722,839,000) in the United States during that period. are to be frozen or cooked immediately at the establishment. FSIS has responsibility for ensuring that these chit ling specifications are met. Packed poultry held at the plant for more than 24 hours must be kept at 36°F (2°C) or less. Giblets are chilled to 40°F (4°C) or lower within 2 hours from the time they are removed from the inedible viscera, except when they are cooled with the carcass (CFR, 1983~. Only potable water may be used for ice and water chilling. The ice is handled and stored in a sanitary manner; block ice is washed by spraying all surfaces with clean water before crushing (NRC, 1985~. Plant Sanitation Inspection of the sanitation practices of poultry plants begins in the poultry holding areas and continues through the handling of live birds, their carcasses, and the products derived from them. The inspectors examine structural aspects of the premises, water supply, manure and sewage disposal, equipment, personnel, and other features of the plant environment (Blair, 1975~.

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20 Slaughtering or processing in an unclean environment or under unclean conditions is prohibited--a requirement that is enforced by the inspector' s ability to rej ect an unclean department or piece of equipment. The plant is warned that the department or equipment identified must not be placed in service until it has been made acceptable and released for use by the inspector (B] air, 1975) . In addition, the inspector completes a daily sanitation report (MP Form 455, August L979) that covers such items as plant cleanliness, rodent and insect control, ice facilities, and dry storage areas O A copy of the daily report is provided to the establishment. Carcass Re inspects on After dressing operations and routine postmortem inspection are completed, selected samples of chickens are reinspected according to a preestablished sampling plan. Defects are evaluated on the basis of accept-reject criteria, and the result is extended to all carcasses represented by the sample. The Acceptable Quality Level (AQL) standards developed in 1973 (USDA, 1974) are applied in all poultry plants with traditional and modified traditional inspection procedures (Berndt, 1985) to detect dressing defects in broiler carcasses after chilling. The data collected include information on the origin, extent, and nature of carcass contamination so that corrective action can be initiated at the source (USDA, 1983a). Recently, FSIS introduced Finished Product Standards (FPS), which make use of the Cumulative Sum System (CUSUM) to score the presence of defects such as ingests, feces 9 feathers, grease, bile remnants, blisters, bruises, sores, scabs, and other lesions on birds. In this system, defects in a sample of carcasses are counted both before and after chilling. Birds not meeting the standards are ''determined by the FSIS to be adulterated" (Anonymous, 1986b, p. 4) . The FPS were developed from data obtained from a random sampling survey of trim and processing defects in 25 poultry plants. In 1983 and 1984 the results of this survey were compared to AQL in eight pilot poultry plants, and the two sets of standards proved to be comparable (Berndt, 1985 ~ . Res idue Monitoring In 1967 9 the Nati anal Residue Program (NRP) was establi shed in FSIS . This program is the U. S . Government's principal regulatory mechanism for determining the presence and level of chemicals In poultry judged, primarily by the Food and Drug Administration (FDA), the Environmental Protection Agency (EPA), and FSIS, to be of public health concern. (FDA and EPA prescribe the conditions under which approved drugs are allowed in poultry). Through this program, FSIS applies new technologies and testing procedures in the monitoring of approximately 100 of the chemicals that may be found in poultry and red meat. FSIS uses an advisory board of scientists from FDA, EPA, and

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21 FSIS to select these chemicals on the basis of their toxicity, exposure levels, persistence, and other relevant criteria (USDA, 1986~. The NRP has four major objectives: monitoring, surveillance, exploratory testing, and prevention of chemical residues in poultry (USDA, 1984a). These objectives are described in the following paragraphs. Monitoring. Monitoring is accomplished through random sampling of imported poultry products and tissues from apparently healthy poultry as they pass through routine inspection at slaughter (postmortem inspection). These samples are tested for compliance with chemical tolerance levels and are studied to determine patterns and trends in the di stribution, frequency , and levels of chemical residues and to identify tolerance- or action-level violations. For example, approximately 7, 500 domestic samples and 434 samples of imported poultry products were scheduled for such testing in 1986 (USDA, 1986 ~ . Poultry tested under the mono taring system is normally sold and consumed before test results are available. The findings are referred to FDA or EPA for review and for use in on-the-farm inspections to determine whether chemicals are misused. On occasion, test results can trigger surveillance testing. Chemicals are periodically added to or deleted from a test list of approximately 100 chemicals. Some monitoring is designed to discern the presence of so-called generic components. For example, the presence of any member of the family of arsenicals is determined by testing for the presence of arsenic. In general, the number of samples selected for the testing of one chemical is designed to ensure, at the 95% confidence level, that the chemical will be detected in at least one sample if it occurs with a uniform distribution in 1% or more of the population of birds slaughtered during a given year. Surveillance. Surveillance is achieved by targeted sampling of poultry products to control or investigate suspected violations. Approximately 7,200 domestic samples, including poultry, and no samples of imported products were scheduled for surveillance in 1986 (USDA, 1986~. Surveillance testing may be initiated when a producer is suspected of marketing animals with residues above limits set by EPA or FDA. Carcasses are retained while the tests are conducted. If violations are found, the carcasses are condemned and the producer is instructed not to market other birds until additional tissue samples no longer contain illegal residues. Before poultry products can be imported into the United States, the countries of origin must monitor them for residues in programs similar to those in effect in this country. When these products reach their U.S. port of entry, they are once again randomly tested for residues.

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22 Exploratory Testing. In exploratory testing, random or nonrandom samples of poultry are taken to study chemicals for which safe limits have not been established (e.g., mycotoxins, trace chemicals, or industrial chemicals). The information gained from these tests is used to define the distribution of the chemicals as well as the frequency and levels of their occurrence. The exploratory program also includes studies to help develop new methods for evaluating existing programs. Prevention of Chemical Residues. In collaboration with USDA's Extension Service, PSIS initiated a chemical residue prevention program in ~ 981. This program is designed to help domestic poultry producers prevent chemical contamination of their birds. It is a primarily educational undertaking that provides counseling by extension service personnel and consulting specialists (USDA, 1983b). CHANGING ENVIRONMENT FOR POULTRY PRODUCTION AND REGULATION In the years since the establishment of the basic principles of poultry inspection, a growing population and changing consumer tastes have caused rapid growth in the poultry industry ~ Increas i ng demand along with technological advances have produced a consolidated, vertically integrated, and highly competitive industry. To meet the new demands for a wide range of products at an acceptable cost, processors have adopted new techniques and innovative processing methods. Poultry are now bred and raised in environments to promote growth and prevent disease. The controlled use of vaccines and drugs, such as antibiotics, has greatly improved the health of the birds and decreased the number rej ected at inspection as unfit for human consumption. Quality control systems have increased the poultry producers' ability to deliver uniform, high-quality flocks to the slaughterhouse. Poultry slaughtering and processing have largely been automated, and faster, more systematic procedures have replaced less-standardized, manual operations. Advances in packaging and preservation have reduced the likelihood of chemical or microbiological contamination. Poultry production and processing has become a highly concentrated industry. Today, about 20 companies operate approximately 220 broiler chicken plants (USDA, 1983c), and 5% of these plants account for almost 65% of the total production. Poultry slaughtering has also become more concentrated--42% of the plants slaughter 75% of all broilers. Vertical integration has enhanced industry control over the raising and slaughtering of birds. Approximately 95% of all poultry producers control their birds' entire life cycles. The increased use of brand names, which are now given to 65% of all poultry products sold at retail, along with the growing selectivity of consumers and potential legal liability have provided strong motivation for-quality control on the part of producers.

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23 The inherent quality of poultry products has undoubtedly improved, but progress in reducing the public health hazards associated with poultry has not been entirely uniform. The proliferation of environmental contaminants and chemicals added to poultry feeds and, to some extent, processed foods has increased the possibility that potentially harmful chemical residues will be found in poultry. The production of poultry products has also become more complex. Early in this century, only a few basic cuts of poultry were available. At present, there is great variety of raw, canned, cured, dried, fermented, and frozen products. Any aesthetic benefits derived from this variety are sometimes offset by new sources of food-borne microbial organisms and chemicals and opportunities for them to contaminate the products. Thus, public health concerns now include antibiotic-resistant bacteria as well as chemical toxicity. Currently, eight broad classes of public health risk are of concern in poultry inspection: bacteria, bacterial toxins, pares ites, fungal toxins, viruses, toxic chemical residues, intentional additives, and process-associated toxicants (NRC, 1985~. Increased poultry production coupled with inflation has led to a substantial rise in the cost of inspection. Because of these factors, the labor-intensive nature of postmortem inspection, and the regulatory requirement to inspect each bird, taxpayer costs for the present kind of inspection may be expected to continue to increase proportionately with the industry growth rate. By law, the federal government provides all inspection services and pays for all inspection except overtime and holiday work requested by slaughtering establishments. As inspection costs have escalated, FSIS program managers have been under increased pressure to justify their programs and to make them more efficient. Furthermore, all regulatory agencies have been asked to eliminate unnecessary regulatory burdens to facilitate improvements in productivity (Presidential Documents, 1981~. These changes in disease prevalence, poultry husbandry, and financial resources have encouraged FSIS to develop more efficient inspection techniques and procedures that will increase, or at least not lower, health protection. For example, one change instituted in the mid-1970s is the development and testing of alternative postmortem inspection procedures that partially shift the burden for maintaining the quality of inspected poultry from FSIS to plant management working under PSIS supervision. ALTERNATIVE POSTMORTEM POULTRY INSPECTION PROCEDURES Postmortem inspection procedures, the most labor-intensive aspect of inspection, have been the principal targets of efforts to increase efficiency. These procedures have recently been modified by PSIS to increase production efficiency and decrease production time, and further changes are being explored (FSIS, 1984; FSIS, personal communication, 19841.

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24 As noted above, traditional postmortem inspection procedures require a complete examination of each slaughtered bird and all its parts, including a relatively cumbersome sequence of hand motions to manipulate each carcass (Berndt, 1985~. In 1979 FSIS instituted a less labor-intensive method called the Modified Traditional Inspection (MTI) system (FSIS, personal communication, 1984~. Under MTI, three inspectors work in sequence to inspect each bird. One inspector examines the outside surfaces of each carcass, using a mirror to see the back of the bird. The other two inspectors examine the inside surfaces and viscera, coordinating their actions so that each handles every other bird. The hand motions for inspecting the inside of the carcass and its internal organs were also redesigned and streams ined. The MTI system was tested in the field and found to be more efficient than and as effective as the traditional system in identifying evaluated abnormalities. Maximum line speed achievable under MTI is 70 birds per minute (FSIS, 1984~. FSIS has explored and begun to adopt several other methods of sequenced inspection. One method, known as the hands on/hands off procedure (FSIS, personal communication, 1984), involves a team of four inspectors. The first one examines the outside surfaces of a carcass; the second examines the drawn viscera, which are hung on another line. Both inspectors use mirrors, not their hands. The birds are then alternately assigned to the other two inspectors, who examine the inside surfaces with their hands. This procedure is now used in only two broiler plants in the United States (Berndt, 1985~. In a similar, even less labor- intensive design called the total hands - off procedure, a machine opens the carcasses for ins ide viewing . The inspector does not touch either the internal organs or the carcass. Because initial tests indicate that this system is not as effective as the traditional and MTI inspection procedures, it has not been implemented. Future use of this approach will require either the development of improved equipment for opening the birds effectively and consistently so that the inspectors have an unobstructed view, or a change in the criteria used to judge the effectiveness of inspection. In 19829 FSIS began field trials of the New Line Speed (NELS) inspection system, a quality control system operated by the plant but monitored by an FSIS inspector (Berndt, 1985; PSIS9 19841. Under NELS, the government inspectors inspect the birds and determine which birds should be condemned and which should be passed for food. The plant workers then inspect the passed birds for certain outside defects, which they trim. Eliminating the need for direct FSIS participation in the trimming of each carcass reduces inspector time per carcass. With NELS, the maximum line speed depends on a plant ' s ability to provide inspectors with properly presented birds. As the proportion of defective birds increases, line speeds necessarily decrease. Presently, 10 U.S. plants are using NELS on a test basis. Most of these plants operate line speeds of approximately 90 birds per minute O

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25 In 1985 FSTS made further departures from traditional inspection by testing a system that would transfer responsibilities for all bird inspection to plant personnel working under a plant-operated quality control system (Berndt, 1985~. In this Third-Generation Inspection System, the government' s role is limited to inspect) on of a sample of birds to ensure that the quality control system is working properly. Two FSIS inspectors are stationed on each production line. One of them sets a standard for inspection by which five industry inspectors, who have been trained and certified in the NELS procedure, are judged. An automated computer system compares each plant inspector's level of performance (in terms of frequency of inspection actions ~ to that of the USDA food inspector and indicates, through light and audio alarms, when performance is questionable. The second government inspector, who is stationed at the end of the line, uses that information to compare the condemnation and trim rates of the industry inspectors with those of the USDA standard- setter and initiates specific action to respond to any problem. This last inspector also looks for abnormalities suggesting the need for condemnation of birds at the end of the line where the birds pass at a rate of 182 birds per minute. FSIS claims that this final step meets the legal requirements for bird-by-bird inspection (Berndt, 1985~. Recently, FSIS embarked on a program to modify MTI, still the most widely used postmortem inspection system, by incorporating some features found to be effective in the other systems it has explored. In the new system, called the Streamlined Inspection System (SIS) (Anonymous , 1986b) , one or two inspectors (SIS-1 or SIS-2) are needed instead of the three used in MTI, depending on the size of the plant. Each inspector will examine the whole bird, i.e., the outside of birds and the inside cavities and internal organs. A plant employee termed a helper and assigned to each inspector will identify bruises, broken wings, and other manufacturing defects to be trimmed by other plant employees after the giblets are removed. This assistance will allow FSIS inspectors to concentrate on detecting diseases and other abnormalities. In addition to obtaining new equipment and making some facility changes (Anonymous, 1986b; FSIS, 1986 ), the 137 plants now us ing MTI will be required to maintain an FPS program that includes a prechill test to measure the effectiveness of process ing controls and a postchill test to measure changes (such as moisture absorption) that take place during the chilling process. The CUSUM statistical sampling method (see above section on Carcass Reinspection) will be used by FSIS to monitor the adequacy of plant trimming and processing operations to ensure that the product meets regulatory standards (Anonymous, 1986a). The maximum line speeds on SIS wil 1 be 35 birds per minute under one inspector and 70 birds per minute under two inspectors, the same rate now allowed for the three inspectors under MTI.

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26 CONCERNS REGARDING THE HEALTH IMPACTS OF NEW INSPECTION SYSTEMS According to public opinion polls, the general population apparently has confidence that the current traditional system of poultry inspection is sufficiently adequate to ensure that poultry products reaching the marketplace are as safe and wholesome as is technically feasible (Good Housekeeping Institute, 1983; Roper Organization, Inc., 19831. However, some of the recently adopted and proposed changes in the poultry inspection programs have been perceived by the public, consumer advocates, and inspection staff as compromising human health and safety (Community Nutrition Institute, 1977; Hughes, 1983~. The changes that produce or could produce substantial increases in line speed have drawn the most criticism. Also of concern are the health effects of low-level contamination of poultry by pesticides, drugs, and environmental contaminants--none of which can be found by organoleptic inspection. Meanwhile, the industry has questioned the necessity and efficiency of 100% postmortem inspection (i.e., the inspection of every bird) in groups of poultry that are almost uniformly in good health (NRC, 1984~. FSIS contends that none of the changes made to date have reduced the effectiveness of the poultry inspection program. Further major efficiencies will almost certainly require a move toward the inspection of only a sample of birds. Intense inspection of a sample combined with an industry shift from detection of problems to their prevention would have many advantages. However, FSIS may have difficulty persuading the general public (as well as its own inspection staff) that a sampling system based on a substantially more intense inspection of some sample of products could in fact lead to better identification of problem areas and hence improve public health protection. The Need for Risk Assessment In 1984, recognizing the need to evaluate new and proposed changes to meat and poultry inspection procedures in general, FSIS asked the Food and Nutrition Board (FNB) to examine the scientific basis of USDA's meat and poultry inspection program. The committee appointed to perform that task concluded that the new postmortem inspection procedures for poultry instituted between 1979 and 1983 ''are not likely to diminish protection of the public health," but noted that it could make no overall assessment of risks and benefits because it could find no comprehensive statement of criteria, no systematic accumulation of data, and no complete technical analys is of the hazards or benef its to human health in the traditional inspection program or as a consequence of the adoption of new techniques (NRC, 1985, pp . 7 - 8 ) . That committee considered whether to recommend the newly proposed cooperate ve industry- government inspection system for chickens, in which the USDA inspector's primary responsibility is to monitor inspection performed by plant personnel. It concluded, ''No such change

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27 should be recommended until a detailed risk analysis, based on sound scientific data, compares the present and proposed approaches and documents that efforts of FSIS to attain its major public health objective would not be harmed" (NRC, 1985, p. 91~. The committee also recommended that FSIS establish a risk-assessment program to help organize and evaluate its risk-management strategies. Through such a program, PSIS could establish limits on the concentrations of chemical residues that can be tolerated in poultry products, set priorities for controlling residues, and design programs to ensure compliance with established limits. - The report prepared by the committee pointed to two key elements that are missing from the present FSIS approach to inspection and risk management: comprehensive assessment of the kinds of public health hazards that face the U.S. public and objective criteria to determine whether solutions to identified problems are being appropriately and successfully pursued. The committee recommended that FSIS apply formal risk-assessment procedures to assist in the planning and evaluation of all phases of poultry inspection, especially in the assessment of public health consequences that might result from modification of the inspection process. In response to the committee's observations, the FSIS Administrator asked the FNB to undertake another study with two goals: analysis of the public health risks associated with broiler chickens at the time of slaughter and development of methods for comparing the effects on public health of different inspection goals and strategies. The findings of that study are described in this report. REFERENCES Anonymous. 1986a. Equipment for SIS. Natl. Provis. 194:5. Anonymous. 1986b. Streamlined Inspection System (SIS). Fed. Vet. 43:3-4. Berndt, D. L. 1985. Response to NAS Committee Questions. Slaughter Inspection Standards and Procedures Division, Meat and Poultry Inspection Technical Services, Food Safety and Inspection Service, U.S. Department of Agriculture, Washington, D.C. 14 pp. Blair, J. L. 1975. Elements and controls of meat hygiene. Pp. 16-32 in J. A. Libby, ed. Meat Hygiene, 4th ed. Lea & Febiger, Philadelphia. CFR (Code of Federal Regulations ~ . 1983 . Title 9, Animals and Animal Products; Section 381.66, Temperatures and chilling and freezing procedures. U.S. Government Printing Office, Washington, D.C.

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28 Community Nutrition Institute. 1977. Assessment of the Booz-Allen & Hamilton, Inc., Study and Recommendations on a Reorganization of the Meat and Poultry Inspection Program Community Nutrition Institute , Washington, D . C . ~ 35 pp .; FSIS (Food Safety and Inspection Service). 1984. New line speed inspection system for broilers and cornish hens O Proposed rule. Docket No. 82-023P. Fed. Regist. 49: 2473-2478 . FSIS (Food Safety and Inspection Service). 1986. Facility and equipment requirements for the Streamlined Inspection System for broilers and Corinth game hens. Proposed rule O Docket No. 85-036P. Fed. Regist. 51:3621-3624. Good Housekeeping Institute. 1983. Food Labeling Study. Consumer Research Department, Good Housekeeping Institute, New York. 38 pp. Hughes, K. 1983. Return to the Jungle: How the Reagan Administration is Imperiling the Nation's Meat and Poultry Inspection Program. Center for the Study of Responsive Law, Washington, D.C. 63 pp. Libby, J. A. 1975. History. Pp. 1-15 in J. A. Libby, ed. Meat Hygiene, 4th ed. Lea & Febiger, Philadelphia. Libby, J. A., and M. R. Humphreys. 1975. Post-mortem dispositions. Pp. 85-186 in J. A. Libby, ed. Meat Hygiene, 4th ed. Lea & Febiger, Philadelphia. NRC (National Research Council) 1984. Transcript of Public Meeting. Committee on the Scientific Basis for Meat and Poultry Inspection Programs. On file with the Food and Nutrition Board, Washington, D.C. 81 pp. NRC (National Research Council) 1985. Meat and Poultry Inspection: The Scientific Basis of the Nation' s Program. Report of the Committee on the Scientific Basis of the Nation's Meat and Poultry Inspection Program, Food and Nutrition Board. National Academy Press, Washington, D.C n 209 pp ~ Presidential Documents. 1981. Executive Order 12291 of February 17, 1981--Federal Regulation. Fed. Regist. 46:13193-13198. Roper Organization, Inc. 1983. Postal service most favored of federal departments . P . 2 in Roper Reports, Summary of 83 - 5 . Roper Organization, New York. IJSC (U. S . Code) 0 1983a. Title 21, Food and Drugs; Section 451, Congressional statement of findings. United States Code, 1982 ed. U.S. Government Printing Office, Washington, Dock

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29 USC (U. S . Code) . 1983b. Title 21, Food and Drugs; Section 455, Inspection in official establishments. United States Code, 1982 ed. U. S . Government Printing Office, Washington, D.C. USDA (U. S . Department of Agriculture) . 1974. MPI Directive 918.1, Poultry Carcass Inspection Program. MPI Bulletin 619, issued February 25, 1974. Meat and Poultry Inspection Program, Animal and Plant Health Inspection Service, U.S. Department of Agriculture 9 Washington, D. C . 2 pp . USDA (U.S. Department of Agriculture). 1983a. Meat and Poultry Inspection Manual, Combined Changes 83-1 through 83-12. Meat and Poultry Inspection, Food Safety and Inspection Service, U.S. Department of Agriculture, Washington, D.C. [37 pp.] USDA (U.S. Department of Agriculture). 1983b. Prevention--A new direction in reducing the risk of chemical residues in meat and poultry. Pp. 21-23 in Food Safety and Inspection Service Program Plan: Fiscal Year 1984. Food Safety and Inspection Service, U.S. Department of Agriculture, Washington, D.C. USDA (U.S. Department of Agriculture). 1983c. Protection and Productivity: The Strategy for Meat and Poultry Inspection in the 198O's. Food Safety and Inspection Service, U.S. Department of Agriculture, Washington, D.C. 40 pp. USDA (U.S. Department of Agriculture). 1984a. FSIS Facts: The National Residue Program. FSIS-18. Food Safety and Inspection Service, U.S. Department of Agriculture, Washington, D.C. 4 pp. USDA (U.S. Department of Agriculture). 1984b. A Review of the Slaughter Regulations under the Poultry Products Inspection Act. Regulations Office, Policy and Program Planning, Food Safety and Inspection Service, U.S. Department of Agriculture, Washington, D.C. 28 pp. USDA (U.S. Department of Agriculture). 1985. Statistical Summary: Federal Meat and Poultry Inspection for Fiscal Year 1984. FSIS-14. Food Safety and Inspection Service, U.SO Department of Agriculture, Washington, D.C. 39 pp. USDA (U.S. Department of Agriculture). 1986. Compound Evaluation and Analytical Capability: Annual Residue Plan. Science Program, Food Safety and Inspection Service, U.S. Department of Agriculture, Washington, D.C. 127 pp.