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CHAPTER 6 APPLICATION OF THE MODEL TO THE CURRENT FSIS INSPECTION SYSTEM . ~ ~ . In evaluating the current FSIS poultry inspection program, the committee identified those parts of poultry production, slaughtering, and processing that appear to present the greatest risk to public health, especially in terms of microbial and chemical contamination. Current FSIS inspection activities were then compared with those risks to determine whether the methods used are appropriate for detecting and preventing risk, to identify areas in which major risks seem to be inadequately addressed, and to determine where current or proposed inspection practices seem to provide little protection for public health O The committee's findings are discussed below according to the major component of the risk model to which they apply THE POULTRY PRODUCTION SUBMODEL l Breeding With help from the U.S. agricultural research system, the poultry industry has made substantial progress in improving management practices and the genetic quality of broilers. As a result, the incidence of economically important diseases has been sharply reduced in the broiler population over the last 40 years. disadvantages indirectly accompany the benefits derived from However. some stan~aru~zatron or the generic base and the development of mass production practices in the broiler industry. In particular, diseases in broiler houses can be economically disastrous because of the high-density holding of genetically homogeneous groups of animals that are uniformly susceptible to diseases (Crittenden, 1979; Penner et al. 9 19 74 ~ . Poultry producers tend to use prophylactic drugs to minimize the probability of economically ruinous disease outbreaks, thereby setting the stage for potential human health problems from drug residues and from resistant strains of bacteria (Harris et al., 1986; Holmberg et al., 1984; NRC, 1979, 1980~. The Food Safety and Inspection Service (FSIS) has no legal authority or responsibility to monitor the genetic stock or the breeding process, although other parsecs of the U. S . Department of 140
141 Agriculture (USDA) , notably the Cooperative State Research Service and the Agricultural Research Service, fund important poultry science programs. Because of the indirect connection between the genetic makeup of poultry stock and the public health hazards noted above, it would be useful for those responsible for product safety in FSIS to maintain closer communication with those involved in research on poultry genetics, e.g., poultry science departments at land grant colleges, the Agricultural Research Service, and the poultry industry. FSIS should also be in a position to work closely with poultry science laboratories as new research programs are considered, undertaken, and tested in the field. Hatching Infectious agents can contaminate poultry during hatching. Organisms such as MYcoplasma and Salmonella may infect chicks prior to hatching if infected breeders transmit them transovarially, thus providing a focus of infection for the flock in the grow- out house . Egg-shell contamination by Aspergillus, E. colt, and Salmonella can also contaminate the hatcher and conveyor belts used to transfer chicks from the hatcher through vaccination and sorting to crating for transfer to the grow-out house. Some forms of Salmonella have been associated with systemic disease in chicks less than 3 weeks old (Cruickshank et al., 1982), and avian leukosis viruses (ALV) have been observed in chicken embryos (Crittenden, 1979; Penner et al., 1974~. Although ALV has not been associated with diseases that can be transmitted to humans, the natural history of bird-to-bird transmission of this virus shows that the hatching stage of this submodel is a potentially susceptible critical control point with regard to human health. Grow- Out The possible introduction of microbial hazards, such as Salmonella, and chemical hazards, such as chlorinated hydrocarbon pesticides, are major concerns during the grow-out phase. A variety of infectious microorganisms known to be pathogenic in humans can grow, multiply, and spread undetected among the chickens in the grow-out house. Pesticides, drugs, and other chemicals introduced in low concentrations can become highly concentrated in the tissues of the birds. Sanitation Sanitation controls are important in all phases of poultry production (breeding, hatching, grow-out), since most pathogens of concern are exogenous to the broiler stock. Broilers are most often born healthy and substantially free of contamination. It is primarily in the grow-out environment that pathogens, residues, and diseases may be introduced. FSIS has no control over the level of sanitation at grow-out facilities, but because of the economic incentives of growing healthy birds, almost all major manufacturers (accounting for more than 90% of the young chickens produced in the United States) follow good sanitation practices.
142 From a health perspective, disease outbreaks are sometimes so disastrous that entire flocks are lost or must be destroyed. FSIS must ensure that condemned birds are indeed destroyed and do not reappear at the slaughter house for processing Feed Milling and Feed Protection Young chickens intended to be grown and slaughtered within 3 months after birth are fed highly enriched diets. During this period, three potential public health risks are presented: unintentional contamination of feed or water with natural toxins, drugs, or other chemicals; inadequate withdrawal from drugs intentionally added to feed; and microbial contamination of feed. Unintentional drug contamination of feed can occur during commercial feed production and milling, which are largely decentralized. The cleanliness of feed mills and the technology used in them can affect the health of young broilers. Unintentional mixing of feeds and raw materials intended for diverse purposes may occur because one plant may oversee the manufacture of many products. This environment provides the opportunity for cross-contamination of feed components. Drugs and vitamins are often added, and if residues are not adequately removed from the mill after a mix, substantial drug contamination of the following batch can occur. The feed constituents themselves can also be contaminated with pesticides or other environmental chemicals. It is recognized that feed mill contamination is a potential human health problem. Thus, all mills are theoretically regulated and inspected by the Food and Drug Administration (FDA). In practice, however, only a small percentage (e.g., 25-33~) of the feed mills in question are inspected each year because of constraints on FDA resources. FSIS relies entirely on FDA to monitor feed mill contamination. Because of the limited resources at both FDA and the FSIS National Residue Program CORPS, one can reasonably ask whether the level of protection is sufficient. Certain FDA-approved drugs (e.g., antibiotics and coccidiostats) are deliberately added to poultry feed during milling to prevent poultry diseases or to promote growth. Most of these drugs are not used to treat disease in humans, but each of them has designated withdrawal times, i. e ., the amount of time prior to slaughter during which the drug is not to be used to prevent unsafe res idues of the drugs from contaminating edible tissues. These withdrawal times are important, because drugs and residues can have potentially adverse effects on consumers (Settepani, 1984~. FDA, which has its own resource constraints, is responsible for ensuring that the presence of approved animal drugs is monitored by acceptable analytic methods and that there is adherence to speci fled
143 withdrawal times. USDA's Animal and Plant Health Inspection Service (APHIS) assumes some responsibility for working with FDA because of its responsibility to prevent animal disease. This is an area requiring collaboration between FSIS, APHIS, and FDA personnel, but progress is sometimes limited by legitimate disagreements on technical problems. For example, attempts to agree on uniform analytical methods used to detect drug contamination of feeds have been hampered by disagreements over which method is best. In addition, it has been difficult to agree on the amount of resources devoted to monitoring and testing. Poultry feed given to broiler flocks has been demonstrated to be a source of salmonellae that subsequently contaminate broiler carcasses (Williams, 1981~. Thus, FSIS should investigate further the possibility of providing Salmonella-free feed for broilers. FSIS authority over Salmonella contamination of broiler carcasses is presently restricted to critical control points during slaughtering and processing, but greater protection of public health might result if attention were given to the points at which Salmonella is introduced during production, beginning with the introduction of Salmonella into feed (see also Chapter 4~. Until reliably Salmonella-free feed ingredients can be ensured, the poultry industry should consider restricting its feed supply to pelleted material, which reduces the potential for Salmonella contamination (Shapcott, 1985~. When feed is processed at 180°F (82.22°C) or higher, levels of microbial contamination are effectively reduced. However, this process alone will not guarantee a Salmonella-free product (Blankenship et al. , 1985; Cover et al. , 1985) , . and efforts should continue to be made to reduce the level of contamination at each critical control point during the manufacture of feed and feed ingredients and in feeding processes and equipment within the production submodel. Natural Toxicants and Other Environmental Contaminants Contamination of groundwater supplies by environmental contaminants has generated concerns about chemical contamination of water used in poultry production and slaughter. For example, chlorinated hydrocarbon pesticides may be used in fields near grow-out houses, and safeguards must be (and are) taken to protect against the accidental contamination of poultry feed during grow-out. Air pollution is another problem in some settings, and care must be given to air-filtering systems, which are sometimes used by growers. In all these cases, the possibility of serious accidental contamination by environmental contaminants is minimized by the integrated structure of the poultry industry. This structure facilitates self-monitoring and communication of potential problems between subcomponents of the production phase. There is an increasingly strong capability along with a financial incentive to trace flocks back through the production system to determine the causes
144 of specific problems and to ensure that the production of unfit animals is rapidly terminated. To assist farmers in developing adequate production practices, the FSIS transferred $3 million to the USDA Cooperative Extension Service over a 3-year period from 1983 to 1985. In turn, this service has provided funds to state extension services for programs to teach farmers about the appropriate use of chemicals and drugs and to provide informati on about the overall production environment . Intuitively, this cooperative effort seems reasonable, but it would be useful to evaluate its effect on overall risk in poultry production. Important microbial and chemical risks occur during poultry production, but FSIS must rely extensively on economic incentives to growers and on the often uncoordinated efforts of other federal and state agencies For which food safety is not a primary objective. FSIS ' s lack of authority to control the front end of the production process (i.e., the raw materials used in production) increases the importance of FSIS inspection activities once young birds enter the slaughterhouses. Trans it Pout try are most often transported from grow-out houses to slaughtering facilities on trucks. During transport, susceptible or poorly protected birds are subjected to great stress, and deaths are not uncommon. This phase also provides a major opportunity for unscrupulous operators to reintroduce dead, diseased, or dying birds into the human food chain. Care must be taken to ensure that raw material destined for pet food, for example, is not reintroduced into food being produced for human consumption. None of this generally has much implication for human health, but it brings to light some issues to be considered in attempts to ensure that wholesome food is placed on the consumer's plate. FSIS employs several dozen compliance officers who visit production facilities throughout the country searching for such potential health- related factors as problems in transit. SLAUGHTERING SUBMODEL FSIS responsibilities for poultry inspection begin at the gate of the slaughterhouses. As the trucks roll in carrying the broilers in holding crates, federal authority passes to FSIS from a variety of other agencies (e.g., state agriculture departments, APHIS, EPA, and FDA). Sometimes the inspectors on site will know from experience what to expect from the animals supplied by a particular farm or grow-out house. Often they will have been stationed at the same plant for an extended period or they will themselves live nearby and thus will know something about both the grower and any recent environmental conditions or diseases in the area. Frequently, however, they will have neither formal information about disease incidence in the bird population nor a
145 systematic way of evaluating the health of the birds other than by visual inspection. The growers are concerned about the health of their flocks during grow-out and transit, but they have strong disincentives to provide any information that can be used against them at later stages. Similarly, plant personnel are not particularly forthcoming about problems. Moreover, no other state or federal agency is required to provide FSIS with such information. Accordingly, FSIS inspectors pursue this responsibility essentially without assistance. Antemor~cem Inspection In this highly informal, unsystematic environment, the inspection staff begins its first task, antemortem inspection. Birds may be examined while they are still in cages on trucks so that a subjective determination can be made about the overall condition of the flock. As the thousands of birds are pulled out and placed on a line, the inspector makes a rough visual determination of the prevalence of disease in the flock. Years ago, when birds were slaughtered by the dozens or hundreds, this procedure was more effective than it is now when as many as 60,000-70,000 birds (depending on line speed) pass through antemortem inspection daily. From an aesthetic and public health perspective, this inspection appears to detect little. Perhaps one plus is that the resources required to conduct antemortem inspection are very small. Approval of Slaughtering Facilities Before a slaughtering facility can begin operation, blueprints for the plant must be approved by PSIS (CFR, 1986a). This practice was adopted in the 19 50s, apparently to ensure that proper water suppl ies were available to the plant (e . g., that sewage and freshwater supplies would not be mixed) and that materials in the plant would not be good breeding grounds for microbial organisms. The necessity for approval of blueprints should be continually reevaluated, along with other steps in the overall inspection strategy, as FSIS constantly shifts resources to match them with evolving hazards. Current rules require that an inspector examine slaughterhouses every morning before operations begin (USDA, 1983a). During this procedure, the inspector must ensure that all work surfaces are clean to the naked eye, that temperatures are within required ranges (e. g. , in scalders and chillers), that condensation in cooled areas is minimal, that no illegal chemicals are on the premises, and that lines are operating properly and are well lighted. This inspection can be a helpful quality assurance technique if properly conducted. Although many potential health problems are not visible to the naked eye, the requirements for visible cleanliness probably helps to ensure adequate public health protection.
146 Stun Scal d. and Pluck FS IS participates little in the development of technology for this part of the process, although new equipment and techniques could have an impact on carcass contamination. Evisceration and Postmortem Inspection FSIS plays a major role in the evisceration and postmortem inspection of poultry. It is an important responsibility, since these procedures provide almost a single line of defense against the intrusion of pathogens into the food supply. Following is a list of the key variables in the evisceration and postmortem inspection process: Quality of the mechanical devices and procedures used in evisceration. Placement of the viscera next to the bird of origin to facilitate matching of the two. Inspection time (line speed). Quality of the postmortem inspection procedure. Quality assurance techniques. Quality of the Mechanical Devices and Procedures Used in Evisceration. The greatest risk of microbial contamination is presented when the gastrointestinal tract is separated from the rest of the carcass. Ideally, this process should be designed to decrease or eliminate fecal contamination and cross-cont~mination. Current practices do not achieve this goal, however, despite the introduction of automatic evisceration machines in the mid- to late 1970s that facilitated the inspection of entrails and observation of the open body cavity. The new equipment often malfunctions, resulting in poor placement of the carcass, and the gastrointestinal tracts are frequently broken so that feces and other intestinal contents contaminate the surface of the birds with a variety of bacteria, including salmonellae. Decreased line speeds might eliminate many of these shortcomings, but such speeds would have to be substantially slower than those used in traditional inspection . Placement of the Intestinal Tract. Carcass evisceration facilitates the inspection process by enabling the inspectors to obtain a clear view of the viscera of each bird while enabling them to associate the viscera (including heart, liver, and spleen) with the carcass to which they belong and thus to prevent contamination and cross-contamination between diseased and healthy carcasses or viscera. The current poultry processing system and the inspection system seem to accomplish this well.
147 Inspection Time (Line Speed). Once the carcass has been eviscerated, and the carcass and viscera have either been separated (but tagged for identifications or hung together for easy viewing, the bird approaches the inspectors. Depending on the line speeds in the Streamlined Inspection System (SIS) and the New Line speed (NELS) system, the inspector has between 1 and 1.5 seconds to perform the entire postmortem inspection, and that time is further decreased in the Third-Generation System, in which one inspector would be responsible for 1~(~) A; sac nor m; newts rim . It appears that little attempt has been made to evaluate inspection methods and line speeds with regard to fecal contamination, microbiological quality, and public health impact. the past decade FSIS has spent a substantial amount of time investigating the effects of accelerated line speed on inspection and trying to devise work measurement standards that would enable one or more inspectors to conduct postmortem inspection more rapidly. If these rapid line speeds can be shown to result in greater fecal contamination, a case might be made for slowing the process, even though substantial contamination may also occur in other ways (such as in the chiller) and despite the fact that we cannot relate the exact load of bacteria on birds at this stage to the load present on the consumer's dinner plate. In the 1967 study, chickens: in 1979. Over Numerous microbiological surveys of consumer-ready poultry have demonstrated that many carcasses are heavily contaminated with fecal flora, even when the carcasses are clean to the naked eye, but this contamination may not be associated with line speed. Surveys of IS federally inspected plants conducted in 1967 and 1979--before line speeds were accelerated--determined the incidence of salmonellae in processed, ready-to-market, whole young chickens (Green et al., 1982~. salmonellae were isolated from 28. 6% (mean) of the 36.9% of similarly analyzed chicken samples were positive. A more recent 2-year survey of the same 15 plants conducted from 1982 to 1984- - after poultry line speeds were increased--revealed that 35% were positive for salmonellae (R. W. Johnston, FSIS, personal communication, 1986~. Before it can be stated with assurance that line speed is irrelevant from a public health perspective, more studies on this subject need to be conducted. Current evidence seems to indicate, however, that the mix of changing conditions in production and slaughter--including accelerated line speeds--results in a product that is not contaminated more often than it was before line speeds were increased. Quality of the Postmortem Inspection Procedure. Bird-by-bird postmortem Inspection as aescrtneo In unaprers ~ and ~ is required for all poultry slaughtered in an FSIS-inspected establishment. To ensure that the postmortem inspection proceeds effectively, FSIS requires plants to provide some form of control (e.g., a switch or button) so that the inspectors can stop, start, or slow the lines on which the birds are hung. Adequate lighting of uniform intensity at all work levels is also required. Double lines must be separated by dividers to
148 prevent confusion and to ensure that each carcass receives the inspector' s attention, and as ~ ndicated above, visceral organs must be kept with the carcass from which they have been removed. Hand-washing facilities must be adequate and properly located at both operating and inspection positions (Libby, 1975)0 Trained company employees are ass igned to each inspector to perform such functions as picking feathers, trimming bruises, moving condemned birds from the lines into condemned cans, placing suspect birds on racks for more detailed inspection, marking the condemnation record sheets, and generally assisting the inspector in tasks related to inspection procedures O The objectives of each of the postmortem Inspection techniques described in Chapter 2 are to ensure that no vis ible les ions or systemic infections reach the consumer in either whole birds or parts of birds e The inspection procedures do not have as their objectives the diagnoses of any specific disease state that could be transmitted from broilers to humans. Under any form of manual inspection, i ncluding traditional, modified traditional, hands on/hands off, new line speed, or streamlined inspection system, there are Apple opportunities for microb ial contamination to spread from carcas s to carcass. Moreover, there is no provision for making a systematic examination to determine the presence of chemical residues, including drugs and environmental contaminants. Thus, the weight of the evidence suggests that the current program is not effectively protecting the public health. The committee believes that whatever benefits the current system may provide, the alternative strategies discussed in Chapter 7, including detailed inspection of a sample of birds, may provide greater public health protection. Accordingly, FSIS should strongl y consider immediate changes in its current i nspecti on practices . If substantial public resources are to continue to be dedicated to bird-by-bird poultry inspection as it is currently conducted even under the most streamlined circumstances, it is important for FSIS to demonstrate the associated public health benefits, if any, as soon as possible. If aesthetic improvements are the only benefits derived from the present system, the committee believes there is no justification for continuing the government's intense involvement. Quality Assurance Techniques. In the current inspection system, condemned whole carcasses are discarded and are thus highly unlikely to reenter the food chain. However, since some birds that should be condemned are passed, and since the link between carcasses and the viscera is lost once the parts have passed the postmortem inspection station, there is substantial likelihood that contaminated parts are brought together with clean parts on a regular basis. After evaluating each part of the evisceration and postmortem procedure, the committee came to the following conclus ions:
149 · FSIS should continue to apply substantial resources to this part of the production system, especially because of the absence of safeguards in poultry production, but these resources should be better justified and reallocated in ways more likely to protect the public health. · The public health impact of resources applied to this part of the production system need to be evaluated. · FSIS should conduct further studies to determine the impact of inspection line speed on public health. Chemical Traceback The U.S. poultry industry is highly integrated, with strong relationships extending from producer to wholesaler. Accordingly, unlike most of the red meat industry, there is a substantial capability to trace known episodes of contamination back through the system to their sources. This traceback capability, along with producer education, probably decreases the risk from chemical contamination in the poultry supply. So do the economic and public relations repercussions of major recalls; several widely publicized incidents during the late 1970s also impressed upon poultry producers the unpleasant consequences of serious lapses (USDA, 1980~. National Residue Program Monitoring. The number of samples tested in the National Residue Program (NRP) is designed to ensure, at a 95% confidence level, that a 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 or animals slaughtered each year (USDA, 1983b, c, 1984, 1985a) . Since more than 4 billion broilers are slaughtered annually, as many as 40 million broilers could be contaminated without detection by the current inspection system. Thus, the chance of any animal being sampled in the United States is minuscule. This is not adequate for effective public health protection. Because hazards are not uniformly distributed over populations of poultry or consumers, this overall contamination rate of 1% could represent a substantial public health hazard to normal as well as highly susceptible persons. Thus, FSIS should consider revising its sampling program. Following are some of the technical problems and opportunities that will need to be weighed: . Ensuring randomness, so that neither inspectors nor plant personnel can forecast which items are to be sampled and no element of personal discretion affects sample selection. This may be an especially important consideration in sampling birds on the line. Due consideration of alternatives to simple random sampling to meet program objectives by using the smallest possible samples and to minimize complexity in interpretation. For example, there will be good reasons to sample at different rates under
150 . . different circumstances. Stratified random sampling may have many advantages. Selecting the percentage of birds to be sampled and changing those percentages as new data indicate local or widespread short- or long-term variations in the likelihood of finding significant risks to health. For examples it may be desirable to increase the percentage of birds sampled even up to 100% (the present approach to organoleptic inspection) when observations indicate that a particular flock presents health risks not adequately controlled by plant personnel in their own inspections. This might occur when many of the birds are septicemia, when evisceration equipment is out of adjustment, or when a sampled bird dies from causes other than slaughter. Calculating variances correctly for use with quantitative estimates based on data from complex samples. The committee believes that a two-stage sampling scheme, with a third stage for more detailed examination, may be best for the inspection of whole slaughtered birds. This system is described in Chapter 7. Surveillance Testing. FSIS continues to develop new methods to enable it to test for residues more rapidly, perhaps while carcasses are still in the plant. However, no new tests for environmental contaminants of poultry have been brought on lines The committee concluded that sample size in the FSIS surveillance program is not adequate, and that its tie with the monitoring program ensures that it cannot be truly representative of the residue problem in the broiler population. Exploratory Testing. The committee reviewed the current exploratory testing program and found that existing methods of selecting samples and determining sampling frequency are inadequate. Furthermore, it believes that FSIS does not rigorously follow the eight steps described in Chapter 5 that are needed for an effective residue control program. In particular, the committee concluded that FSIS should play a larger role in determining the degree of consumer exposure to various agents that might be found in poultry and that the current FSIS program is not adequate to deal with occasional but potentially serious contamination. Operations. In the NRP, an inspector in charge, usually a veterinarian, receives a computer print-out specifying the number of carcasses to be sampled and a sampling plan for collecting those carcasses. Each plant makes provisions for collecting, labeling, freezing, and transporting the requested samples to one of FSIS's national laboratories, where they wait in a queue for analysis. As many as 10 days may elapse before results are reported. The effective communication of results requires vigilance from a
151 supervisor and good mechanisms for communicating between the field and headquarters in Washington, D.C. Once a report arrives at headquarters, information must be relayed across program lines from the Deputy Administrator for Science to field operations. Any problems must be further communicated to the employees and FSIS compliance staff at the plant. This system is both cumbersome and slow when it works as planned, and there are many opportunities for further delays and complete break- downs. FSIS established mechanisms for minimizing delays after a serious problem occurred in Montana in 1979 (USDA, 1980), but even under good circumstances, a month can pass before contamination found in the system is brought to the attention of administrative officials and action can be taken. As stated before in the discussion on monitoring, the odds of catching even continuous but not nationwide contamination, should it exist, are very low. Many years could go by before even one bird from a given plant is sampled and the process of analysis and notification can begin. Several reforms could speed this process. In particular, the time required to store and transport samples to FSIS laboratories could be shortened, and new resources could be devoted to speeding up laboratory testing and the communication of results. A relatively small infusion of laboratory and testing resources could improve methodology, substantially shorten the queue, speed the development of methodology, and enhance the strength of the program. Washing and Chilling to Inhibit Microbial Growth Questions have been raised about the safety of communal ice baths because of the potential for microbial contamination to spread among the thousands of carcasses immersed in the same tank. In the absence of adequate data, it is not clear to the committee that so - called dry chill procedures are inherently better In reducing overall bacterial contamination. The committee urges FSIS to collect more data to support a thorough comparison of chill procedures. Following chilling, the birds are reinspected to check for the presence of defects, according to recently adopted finished product standards. Birds not meeting these standards will be classified as adulterated (Anonymous, 19861. Less than 1% of birds inspected are condemned, according to current criteria (see Table 2-2 in Chapter 2) (USDA, 1985b). A large portion of the birds carry undetected enteric bacteria that are harmful to humans. Some of these bacteria may have been introduced by the process of poultry inspection itself. A smaller number of birds contain drug or pesticide residues that exceed prescribed limits. Such problems can persist for some time in the current inspection system before action is taken, and postmortem inspection itself may have little direct effect on them.
152 THE PACKING AND PROCESSING SUBMODEL Most young chickens are sent directly to market, but an increasingly larger percentage of them are being processed further in response to consumer demand for more ready-to-eat food and food that requires less preparation time. Some of the risks to human health introduced during this processing are described in Chapter 40 After reviewing the data, the committee concluded that the risks presented during packing and processing are managed quite adequately O Further processing includes cutting up whole chickens and packaging the pieces. The pieces are often obtained from birds that when whole are not aesthetically acceptable. At this stage, microbial contamination may be introduced by cutting boards and saws that are not adequately cleaned. Both regulation and technology seem to be adequate to deal with the major potential health hazards that arise when cooking is part of further processing. The consequences of improper cooking could be disastrous for manufacturers, so they will go to great lengths to avoid errors. Once optimal cooking conditions have been determined, it would not be difficult to ensure that the cooking time and the temperature are adequate through monitoring. Hazards presented by food additives during the packing and preparation of poultry are described in Chapter 3 (pp. 41-42~. FDA is responsible for setting standards for food additives, and FSIS evaluates the specific use of each additive in poultry products. Although there may be some marginal benefits to this reevaluation by FSIS, it is difficult to justify duplication of a process to which the FDA devotes major scientific and financial resources. Evaluation of potential risks from packing material is complex; it includes the identification, measurement, and toxicological evaluation of compounds obtained from the material under various storage conditions. Although there is no information directly linking the small amounts of these compounds that may be present in foods to adverse effects on human health, FDA approval is required for all materials used to package poultry in the United States (Kare] and Heidelbaugh, 1975; Sacharow, 1979) processing industry. This chance . Quality assurance has progressed rapidly in the entire poultry ¢_ __ O _ _, _ _ A ~ is not altruistic; more and more managers understand the necessity to keep their production systems under control for financial and regulatory reasons. FSIS has historically provided daily inspection of processing as it is required to do for slaughtering. Inspectors look for a variety of regulatory violations in an attempt to police the industry. In the
1S3 past, some plant managers have looked upon the inspection service as a substitute for having their own quality assurance program. Since 1980, FSIS has encouraged the development of voluntary quality control systems in plants. These systems are designed to emphasize good manufacturing and control practices and to provide both the manufacturer and the FSIS inspection staff with a more systematic look at the production process. The NRC report on meat and poultry inspection (ARC, 1985) described some successes and shortcomings of this system. DISTRIBUTION AND PREPARATION SUBMODEL Transport to Retailer Once a product leaves the plant in either fresh or processed form, the federal government has no more control over it. In extreme circumstances, FSIS can use plant records to locate shipments in warehouses or supermarkets before the product reaches the consumer. FSIS has the power to impound the product, pending the outcome of an administrative or judicial process. The time it takes for fresh products to be transported from the plant to the supermarket is, on average, only several days and can be as short as 1 day. During this period the product is once more at risk but is not subject to regulation by FSIS or any other federal agency. Handling in the Retail System At retail, many poultry products bear a label identifying the manufacturer. Accordingly, consumers do not regard such products as a general commodity as they do red meat, but, rather, as a product of the specified brand-name producer. This labeling provides manufacturers with an incentive to make high quality products available to consumers in return for a premium price. In addition, large poultry chains, wholesalers, and retail store managers have an economic incentive to ensure the adequacy of environmental conditions inside the retail s tore and to prevent spoilage or contamination beyond that already on the product when it enters the store. The Multiple Roles of Labeling Every manufacturer must label each product to show its ingredients. Nutritional labeling is optional, but if done, must conform to specific guidelines (CFR, 1986b). Labels may also suggest proper modes of preparation and provide recipes. Such information is provided at the discretion of the manufacturer and is not subject to FSIS approval unless it impinges on other regulated issues, e.g., the rank order of ingredients, net weight, or the size of type specified for some required information.
154 There are no systematic efforts to educate consumers about the possible dangers of mishandling or improperly cooking poultry products. FSIS offers some educational information about food safety through a variety of public affairs programs, including school poster contests, public service spots on radio and television, and consumer hot-lines. These programs should be emphasized and broadened, since the major role of improper food handling in disease outbreaks has been well documented (Bryan, 1978, 1980) . Therefore, the probability is high that morbidity rates can be controlled effectively through consumer education and action Accordingly, any rational risk-management strategy to combat enteric diseases derived from poultry must include a substantially stronger informational component than presently exists. At minimum the committee suggests that simple labels be attached to each ready-to-cook bird to remind consumers about the preparation procedures that are necessary to avoid illness. Such labeling need not encourage consumers to avoid the product. Rather, a simple tag emphasizing the need to wash all implements, cool the product thoroughly, and chill leftovers as soon possible after serving could go a long way toward adequate consumer protection. FSIS should use its existing authority or seek additional authority, if necessary, to implement such a system if it is unable to persuade manufacturers to label their products voluntarily. Such a labeling system should not be regarded as a substitute for other attempts by FSIS and industry to reduce the overall load of bacteria entering consumer channels. Food Preparation Almost all cases of food poisoning resulting from microbial contamination of poultry can be prevented by proper preparation of the food. But this fact should not mitigate the responsibilities to protect public health delegated by the Congress to the Secretary of Agriculture. The committee endorses substantial efforts to improve food safety during food preparation, but does not believe that consumers can or should bear the sole responsibility for the microbial safety of the poultry they consume. FSIS recognizes its responsibility to facilitate consumer understanding of proper food preparation. The committee did not review the agency's efforts to meet this responsibility, but it nonetheless urges USDA to obtain profess tonal advice about the direction and purpose of its educational programs. Education is not a form of public relations, nor should it be regarded as a substitute for other actions. A successful program must almost certainly be multitargeted, reinforced by the mass media on a continuing basis, and formally evaluated periodically to be sure it is having the intended effects.
155 OVERALL EVALUATION In the current FSIS inspection programs, considerable resources are devoted to some of the critical control points in the production system, but these activities have not been designed with an eye toward their evaluation and hence are not demonstrably effective. It also shows that because of the very nature of the poultry industry, it is less vulnerable to some risks than to others and that several control points are theoretically controlled by federal agencies other than those responsible for ensuring the safety of poultry products. In sum, resources are not always allocated to the right points and the resources that are properly directed are not achieving measured results. Major changes are required in the poultry inspection system if public health is to be protected and if the investment of resources is to have maximum effect. REFERENCES Anonymous. 1986. Streamline Inspection System (SIS). Fed. Vet. 43:3-4. Blankenship , L. C ., D. A. Shackelford, N. A. Cox, D. Burdick, J. S. Bailey, and J. E. Thomson. 1985. Survival of salmonellae as a function of poultry feed processing conditions. Pp. 211-220 in G. H. Snoyenbos, ed. Proceedings of the International Symposium on Salmonella held in New Orleans, Louisiana, July 19-20, 1984. American Association of Avian Pathologists, Kennett Square, Pa. Bryan, F. L. 1978. Factors that contribute to outbreaks of foodborne disease. J. Food Protect. 41:816-827. Bryan, F. L. 1980. Foodborne diseases in the United States associated with meat and poultry. J. Food Protect. 43:140-150. CFR (Code of Federal Regulations). 1986a. Title 9, Animals and Animal Products; Section 381.19, Application for inspection; required facilities. U.S. Government Printing Office, Washington, D.C. CFR (Code of Federal Regulations). 1986b. Title 21, Food and Drugs; Section 101.9, Nutrition labeling of food. U.S. Government Printing Office, Washington, D.C. Cover, M. S., J. T. Gary, Jr., and S. F. Binder. 1985. Reduction of standard plate counts, total coliform counts and Salmonella by pelletizing animal feeds. Pp. 221-231 in G. H. Snoyenbos, ed. Proceedings of the International Symposium on Salmonella held in New Orleans, Louisiana, July 19-20, 1984. American Association of Avian Pathologists, Kennett Square, Pa.
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