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2 Introduction and Historical Review of Meat Inspection Abstract Throughout history, meat inspection legislation, regulations, and procedures have been altered to keep pace with changing methods of beef production, slaughter, processing, and consumption. Today, rapidly changing technologies and increasing public expectations dictate a major reevaluation of inspection systems and philosophies. The Federal Meat Inspection Act of 1906 (P.L. 59-242) and the Wholesome Meat Act of 1967 (P.L. 90-201) were designed and implemented to provide the public with a safe, wholesome meat supply. Today's consumer relies on the Food Safety and Inspection Service (FSIS) inspectors to ensure this. No raw food product is totally sterile. Furthermore, contamination and recontamination may occur. Therefore, consumers must be aware of and implement proper handling, storage, and preparation practices for meat. Beef production and processing are highly competitive, rapidly changing industries. Today, most finished beef cattle production is concentrated in feedlots in the midwestern and southwestern regions of the United States, where more than 15 million steers and heifers are slaughtered annually (FSIS, 1990b). In some plants, more than 400 cattle are processed each hour. These numbers and speeds present challenges to those responsible for the inspection of all cattle and assurance of a safe and wholesome edible product for the consumer. Over the years, the U.S. Department of Agriculture (USDA) has made adjustments, changes, and modifications in an effort to keep abreast of the dynamic livestock industry. As the FSIS moves into the twenty-first century, it must make radical changes in its system and its ability to respond to the food safety needs of 250 million Americans. Historic Food Safety Concerns and Early Meat Inspection Legislation The public has always been concerned about the cleanliness, safety, and wholesomeness of its food supply. In early agrarian societies, people personally observed food from harvest to consumption. Today, consumers rely on unseen third parties to scrutinize the safety and wholesomeness of perishable foods and to protect them against natural and man-made hazards that can enter the food chain. Since antiquity, people have associated "unclean" meat with disease and have placed religious or government restrictions on slaughter, processing, distribution, and consumption of meat products. Religious restrictions against eating certain meat products originated in biblical times and still exist today. In ancient times, hogs probably were infected with the trichinosis organism, an intramuscular parasite, and 8

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people who consumed inadequately cooked pork became ill. Religious prohibition on pork consumption probably prevented serious public health problems long before the actual causes of trichinosis and other diseases were known. Today, rabbis and their representatives still determine if kosher meat meets ritualistic requirements. Laws enacted in Italy in the thirteenth and fourteenth centuries to correct unsanitary and fraudulent practices required butchers to renew their licenses annually, prohibited misrepresentations, substitutions, and unsanitary practices, and provided for inspections. And so the science of meat hygiene was born. The health of slaughter animals has long been associated with meat safety. The first meat inspection law in North America was enacted in New France (Canada) in 1706 (Brandly, et al., 1966~. It required butchers to notify authorities when animals were to be slaughtered so that meat could be inspected. Farmers were also required to certify that animals destined for slaughter had not been sick, down, or poisoned. At that time, the close relationship between butchers and consumers helped prevent grossly unsanitary butchering practices, because buyers could voice complaints directly. In the ISSOs, the quality of dressed beef, salted pork, and bacon was important to export markets. Rumors in foreign countries suggested that diseases in U.S. livestock rendered meat unfit for food. A bill passed on August 30, IS90 (stat. 2594, 5Ist Congress) as a result of these pressures provided for final product inspection before export upon request of a buyer, seller, or exporter. A meat inspection act passed on March 3, IS91 (26 stat. 1089) and a meat inspection amendment of March 2, IS95 (28 stat. 727, 731) strengthened meat inspection laws but did not provide for a national meat inspection system. In the early 19OOs, when Theodore Roosevelt was president, there was public outcry over unsanitary conditions and inadequate inspection. This public indignation was increased by Upton Sinclair's novel The Jungle (Sinclair, 1906), in which he described the horrendous working conditions and poor sanitation in Chicago slaughterhouses. This led to the enactment on June 30, 1906 of the comprehensive Meat Inspection Act of 1906 (P.~. 59-242), which strengthened requirements for sanitary conditions in packing houses and required inspection of meat for interstate commerce. Developments After the Meat Inspection Act of 1906 Since the Meat Inspection Act of 1906, there have been periodic changes in meat inspection regulations. The early legislation included, as it does now, inspection before (antemortem), during, and after (postmortem) slaughter; inspection during all processing steps; approval of labels for processed meat products; and strong controls over the sanitation, facilities, and equipment used in meat packing plants operating under federal inspection. Following enactment of the 1906 Meat Inspection Act, USDA provided 9

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inspection that helped control some zoonotic diseases, such as tuberculosis and cysticercosis, the lesions of which can be detected visually. Traditional meat inspection is based on organoleptic examinations in which inspectors make professional judgments based on what they see, feel, and smell. These procedures have provided reasonably acceptable products to consumers since 1906, even though the vast majority of foodborne diseases occurring today are caused by microorganisms that cannot be detected visually. Dr. Robert K. Somers, a former Deputy Administrator of USDA's Meat Inspection program, reviewed the changes that occurred from 1906 to 1966 (Somers, 1966~. Other historic accounts of meat inspection appeared in a previous Food and Nutrition Board report (NRC, 19SSc) and other sources (Brandly et al., 1966~. Implementation of the National Humane Slaughter Act of August 27, 1958 (P.~. 85- 765, SSth Congress) improved the way animals were rendered insensible at slaughter. Frequent changes have been made in the "regulations governing the meat inspection of the USDA" (Somers, 1966), which cover the entire gamut of facilities, sanitation, antemortem inspection, postmortem inspection, labeling, reinspection and preparation, transportation, imported products, standards of identity, and relevant details. Some of these changes were the result of legislation in such Acts as the Horse Meat Act of June 24, 1919 (41 Stat. 241, 66th Congress); Imported Meat Act of June 17, 1930 (em. 361, 7Ist Congress); Agricultural Marketing Act of August 14, 1955 (P.L`. 272, 84th Congress); and Wholesome Meat Act of December 15, 1967 (P.~. 90-201, 90th Congress). Other changes were instituted by directives from the Secretary of Agriculture, or the Administrator responsible for meat inspection, as new knowledge and research dictated greater protection of the consumer. Meat inspection was first administered by the Bureau of Animal Industry, which later became part of the USDA's Agricultural Research Service (ARS). Later, it was administered by three divisions in USDA's Consumer and Marketing Service (CMS), Livestock Slaughter Inspection Division, and Processed Meat Inspection and Technical Services Division. These changes were made to keep pace with the rapidly changing industry and to strengthen protection to consumers. With continued industrial development and improved transportation, the meat industry became national, the personal touch was lost, and consumers could no longer influence the butcher/packer regarding sanitation, product wholesomeness, and freedom from adulteration. Up to World War Il. the meat packing industry was centralized in cities, and livestock were shipped for long distances. When feedIots developed, slaughter plants left cities and moved to areas where finished cattle were concentrated. By the 1960s, it was apparent that the 1906 act did not provide adequate consumer protection because some conditions were not covered in the law and because all animals slaughtered for intrastate commerce were not adequately inspected. Inspection was a state responsibility, but because state funds for inspection were limited, extensive abuses occurred. The 1906 law also permitted interstate shipment of 10

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products from whole carcasses slaughtered for intrastate commerce and the import of uninspected meat products, and did not control rendering plants. The Wholesome Meat Act of 1967 (P.~. 90-201) gave the USDA authority to regulate transporters, renderers, cold storage warehouses, and anima1-food manufacturers. Requirements on imported meat became more stringent, and inspection of all animals prior to slaughter (antemortem inspection) became mandatory. The meat industry has grown, and the jurisdiction of federal meat inspection has increased. This growth has presented challenges requiring greater sophistication and efficiency of USDA monitoring of this vast industry. Reorganization of this arm of the USDA under the title of the Food Safety and Inspection Service (FSTS) evolved to better address the safety and wholesomeness of all food products, especially those of animal origin, which are highly perishable. In accomplishing its mission, FSTS today employs a field force of approximately 8,000 people (1,500 veterinarians and 6,500 food inspectors) and spends about $400 million annually. Modern beef production involves the finishing of steers and heifers in feedIots, which supply more than 15 million cattle per year to large U.S. slaughter plants. Today, large meat plants slaughter from 200 to 400 cattle per hour (3,000 to 5,000 per plant per day). Approximately 10% of U.S. cattle slaughtering plants handle 90% of commercial cattle (FSTS, 199Ob), and 58.1% of U.S. cattle slaughtering occurs in four states: Kansas (18.0%), Texas (17.0%), Nebraska (16.7%), and Colorado (6.4%~. The concentrated industry and speed of processing present major challenges to the nation's meat inspection system. The high concentration of cattle in feedlots provides opportunity for spread of microorganisms such as Salmonella and Campylobacter that cause diseases. On the other hand, feedIot cattle are more uniform in size and age and less likely to be diseased, down, dying, or loaded with drugs than are cull daily cattle, mixed groups of slaughter cattle, or veal calves. This uniformity, large numbers, high speeds of slaughter (exceeding 400 carcasses per hour in some modern facilities), and low levels of organoleptically detectable defects in large fed-cattIe slaughter operations make them candidates for innovative inspection techniques. USDA has attempted to alter traditional meat inspection methods to make use of modern technology to better monitor levels of microorganisms and residues of therapeutic drugs, agricultural chemicals, and environmental pollutants that cannot be detected or~anolentical~v. However, today's inspection is still essentially organoleptic. The sheer volume of carcasses needing inspection requires ever-increasing numbers of trained and physically able inspectors; however, resource limitations have prevented the expansion of the inspection workforce. A current strategy is to give more quality control responsibility to management of slaughter facilities, as was recommended in previous Food and Nutrition Board reports (NRC 1985b7 1987a). This strategy was based on the premise that the wholesomeness of the final product is the joint responsibility of industry (management) and the FSIS. This concept as applied to beef is called Streamlined Inspection System for Cattle (SIS-C). ~. , 11

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Throughout the twentieth century, advances in microbiology and toxicology led to the identification and description of specific causes of many foodborne diseases. Scientists developed new tests and epidemiologic techniques for investigating foo`dborne disease outbreaks. Toxicological tests have become increasingly sensitive, permitting detection of infinitesimal amounts of natural or man-made substances. However, these technologies are usually applied to disease investigations only when a potential agent is suspected. It is not economically or logistically possible to monitor all food products for every possible harmful agent, but random testing revealing traces of potentially harmful materials has caused public alarm. The hype of the biotechnologic revolution and the advent of convenience packaging, preparation, and serving methods have helped the public forget age-old precautions. Thorough cooking is still necessary to reduce microbial loads, and strict hygiene is necessary to prevent recontamination. Current generations need to know that care is needed in the kitchen as well as the slaughterhouse. Laboratories have been established across the nation to provide supplemental scientific analysis of meat and meat products and for approval of additives incorporated into meat products. In 1955, 29,000 samples were tested by USDA laboratories; in 1965, more than 174,000 samples were tested; and in 1989, 564,000 analyses were conducted in the various species of animals slaughtered under U.S. federal inspections as shown in Table 2-~. Table 2-l Analyses Performed by FSTS in 1989 Type of Analysis Number of Analyses Performed on: All Speciesa Steers and Heifersb Food chemistry62,435 Food microbiology36,908 Chemical residuesIS5,1633,022 Antibiotic residues255,851844 Pathology11,017 Serology1,630 Food additives10,907 Radiation139 TOTAL564,0503,866 aSource: FSIS, 1990b. bUnpublished data from FSIS. 12

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These data demonstrate the contemporary challenges faced by FSIS. FSIS has also had to address the European Economic Community (EEC) hormone ban and the [zstena and Salmonella scares (FSIS, 1990b). It has also responded to residue episodes by intensifying its surveillance of heptachIor, aflatoxin, and sulfamethazine since 1989 (FSIS, l990b). These activities testify to the changing face of FSIS as it progresses from an inspection agency to a public health agency. In a brochure entitled Inspection Honzons, Food Safer and 'zspection Service Strategy for the 199Os (FSIS, 1990a), FSIS addresses its future plans to provide the U.S. consumer with a safe meat supply. Emergence of HACCP as a Mode! Inspection System As advancing microbiologic, toxicologic, and epidemiologic technology indicated the enormity and complexity of the food safety issue, segments of the food industry and of the regulatory and scientific communities embraced an apparently exemplary mode] for controlling microbiologic contamination of foods. The hazard analysis critical control point (HACCP) concept had been evolving through the 1970s and l980s. It provided new vocabulary and complicated standards to which existing and proposed inspection systems could be compared. The HACCP system consists of (~) an assessment of hazards associated with growing, harvesting, processing/manufacturing, distribution/marketing, preparation and/or use of a given raw material or food product; (2) determination of critical control points required to control any identified hazardous); and (3) establishment of procedures to monitor critical control points. Basically, the HACCP system provides a more specific and central approach to the control of microbiological hazards than that achievable by traditional inspection and quality control procedures (WHO, 1980~. "The HACCP system for meat consists of an assessment of hazards associated with such operations, the determination of critical control points necessary to prevent or control the identified hazards, and the establishment of procedures to monitor (check or verify) the critical control points" (NRC, l985b). In order to minimize microbial contamination of beef using HACCP concepts, HACCP systems must be designed uniquely for the various types of cattle production systems and slaughter operations and customized for every individual processing plant and product. This complex approach has broad applications to all points in the food chain from production through consumption. It has been expanded beyond microbial contamination to include potential chemical hazards (FSIS, 1989a). Critics fear FSTS will extend it beyond contamination considerations into regulation of labeling, economic adulteration, and other nonsafety issues. FSIS has been urged to identify critical control points solely on the basis of public health considerations (FCN, 1990~. The HACCP concept was first applied in the 1960s to ensure risk-free foods for U.S. astronauts. In the 19SOs, it was recommended by a committee of the Food and Nutrition Board (NRC, 1985b) and the National Advisory Committee on Micro 13

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biological Criteria for Foods. In 1989, FSIS made a commitment to this highly specialized and scientific system without any clear evidence that all of its personnel fully understand it. HACCP has been specifically recommended as a basis for meat and poultry inspection (NRC, 1985a, 1987a), and it has been modified through many years of operation and fine-tuning. It is designed to prevent problems from occurring rather than to identify contaminated products at the end of the production line. According to FSIS, "it should benefit consumers, the industry and the agency by focusing inspection activities on critical areas of product safety, wholesomeness, and preventing adulteration; focusing industry responsibilities and actions to produce safe and wholesome food; and increasing the scientific basis for inspection operations" (FSTS 1989a). Contemporary Public Concerns About Meat Inspection The safety of foods of animal origin, particularly meat, is a contemporary public concern involving science, politics, regulatory programs, and the economics of meat production and processing. It has worldwide implications as the United States struggles to remain competitive in a dynamic global economy. In the United States, foodborne diseases appear to be steadily increasing: an estimated 5 million cases of foodborne disease and approximately 5,000 related deaths occur annually. This apparent increase is variously attributed to automated food processing, increased reliance on fast foods, greater use of prepackaged foods and microwave ovens, urbanization, public naivete about food production and slaughter methods, and lack of knowledge about the hygienic precautions required at all stages of food handling, including preparation and serving. Other contributing factors may include better surveillance, improved reporting, more sensitive diagnostic tests, and improved methods of detecting contaminating microorganisms and chemical residues. The current revival of interest in food safety has been fueled by reports of massive foodborne disease outbreaks. The hype of the biotechnologic revolution has convinced the public that government can assure them of zero risk of foodborne diseases. Unwillingness to accept any level of any unwanted materials (no matter how trivial) in meat has given rise to the concept of zero tolerance. However, both zero risk and zero tolerance are unachievable. Nevertheless, they are worthy targets. It is not economically and logistically feasible to achieve total freedom from all microbial and chemical contamination in meat through slaughter inspection. However, the public deserves effective national policies that provide: 0 a degree of assurance of minimal food-related exposure to microbial pathogens that cause illness in humans; 14

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a degree of assurance that production, slaughter, processing, packaging, distribution, preparation, and serving of meat will be conducted so as to limit contamination and growth of pathogenic - microorganisms; c7 r ~o o a degree of assurance of minimal exposure to levels of chemicals, antibiotics, or other residues that may be allogenic, acutely toxic, cumulatively toxic, or carcinogenic; o o recognition that varying susceptibilities exist populations have unique food safety needs; and and that different believable scientific information to underpin regulatory guidelines for production and processing of meat products. Mounting pressures for these assurances are coming from the scientific community, consumer groups, public interest groups, and public officials. Previous Food and Nutrition Board reports (NRC, 1985a, 1985b) have outlined legitimate reasons for public concern about foodborne diseases transmitted by beef or beef products. Conclusions The USDA has made many changes as it has strived to fulfill its mandate during 84 years of meat inspection. However, advancing technology, new methods of food processing and serving, and increasing public expectations dictate frequent reassessment of meat inspection programs and new approaches. The future will require new ways of preventing public exposure to contaminants, scientifically valid and believable methods of evaluating inspection technology, and implementation of appropriate portions of HACCP programs. 15