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CATm'
LE
NSP~TION
Committee on Evaluation of
USDA Streamlined Inspection System for Caine
/CTO ~\
Food And Nutrition Board
Institute of Medicine
National Academy of Sciences
National Academy Press
Washington, D.C.
1990
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National Academy Press ~ 2101 Constitution Avenue, N.W. ~ Washington, D.C. 20418
NOTICE: The project that is the subject of this report was approved by the Governing Board of the
National Research Council, whose members are drawn from the councils of the National Academy of
Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the
committee responsible for the report were chosen for their special competences and with regard for
appropriate balance.
This report has been reviewed by a group other than the authors according to procedures
approved by a Report Review Committee consisting of members of the National Academy of Sciences,
the National Academy of Engineering, and the Institute of Medicine.
The Institute of Medicine was chartered in 1970 by the National Academy of Sciences to enlist
distinguished members of the appropriate professions in the examination of policy matters pertaining to
the health of the public. In this, the Institute acts under both the Academy's 1863 congressional charter
responsibility to be an adviser to the federal government and its own initiative in identifying issues of
medical care, research, and education. Dr. Samuel O. Thier is president of the Institute of Medicine.
This study was supported by contract no. 53-3A94-9-06 from the Food Safety and Inspection
Service, U.S. Department of Agriculture.
Library of Congress Catalog Card No. 90-62817
International Standard Book Number 0-309-04345-X
Copyright ~ 1990 by the National Academy of Sciences
The cover photo was taken by Larry LeFever of Grant Heilman Photography, Inc.,
506 West Lincoln Avenue, Lititz, PA 17543, which provided the photo.
Additional copies of this report are available from:
National Academy Press
2101 Constitution Avenue, NW
Washington, DC 20418
S228
No part of this book may be reproduced by any mechanical, photographic, or electronic process,
or in the form of a phonographic recording, nor may it be stored in a retrieval system, transmitted, or
otherwise copied for public or private use, without written permission from the publisher, except for the
purposes of official use by the U.S. Government.
Printed in the United States of America
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COMMITTEE
COMMITTEE ON EVALUATION OF USDA
STREAMLINED INSPECTION SYSTEM FOR CATTLE
ROBERT F. KAHRS (Chainnan), Dean, College of Veterinary Medicine, University of
Missouri-Columbia, Columbia, Missouri
HELEN M. ACLAND, Associate Professor of Pathology, School of Veterinary
Medicine, University of Pennsylvania, Kennett Square, Pennsylvania
ROGER G. BREEZE, Director, USDA-ARS Plum Island Animal Disease Center,
Greenport, New York
GRAHAM C. CLARKE, Chief of National Programs, Meat and Poultry Products
Division, Food Production and Inspection Branch, Agriculture Canada, Ottawa,
Ontario, Canada
DONALD M. KINSMAN, Professor Emeritus, Department of Animal Science,
University of Connecticut, Storrs, Connecticut
FARREL R. ROBINSON, Chief of Toxicology Service, Animal Disease Diagnostic
Laboratory, School of Veterinary Medicine, Purdue University, West Lafayette,
Indiana
CONSULTANTS
STANLEY M. MARTIN, Chief of Statistical Services Activity, Division of
Bacterial Diseases, Centers for Disease Control, Atlanta, Georgia
I. GLENN MORRIS, JR., Associate Professor of Internal Medicine, Division of
Geographic Medicine, University of Maryland School of Medicine, Baltimore,
Maryland
MORRIS E. POTTER, Epidemiologist, Division of Bacterial Diseases, Centers for
Disease Control, Atlanta, Georgia
STUDY STAFF
FARID E. AHMED, Project Director, Food and Nutrition Board
FRANCES M. PETER, Editor, Institute of Medicine
. . .
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FOOD AND NUTRITION BOARD
RICHARD ]. HAVEL (~Chairman), Cardiovascular Research Institute,
University of California School of Medicine, San Francisco, California
DONALD B. McCORMICK (Vice Chairman), Department of Biochemistry, Emory
University School of Medicine, Atlanta, Georgia
EDWIN L. BTERMAN, Division of Metabolism, Endocrinology, and Nutrition,
University of Washington School of Medicine, Seattle, Washington
EDWARD I. CALABRESE, Environmental Health Program, Division of Public Health,
University of Massachusetts, Amherst, Massachusetts
DORIS H. CALL`OWAY, University of California, Berkeley, California
DeWITT GOODMAN, Institute of Human Nutrition, Columbia University, New York,
New York
M.R.C. GREENWOOD, University of California, Davis, California
JOAN D. GUSSOW, Department of Nutrition Education, Teachers College, Columbia
University, New York, New York
JOHN E. KINSELLA, Institute of Food Science, Cornell University, Ithaca, New York
LAURENCE N. KOLONEL, Cancer Center of Hawaii, University of Hawaii, Honolulu,
Hawaii
REYNALDO MARTORELL,
California
Food Research Institute, Stanford University, Stanford,
WALTER MERTZ, Human Nutrition Research Center,
U.S. Department of Agriculture, Beltsville, Maryland
MALDEN C. NESHEIM, Office of the Provost, Cornell University, Ithaca, New York
JOHN LISTON (Ex Officio), Division of Food Science, School of Fisheries, College of
Ocean and Fishery Sciences, University of Washington, Seattle, Washington
ARNO G. MOTUESKY (Ex Officio), Center for Inherited Diseases, University of
Washington, Seattle, Washington
ROY M. PITKIN (Ex Officio), Department of Obstetrics and Gynecology, School of
Medicine, University of California' Los Angeles, California
Agricultural Research Service,
Staff
CATHERINE E. WOTEKI, Director
SHIRLEY ASH, Financial Specialist
UTE HAYMAN, Administrative Assistant
1V
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Preface
Since the early 1900s, the U.S. Department of Agriculture (USDA) has been
responsible for mandatory federal meat inspection programs, which remained essentially
unchanged into the 1980s. In 1980, USDA's Food Safety and Inspection Service (FSIS)
asked the Food and Nutrition Board of the National Academy of Sciences (NAS) to
conduct scientific evaluations of its meat and poultry inspection programs. The Food and
Nutrition Board's recommendations were released in two reports published in 1985 and
1987 (NRC, 1985a, 1987a).
Meanwhile, FSIS worked to modernize inspection in high speed slaughter operations
through streamlined inspection systems (SIS). These systems were introduced to ensure
more efficient use of inspection personnel, to help industry to become more efficient, and
to assist the agency's transition to a more public health-oriented inspection. They initiated
SIS in pilot plants and published the proposed rule in the Federal Register in November
1988 (Fed. Regist., 1988; Appendix A). In response to questions raised about the
proposed rule, FSIS asked the Food and Nutrition Board to evaluate SIS for cattle (SIS-
C) for acceptability as an alternative to traditional slaughter inspection.
This six member committee was convened under the auspices of the Institute of
Medicine's (IOM) Food and Nutrition Board (FNB) in conjunction with the National
Research Council's (NRC) Board on Agriculture. The committee and its three consultants
included experts in biostatistics, epidemiology, meat science, meat inspection, public health,
veterinary pathology, veterinary microbiology, and veterinary toxicology.
The committee was charged with the following tasks:
0 Evaluate SIS-C as compared to the traditional cattle inspection system and its
acceptability as an alternative to traditional cattle slaughter inspection.
0 Perform on-site reviews of two high volume cattle slaughtering plants
(establishments) operating under traditional inspection and two plants
operating as pilot studies for SIS-C.
o
o
SuIvey procedures for monitoring chemicals and pathogens in carcasses.
Examine how this proposed system has integrated recommendations in the
1985 and 1987 reports, which called for FSIS to pursue new scientific
directions, address contemporary public expectations for meat and poultry
products, and work toward an ideal meat inspection program.
O Evaluate efficacy of STS-C in protecting the public's health.
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The committee received an overview of SIS-C from FSIS management, heard
testimony from eight witnesses at a public hearing, and then visited three SIS-C pilot
plants and two traditionally inspected plants. Altogether, it met six times. Throughout the
study, the committee also requested and received additional data from FSTS (Appendix B).
During their presentation to the committee, FSTS staff indicated that traditional
inspection procedures were serving as the baseline for modernizing inspection and as a
springboard for future improvements. FS S emphasized that SIS-C Is not a system for
detecting microbial or chemical contaminants and that it is not a Hazard Analysis Critical
Control Point (HA CCP) program but, rather' Is a single step toward those goals. FSIS
regards SIS-C as an innovative system that identifies control points, increases use of plant
personnel in quality control and in presentation of carcasses and parts for inspection, and
incorporates statistical samples and tests to monitor products and the slaughter process.
SIS-C differs from traditional inspection in several ways. In traditional inspection
programs, FSIS inspectors incise the bile ducts, heart, cheek muscles, and numerous lymph
nodes seeking visible lesions. Inspectors are responsible for condemnation and disposition
of diseased carcasses. FSIS inspectors also identify and supervise the trimming of
carcasses with various dressing defects and nonconformances. Under SIS-C, plant
employees incise the heart and cheek muscles, position parts for inspectors, and assume
responsibility for dressing nonconformances and designated trimmable conditions (see
Chapter 3~. FSIS leadership believes that these conditions can be recognized by personnel
with limited experience, are susceptible to market pressures, and are the responsibility of
plant management. Under STS-C, however, inspectors are still responsible for
condemnation and disposition of diseased carcasses and still examine every head, viscera,
and carcass.
In conjunction with STS-C, plants killing more than 275 cattle per hour must have a
formal written, customized, partial quality control (PQC) program. SIS-C~QC programs
require the plant to identify control points, establish standards, and take actions when
FSIS-supervised monitoring reveals that standards are unmet. Plants unable to implement
SIS-C~QC successfully must operate at chain speeds below 275 cattle per hour.
The SIS-C system is currently in effect in five pilot plants conducting high speed,
high volume slaughter of fed steers and heifers -- a class of animal with low prevalence of
conditions detectable by traditional meat inspection procedures. Approximately 80 of more
than 1,300 USDA-inspected cattle slaughter plants would be eligible for SIS-C were the
proposed rule implemented.
The eight speakers who addressed the committee during the public meeting held on
January 23, 1990, represented consumer advocates, the meat industry, food inspectors,
former USDA scientists and inspectors, and national associations (Appendix C). Some of
their testimony criticized FSTS for previous deficiencies in inspection programs, for failure
to emphasize public health, for unwillingness to listen to the scientific community, for
reluctance to improve its technologic capacity, for failure to incorporate recommendations
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in previous Food and Nutrition Board reports, and for fundamental flaws in SIS-C.
Several speakers criticized SIS-C because responsibility for quality control is given to
management of meat plants. This abdication, it was said, compromises the integrity of
FSIS and is not feasible because it requires ideal conditions in every plant and requires
plant employees to place the public interest above profit considerations. Witnesses also
stated that SIS-C is flawed because head, viscera, and carcass inspection are all
compromised and there is no assurance that company personnel are properly trimming
contaminated areas from carcasses. These problems are compounded by staff reductions
and increased paperwork for the inspection force. The opinion was expressed that SIS-C
lacks clear rational statements of goals and definitions for its sampling plans and that solid
scientific data supporting those plans are absent.
Meat industry representatives questioned USDA-FSIS's ability to regulate plant
quality control programs. They suggested that clear guidelines and appeal procedures are
needed if the government assumes this role.
Most witnesses emphasized concern about microbial and chemical contaminants.
The committee had to deal early with the real distinction between safety and quality
because FSIS contends SIS-C is not designed to detect and remove these contaminants.
The FSIS chemical residue monitoring program whether in traditional or SIS-C plants is
designed to provide incidence information -- not to prevent public exposure to residues.
The committee visited three SIS pilot plants (in Texas, Colorado, and Nebraska)
and two traditionally inspected plants (in Texas and Kansas). Its findings from these site
visits are summarized in Appendix D. The committee interviewed 24 lay food inspectors,
6 inspectors in charge, 5 veterinarians, 5 supervising veterinarians (including one area
supervisor), 7 representatives of plant management, and 9 plant quality control personnel.
From the outset, it was apparent that people were concerned about food safety,
meat and poultry inspection, and SIS-C. The committee received sworn affidavits and
letters from inspectors and veterinarians who were disillusioned with SIS-C (see Appendix
E) and many letters from one veterinarian who was formerly an FSIS employee. The
committee was also bombarded with testimony, many other letters, information,
undocumented anecdotes, newspaper clippings, and dogmatic statements assailing SIS and
blaming it for imperfections in meat and poultry inspection programs. Much of this input
implied that the public expects the government to ensure zero risk of meat-borne disease
through inspection. The committee heard little evidence that the public is aware that
some bacterial contamination of raw meat is inevitable and no mention of the crucial role
of food handling, preparation, and serving methods in limiting foodborne diseases.
The committee was chosen for its diversity and scientific credibility. Because of its
charge, it considered only commentary relevant to SIS-C. It was a challenge to sort
through the emotions, political motivations, hidden agendas, and vested interests of people
presenting opinions and recommendations. Because of the lack of hard quantitative data,
· ~
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it was difficult to separate perception from fact. This complex controversial issue
abounds with unsubstantiated accusations, subjective opinions, and deep emotional
involvements. The committee did its best to listen carefully, to be critically analytical, and
to address the specific charge. Although the report deals only with beef cattle slaughter
and SIS-C, the committee addressed some recommendations dealing with poultry in one of
the earlier reports (NRC, 1987a) when it believed they had application to beef slaughter
and the FSIS mission. The committee hopes the report is fair and will serve the best
interests of the American people.
Chapter ~ (the Executive SummaIy) summarizes the committee's charge, findings,
conclusions, and recommendations. Chapter 2 provides an introduction and a historic
overview of meat inspection and public concerns about food safety. In Chapter 3, the
committee examines the proposed STS-C ruling, its rationale, and its potential impact on
consumers. The statistical procedures used in SIS-C are discussed in Chapter 4. Chapter
5 contains a discussion of microbiological and toxicological data. An example of how to
collect and analyze microbiological samples is presented in Appendix F. Chapter 6
discusses how the proposed SIS rule could have incorporated recommendations in the
earlier Food and Nutrition Board reports. A GIossa~ of terms and acronyms can be
found in Appendix G. The affiliations and major research interests of committee members
and staff are presented in Appendix H.
The committee commends the assistance, hard work, and support of the FNB staff:
Dr. Farid E. Ahmed, for the organizational and administrative support of the committee's
work, Frances Peter for editing the report, and Barbara Matos for typing the document.
The committee expresses its appreciation to FSIS personnel for expediting facility
visits and providing data, to all the plant personnel who extended hospitality, and to all the
witnesses who testified at the public hearing. The committee is also grateful to the
anonymous USDA inspectors and veterinarians and many plant employees who
volunteered time and shared their concerns.
As chairman, ~ also thank the committee members and consultants and their
employers; they volunteered countless hours and effort to produce an objective and timely
report on a controversial subject that is a small part of a major national issue -- the safety
of the food supply.
~ /~
Robert F. Kahrs, Chairman
Committee on Evaluation of USDA
Streamlined Inspection System for Cattle
. · .
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Contents
Executive summary
Committee charge, its response, and its conclusions
Recommendations
2
3
Introduction and Historical Review of Meat Inspection
Abstract
Historic food safety concerns and early meat inspection legislation
Developments after the Meat Inspection Act of 1906
Emergence of HACCP as a mode] inspection system
Contemporary public concerns about meat inspection
Conclusions
The Proposed STS Rule
Abstract
Rationale and assumptions of the ruling
An overview and commentary on SIS-C and the slaughter PQC program
STS-C postmortem inspection
Streamlined inspection procedures
Cervical/head inspection
Viscera and carcass inspection
Uniform presentation standards
Specific equipment and facilities
Carcass dressing requirements
Assessing the wholesomeness of the carcass and product
FS:IS data in support of the proposed ruling
Impact of SIS-C on consumers, inspectors and plants
Consumers
Inspectors
Plant managers and employees
Conclusions and recommendations
Statistical Considerations
Abstract
Rationale supporting the change from AQL to SIS
Use of CUSUM for process control
The sampling basis for CUSUM
Discussion
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Discussion
Recommendations
s
Microbiologic and Toxicologic Assessment
Abstract
Assessment
Recommendations
6 The Extent to Which Previous FNB Recommendations
Have Been Integrated into the SIS Proposed Rule
Abstract
Recommendations in Meat and Poultry Inspection:
The Scientific Basis for the Nation's Program
Recommendations
Detection and elimination of pathogenic microorganisms
Preventing and detecting chemical residues
Monitoring hazardous agents during livestock
production and traceback mechanisms
Integration of risk assessment procedures into
the inspection process
Research and advisory programs to develop high
technology-based inspection
Characteristics of an optima] meat and poultry
inspection program
A system of traceback to producers
Use of plant personnel to monitor critical control points
Use of contemporary technologic expertise in
inspection management
Multitiered levels of inspection
Analysis of the utility of each inspection procedure
Develop a data base on specific causes of condemnations
Rapid screening for residues
Protection of consumers from residues
Hazard Analysis Critical Control Point (HACCP) Programs
Documentation and compliance enforcement
Enhanced enforcement capability
Improve technologic base of FSIS
Mandatory continuing education
Involvement of scientists in policy development
Expert advisory panels
Interagency liaison
Data and information analysis
Implementation timetable
Recommendations in Poultry Inspection: The Basis
for a Risk-Assessment Approach
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General recommendations
Specific Recommendations
Conclusions
References
Appendices:
A Proposed Rule. Streamlined Inspection System-CattIe
and Staffing Standards
B Information Provided by USDA-FSIS to Committee
C Public Meeting Agenda
D Reports on Site Visits
E Summary of Verbal and Written Testimony by FS1:S Inspectors
F Bacteriological Study of Beef Carcasses in Quebec
Annex 1 Data Sheet for Establishment
Annex 2 Needle Point Stamp for Marking Samples
to be Taken
Annex 3 Areas From Which Samples are to be Taken and
Location of Points at Which to Take Temperature and
Relative Humidity Readings
G Glossary of Terms and Acronyms
H Affiliations and Major Research Interests of Committee and Staff
Tables:
2-1 Analyses Performed by FSIS in 1989
3-1 An Overview of the SIS-C/PQC Program
3-2 SIS-C and Traditional Postmortem Inspection Procedures
3-3 Size and Frequency of Sampling by Plant QC Personnel and
FSIS Inspectors
5-1 Classification of Worldwide Meatborne and Poultryborne
Microbial Pathogens According to Modes of Transmission
F.
figures:
3-1 Interactions Between Plant Process Control Operations and
Plant Quality Control and Federal Meat Inspection Staff
4-] Probability of Observing No Defects in Various Lot Sizes
and Line Speeds When the Average Number of Defects/Sample Unit
(Carcass Side) is 0.1
4-2 Evaluation of CUSUM for SIS-C, Assuming n=3, c=0
X1
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