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3
The Proposed SIS Rule
slaughtering plants inspected by USDN
Abstract The proposed SIS-C rule applies to plants in which only heifers and steers
are slaughtered. Thus, it is applicable to approximately 80 of about 1,300 cattle
~ ~ ~~ - SIS-C involves an important change in
pn~(Jpny wnere~y ~nuustIy assumes Auks responsibility for meat quality, permitting FSIS
to concentrate on safety. By assuming the full costs and responsibility for quality,
industry will have an economic incentive to enforce quality controls and correct
manufacturing processes causing defects.
The proposed rule describes new and streamlined postmortem procedures;
uniform presentation standards for viscera and body parts; specific equipment, facilities,
and inspection space requirements; and carcass and edible by-product finished product
standards.
To verify that product standards are being met by plant processing
personnel, SIS-C plants with chain speeds exceeding 275 head per hour must employ
quality control personnel to implement an FSIS-approved and monitored partial quality
control (PQC) program (SIS-C/PQC) in which a statistical procedure known as
cumulative sum (CUSUM) is used to evaluate wholesomeness and acceptability of
products throughout a work shift and over longer periods.
The committee examined various FSIS documents (Appendix B) supporting
the proposed rule (AppendLx A) and assessed the impact of SIS-C on consumers,
inspectors, and packers.
The committee recommends that desired final product characteristics, not
meat inspection as traditionally being done, should be the standard against which
inspection systems or new technologies are judged. The scientific basis for traditional,
SIS-C, and SIS-C/PQC meat inspection was found to be inadequate. The committee
concluded that when quality control programs are effectively implemented, SIS-C/PQC is
acceptable as an alternative to traditional inspection. The committee recommends that
SIS-C without a PQC program should be an interim process lasting no more than 1
year. Strong concerns about SIS-C held by a number of FSIS inspectors led the
committee to recommend that FSIS pay more attention to employee communication and
education.
Rationale and Assumptions of the Ruling
The proposed rule defining the Streamlined Inspection System-CattIe and
Staffing Standards (Fed. Regist., 1988; Appendrx A) details procedures, definitions, and
numerical standards that could bewilder those not experienced with the meat packing
industry. They include topics such as the candlepower of lighting, the size of mirrors,
the diameter of stains, and whether organs should be observed and palpated, or merely
observed. These details obscure the most important issue--the shift of responsibility for
quality from FSTS to industry. For S S-C to work in practice, both FSIS and industry
must fully subscribe to this new philosophy, which is the most important change in bovine
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meat inspection since 1906.
Traditional meat inspection has placed FSIS and industry in an unsatisfactory
relationship in which packers without total commitment to quality control throughout
the slaughter and dressing processes expect FSIS inspectors to detect and deal with
quality problems before the carcass leaves the slaughter floor. Traditionally, FSIS
inspectors, who must ensure that only wholesome products enter commerce, spend 70
to 90% of their time identifying and dealing with dressing nonconformances and
designated trimmable conditions2 that are obvious and easily identified. Some have
little or no implication for public health. These defects can be corrected by packing
plant employees. If industry had to assume the full costs and responsibility for dressing
operations, it would have economic incentive to adopt effective quality controls and to
correct manufacturing procedures that permit defects.
S]S-C creates a new relationship between FSTS and industry. This partnership,
with shared responsibility, permits FSTS inspectors to concentrate on pathologic lesions.
It makes industry take active steps to prevent problems by identifying and resolving
those points in the slaughter and dressing processes at which carcass contamination or
dressing defects occur.
Slaughter and dressing must be performed in a sanitary manner but can never
be sterile operations. The procedures, machinery, and technology involved are intricate
and must be seen to be understood. The carcass can be contaminated by contact with
ingesta, feces, mud balls, equipment, and people. It would be safer for public health if
contamination could be prevented rather than detected and lammed away afterward.
Carcasses that are cleaner during and after dressing are less likely to have extensive
(and invisibles surface bacterial contamination that can worsen during processing before
the product reaches the consumer. SIS-C seeks to involve every plant worker, not just
the federal inspectors, in prevention programs.
An Overview and Commentary on STS-C and the Slaughter PQC Program
Antemortem inspection and slaughter are identical in SIS-C and traditional
systems. Postmortem inspection under SIS-C has three elements that differ from
traditional systems: diminished postmortem inspection, uniform presentation of carcass
and parts, and additional specific equipment and facility requirements (Table 3-1~.
After postmortem inspection by FSTS inspectors, the carcass and edible by-products are
Dressing nonconformances are defects on the carcass that result from errors in the
handling, slaughtering, or dressing operations performed by establishment employees.
These include bruises, hair, dirt, ingesta, feces, organ remnants, and machine grease.
Designated trimmable conditions are abnormal conditions that are not caused by
improper procedures, that are readily identifiable, and that do not affect the disposition
of the carcass. These include fractures, arthritis, localized abscesses, and pigmentation.
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Table 3-! An Overview of the SIS-C/PQC Program
Plant Quality Control Staff
PQC Program Requirements:
Approved by FSIS
Compulsory if slaughtering
> 275 head/hr
Voluntary if < 275 header
Principal Components of PQC Program:
.
Identification of critical control
points (CCPs) in slaughter and dressing
Development of standards at
each CCP
Specification of actions to
be taken if CCP standards are
not met
Responsibilities of Plant Employees
in PQC Program:
Randomly sample head, tongue,
carcass, and edible by-products;
measure compliance with product
standards
Inform production supervisor of
any process trends
Plant Production Staff and FSIS Inspectorate
Fed steers and heifers only (healthiest segment of
population)
Antemortem inspection (FSIS)
Slaughter
SIS-C Postmortem Inspection (FSIS) (Every carcass,
every head, and every set of viscera)
Streamlined
postmortem
procedures:
. head
. viscera
. carcass
Uniform presentation
standards: head,
tongue, viscera,
carcass (scored
under PQC in
SIS-C/PQC plants)
Specific
equipment,
facilities,
and inspection
space
Dressing nonconformances and designated trimmable
conditions removed by establishment employees
Carcass produced to
specific 'finished
product standards'
Edible by-products produced
to specific 'edible by-
product standards'
Reinspection of carcasses at random by FSIS inspector,
who also monitors establishment QC tests of
compliance with product standards
Process in control:
plant producing
product that meets
standards over time
Process out of control:
plant producing product
that does not meet standards.
Establishment takes corrective
action under inspector
. .
supervision
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examined by plant employees and all dressing nonconformances and designated
trimmable conditions are removed. The goal of these procedures is to produce
wholesome carcasses and edible by-products, according to specific product standards.
To verify that product standards are being met, some SIS-C plants employ
quality control personnel to implement a PQC program. These people randomly
sample heads, tongues, carcasses, and edible by-products from the slaughter line and
measure compliance with product standards by a statistical procedure known as
CUSUM (see Chapter 4), which is monitored by the inspector. The goal is to
evaluate the wholesomeness and acceptability of the products using these standards.
Final oversight of product standards is provided by FSIS inspectors, who
independently sample heads, tongues, and carcasses; measure their compliance with
product standards; and compare their results with the plant's records. The frequency
and nature of sampling, tests performed, standards, means of comparison, and
definitions of terms are described in detail in the proposed rule (Fed. Regist., 1988~.
The FSIS inspector must determine if slaughter and packing processes are "in control"
(i.e., that the products meet or exceed standards). If it is "out of control," the
establishment must take immediate corrective action under supervision of the inspector.
Under SIS-C, packing plants slaughtering more than 275 cattle per hour must
have an approved PQC program. For those with slower line speeds, the PQC program
is optional. In plants without PQC, the FSIS inspector oversees product standard
compliance by using the same procedures included in operations with a quality control
program (Figure 3-1).
SIS-C Postmortem Inspection
Under SIS-C, as in traditional inspection, FSTS inspectors inspect every carcass,
every head, and every set of viscera. FSIS insists that this will not change, since the
law mandates 100% inspection.
Streamlined Inspection Procedures
3-2).
STS-C differs from traditional inspection in the following details (see also Table
Ce~vical/head inspection
Under SIS-C, the lateral retropharyngeal lymph nodes are not incised; the
inspector observes but does not cut the masticatory muscles, which have been incised
by a plant employee; and a plant employee, not the inspector, palpates the tongue.
The inspector takes action when a palpable tongue abnormality is identified by the
plant employee. Heads must be presented by the plant employees in a specified
uniform manner to ensure timely and consistent inspection.
9
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WHOLE ANIMAL: SOURCES OF CONTAMINATION
Hide - dirt, manure, moisture
Internal - abscess, disease, sepsis
_
1 -`
. ~
PLANT PROCESS CONTROL FEDERAL MEAT INSPECTION:
_ Organoleptically detects lesions,
Controls manufacturing
defects then makes disposition based
l l on health of the animal J
Evaluate//
Finished product
standards
PLANT QUALITY CONTROL:
Quality control
monitoring
/
/
Figure 3-! Interactions Between Plant Process Control Operations and Plant
Quality Control and Federal Meat Inspection Staff
FSIS presented data to the committee to support its view that these changes in
cervical/head inspection do not permit lesions of diseases to pass undetected or alter
carcass disposition (Wesson, 1983). Some inspectors who spoke to members of the
committee on site visits disagreed (see Appendix E).
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Table 3-2 SIS-C and Traditional Postmortem Inspection Proceduresa
SIS-C
Traditional
Head Inspection
Observe leading side and surfaces of head, eye,
and incised leading lateral and medial
muscles of mastication.
Incise and observe leading parotid lymph node.
Observe trailing incised medial and lateral
muscles of mastication.
Incise and observe trailing parotid lymph node.
Incise and observe lymph nodes attached to the
tongue--medial retropharyngeal
(suprapharyngeal) and mandibular.
Observe tongue and lateral retropharyngeal
(atlantal) lymph nodes.
Viscera/Carcass Inspection
Head Inspection
Incise lymph nodes attached to the tongue--
medial retropharyngeal (suprapharyngeal),
lateral retropharyngeal (atlantal), and
mandibular.
Observe and palpate tongue.
Observe surfaces of head and the eyes.
Incise and observe parotid lymph nodes and
lateral and medial muscles of mastication.
Viscera Inspection
Observe outer surfaces of eviscerated carcass
(including dorsal surface) with the use of the
mirror and observe the superficial inguinal
(supramammary) and internal iliac lymph
nodes.
Observe pelvic and peritoneal cavities, kidneys,
and the diaphragm.
Observe pleural cavity and cut surfaces of
muscles and bone.
Observe mesenteric lymph nodes and abdominal
viscera.
Observe ruminoreticular junction.
Observe esophagus and spleen.
Incise and observe lung's lymph nodes-
mediastinal (posterior, middle, anterior) and
left tracheobronchial.
Observe and palpate costar surfaces of lungs.
Observe inner, cut, and outer surfaces of heart.
Observe hepatic (portal) lymph nodes. Carcass Inspection
Open bile duct (both directions), and observe
its contents.
Observe and palpate ventral surface of liver.
Turn liver over, palpate renal impression;
observe and palpate parietal (dorsal) surface.
Observe eviscerated carcass.
Observe mesenteric lymph nodes and abdominal
viscera.
Observe and palpate ruminoreticular junction.
Observe esophagus and surface of spleen.
Incise and observe lymph nodes of the
lungs mediastinal (posterior, middle,
anterior) and bronchial (right and left).
Observe and palpate costar (curved) surfaces of
lungs.
Incise heart, from base to apex or vice
versa, through interventricular septum, and
observe cut and inner surfaces.
Turn lung over; observe ventral (flat) surfaces
and outer surface of heart.
Incise and observe hepatic (portal) lymph nodes.
Open bile duct (both directions) and observe its
contents.
Observe and palpate ventral surface of liver.
Turn liver over, palpate renal impression, and
observe and palpate parietal (dorsal) surface.
Palpate and observe superficial inguinal
(supramammary) and internal iliac lymph
nodes.
Observe lumbar region.
Observe and palpate kidneys.
Observe pillars of diaphragm and peritoneum.
Observe pleura, cut surfaces of muscles, and
bones, neck, and carcass exterior.
a Source: FSIS, l989b.
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Viscera and carcass inspection
Under SIS-C, unlike traditional inspection, inspection of viscera and carcasses
takes place simultaneously, facilitating identification of corresponding parts and organs.
Because of time constraints, it is important that plant personnel present the viscera in
a specified manner (see section on Uniform Presentation Standards, below).
As shown in Table 3-2, SIS-C differs from traditional inspection of viscera and
carcasses in several ways. In SIS-C, the ruminoreticular junction (common site for
abscesses) is not palpated; plant employees cut the heart muscle (inspector
observes); various organs/lymph nodes are no longer palpated or incised; and the
inspectors do not observe the split vertebral column and surrounding tissues, since the
carcass is split further along the rail (beyond the viscera/carcass inspection station).
These differences are a major source of discontent among inspectors. Under
traditional inspection, FSTS inspectors viewed the interior and exterior of both sides of
the eviscerated and split carcass and had an unobstructed view of the kidneys and
diaphragm. Under STS-C, the last FSIS inspectors in the line are posted at the carcass-
viscera station, where they examine viscera presented on a moving belt on one side,
observe the inside of the corresponding whole (i.e., unsplit) eviscerated carcass as it
passes by on a chain on the other side, and examine the back of the carcass for dirt or
blemishes through a mirror. Except for randomly sampled split carcasses, this is the
last time the inspectors view the carcass before it is washed and sent into the cooler.
Under S1:S-C, in plants slaughtering fewer than 234 head per hour, a plant employee
removes the kidneys for presentation with the viscera at the viscera/carcass station. At
higher slaughter rates, kidneys are examined in the unsplit carcass.
After carcasses pass the viscera-carcass station, plant employees trim dirt, stains,
hair, and other blemishes from them. Under STS-C, there are no inspectors to ensure
that trimming has been done correctly before the carcass is split and washed. This is
the responsibility of the plant's certified trimmers. Their work is checked by plant
quality control staff. Federal inspectors monitor the final products according to
finished product standards and check that quality control is being performed as
specified in Figure 3-~.
Critics of SIS-C contend that inspectors should view the split vertebral column to
detect discolorations, spinal abscesses, and other blemishes: this would require an
additional inspector to be situated on the line after the carcass is split. FSTS
management disagrees with the need for an inspector and believes that company
trimmers can recognize and deal with any dressing nonconformances and designated
trimmable conditions discovered on splitting.
FSIS presented data to support its view that these procedural changes in
viscera/carcass inspection do not permit lesions of diseases to pass undetected or alter
carcass disposition (Wesson, 1983~. However, most inspectors interviewed by the
committee and those who testified at the public hearing disagreed with the FSIS
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position.
Uniform Presentation Standards
Work-measurement studies were conducted by FSIS to determine the times
needed for organoleptic SIS-C procedures. More inspectors are added when chain
speeds are increased. Careful, consistent, and uniform presentation of heads, tongues,
and viscera is important so that inspectors can spend their time examining for disease
rather than sorting through haphazardly distributed organs on a moving belt. The
consistency with which organs are presented for inspection is monitored under the SIS-
C program.
Certain procedures previously performed by FSIS inspectors are the
responsibility of establishment personnel under STS-C, and the time formerly spent in
performing these steps is used to inspect for lesions. The important aspects of
presentation standards are:
0 palpating the tongue
o incising masticatory muscles
o opening heart chambers and incising the interventricular septum
0 positioning organs for ease and consistency of inspection
Some inspectors claim their ability to detect eosinophilic myositis and cysts (the
larval stage of the beef tapeworm) is compromised when cutting of heart and cheek
muscles is delegated to plant employees. This opinion is based on the premise that the
fee] of the inspector's knife passing through these lesions helps them recognize their
presence and provides an opportunity to view the cut surfaces immediately before they
are covered by seeping blood.
Specific Equipments and Facilities
FSIS specifies facility and equipment requirements for SIS-C. These include a
special mirror positioned so that inspectors can view the back of the carcass as it
passes while looking into the opened front of the carcass at kidneys and serosal
surfaces. Lighting standards for each inspection station are also specified.
The committee heard testimony that mirrors become covered with condensed
moisture and do not always present an unobstructed view of disease conditions or dirt
on the back of the carcass. Other testimony refuted this contention. The committee
found the mirrors to be satisfactory for observing the backs of the carcasses in the
SIS-C plants it visited; however, one inspector observed did not appear to be watching
the mirror consistently.
Carcass Dressing Requirements
Plant production employees (as distinct from quality control employees) are
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responsible for removing dressing nonconformances and other designated trimmable
conditions. They must adhere to finished product standards for carcasses and edible
by-product standards. In STS-C plants, FSIS inspectors monitor compliance with the
standards and take corrective action if the establishment has failed to apply the
standards. There is, therefore, a two-tier system for quality control--production staff
and FSTS inspectors. This approach was suggested in a previous Food and Nutrition
Board report (NRC, 19SSa).
In SIS-C/POC plants. there is a third tier--a Dlant oualitv control (OC) arouD-
. _ ~ , ~ ~ ~ ~ - ~ ~ ~
that reports through a supervisor to the plant manager in a chain of command
independent from that of the production staff. The actual independence of PQC staff
has been questioned by critics of SIS-C/PQC, especially FSIS inspectors who allege that
some plant QC employees are urged by management to neglect details that may slow
the process. This QC group monitors the production process continually, performs
random sampling to at least the minimal frequency stipulated in the proposed rule
published in the Federal Register (Appendix A), and uses the finished product standards
and CUSUM to measure process control. FSTS inspectors evaluate the ability of the
company's production personnel to control the process by:
o checking timeliness and accuracy of records
o performing sample tests to correlate with plant QC's findings
o checking presentation standards
0 applying product standards to the carcass, head, and edible by-products
o performing CUSUM calculations
Under both STS-C and SIS-C/PQC, FSIS veterinarians and inspectors are
responsible for determining if the carcass and parts are wholesome before entering
commerce. However, concern was expressed that FSIS can lose control of the final
product once it has passed the final inspection (carcass-viscera) station.
Assessing the Wholesomeness of the Carcass and Product
A beef carcass reinspection program known as Acceptable Quality reeve! (AQUA)
has been used in traditionally inspected plants for many years. In this program,
carcasses are examined for wholesomeness, cleanliness, and acceptability, but the level
of process control is not evaluated (see Chapter 4~.
FSIS has developed a system in which CUSUM is used to continually monitor
the entire slaughter and dressing process. Through it, FSIS and plant employees can
learn whether the process is in control, out of control, improving, or deteriorating. The
method for calculation of CUSUM, the definitions of all terms, and the details of all
standards are set out in the Federal Register (Appendix A) and are discussed in
Chapter 4.
Sample size and sampling frequency as given in the Federal Register are shown in
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Table 3-3.
Table 3-3 Size and Frequency of Sampling by Plant QC Personnel
and FSIS Tnspectorsa
Size of
Sample
Sampling Frequency
By Plant QC
Personnel
By FSTS
Inspectors
Three half carcasses Once an hour Twice every ~ hours
Five tongues Once an hour Twice every ~ hours
Five heads Once an hour Twice every ~ hours
Ten units of each edible Once every At least once every
by-product 2 hoursa ~ hours
aVariable by inspector.
FSIS developed finished product standards to measure wholesomeness and
acceptability, e.g., cleanliness. These standards define limits of conformance that
products must meet to avoid the risk of having to rework, the product. They are
applied after the carcass has been inspected for disease. They are not aimed at
detecting public health problems or diseases missed during inspection. The limits
represent the national average of products qualifying for designation as "U.S. Inspected
and Passed" in all plants slaughtering all classes of cattle.
Plant QC personnel and FSTS inspectors independently determine the total
number of nonconformances for each subgroup, reduce this number to a CUSUM
value, and measure this against predetermined standards (see Appendix A).
When plants maintain process control at or below tolerances, final products
should be within the limits of acceptability. Products that do not meet the acceptable
standard indicate that there is a deficiency somewhere in the slaughter or dressing
process. CUSUM calculations and finished product standards should alert the plant
3Rework is reprocessing the product to correct the condition or conditions causing
the nonconformances. For carcasses, this usually means trimming to remove dressing
non-conformances and designated trimmable conditions.
4Tolerance identifies a limit above which the product is deemed to be
unacceptable.
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and FSIS inspectors to problem areas in the system. Because finished product
standards are used to monitor the process, potential or emerging problems can be
identified promptly provided the standards are appropriate. Test results over time can
be used to define trends.
If the production is not in control, certain specific actions are required. For
example:
o The line must slow by 10% to correct presentation problems (plant takes
action).
O Product/carcasses and by-products are held for rework if finished product
standards are not met. The plant takes action.
O FSIS inspectors have authority to increase sampling rates in trouble areas
and to require that the operation temporarily slow or stop until problems
are corrected.
FSIS data comparing AQL scores under traditional inspection with SIS-C
CUSUM scores in the same plant over time show that improvement in product
cleanliness correlated with introduction of SIS-C (FSIS, 1989b; see also Appends B).
However, correlation does not prove that SIS-C caused the improvement (see Chapter
4~.
FSIS Data in Support of the Proposed Ruling
FSIS presented the following documents to the committee in support of the
proposed rule:
o "A Study on the New Cattle Post-Mortem Inspection Procedure for Steers
and Heifers" (Wesson, 1983~.
In this study it was concluded that the new cattle postmortem inspection
procedure was as effective as the traditional procedure in all areas except liver
inspection. The new procedure proved more effective in identifying visible liver defects
under the conditions of the test. Work-measurement studies showed that the new
procedure will result in increased inspection productivity.
The Wesson study involved a comparison of traditional and new inspection
procedures at four steer/heifer slaughter plants with line speeds of 320, 225, 185, and
95 cattle per hour. Data from two other plants, in which cows and bulls were
slaughtered, were omitted from the report. This omission was criticized by a witness at
the public hearing. FSTS justified this omission because SIS-C is intended only for
plants that slaughter steers and heifers.
0 "Development of Finished Product Standards for the SIS-C Inspection
Procedure" (FSIS, 1989~.
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This manuscript described how FSTS develops finished product standards.
O "Results of Finished Product Standards Test for STS-C Pilot Plants" (see
Appendix B).
This report charted the results of finished product standards test results for the
SIS-C pilot plants. Data for the earliest month were compared with the corresponding
month ~ year later and were graphed in comparison to the national average of carcass
acceptability (tolerance). Four plants produced products well below tolerance. In one
plant, the process was not controlled and corrective action was required.
O "Comparison of Carcass Cleanliness Using Traditional and Streamlined
Inspection Procedures" (see Appendix B).
Carcass cleanliness was compared in a plant that switched from traditional
inspection with AQL to STS-CattIe with finished product standards. Carcasses were
scored with AQL under both systems of inspection. Product cleanliness improved after
srs-c was introduced (see Chapter 4~.
O "Slaughter and Condemnation Data for Steers and Heifers" (see Appendix
B).
Analysis of 1985- 1989 data from the FSIS Animal Disease Reporting System
(ADRS) indicated no discernible difference in condemnation rates or causes of
condemnation between STS-C procedures and traditional inspection, nor were there
differences in the rates of carcasses passed with restrictions. However, the rate of
condemnation in the five pilot plants increased after conversion to STS-C.
The primary goal of inspection is to make decisions on the disposition of
carcasses--not specific etiologic or morphologic diagnoses. Thus, condemnation data
provided by FSIS reveal little about the public health merits of inspection. Diseases of
public health importance that can be detected organoleptically at slaughter, such as
cysticercosis and tuberculosis, are very rare (e.g., approximately three diagnosed cases
of tuberculosis on average are found within each million animals slaughtered) and are
detected with equal frequency under SIS-C and traditional systems (data provided by
FSIS, see Appendrx B).
Consumers
Impact of SIS-C on Consumers, Inspectors, and Plants
Although SIS-C is not directed primarily toward human health risks, it should
have no adverse effect on the health of consumers of meat and edible by-products.
Conditions of public health importance that are missed under SIS-C inspection are
likely to be missed under traditional inspection as well.
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A consumer dissatisfied with a purchased product can seek redress from the
supplier or not buy the product again. It is impossible, however, given the structure of
the meat industry, for a customer unhappy about cleanliness of meat purchased from a
supermarket to influence the practices of the packing plant from which that product
came. The only purchasers potentially able to influence plants are the large fast-food
and supermarket chains. Many of these have their own quality control procedures to
assess the cleanliness and microbial burden of products. The committee asked FSIS if
it had any evidence that the major chains used their own quality control data to choose
suppliers; however, FSIS did not have this information.
Inspectors
FSTS inspectors and veterinarians have the frontline positions in safeguarding the
acceptability of the nation's meat supply. If unwholesome or contaminated meat passes
by them, the bacterial load could increase and contaminate other products as it passes
into the chain of transport, storage, handling, and preparation to the ultimate
consumer. FSIS staff in the field take their responsibilities very seriously; the
committee was impressed by their sincerity and conscientiousness.
The introduction and evaluation of SIS-C were complicated by unrelated and
controversial issues, such as increased chain speeds, union-employer relations in the
packing industry, working conditions, occupational safety (especially repetitive motion
injuries), job security, and job stature. These issues obscured the essence of SIS-C--
that advancing technology and increasing public expectation necessitate a major
overhaul of the philosophy, concepts, and details of the meat inspection system. This
change (SIS-C) has caused conflict within FSIS that could have been avoided by better
communication, training, and appreciation of the concerns of field inspectors about
basic concepts of STS-C.
For 80 years, FSIS has done an excellent job of training inspectors and
developing a culture of responsibility for decisions on carcass disposition and standards
of dressing and fabricating final product. Suddenly, with the introduction of SIS-C,
inspectors were told that decisions they once controlled had been assigned to plant
emniovees who are not trained in meat inspection. Under SIS. inspectors lost the
~ ~ A J .1
· . . . · ~ · - ~ - - -
opportunity to check the work ot plant employees in the reinspection process.
Whatever the statistical merits may be, FSIS inspectors do not accept the agency
position that reinspecting only 6 of between 4,000 and 6,000 sides of beef from an S-
hour shift is adequate. Moreover, inspectors do not support the agency view that most
microbial and chemical residue samples are generally taken to provide data for
proactive intervention to prevent disease rather than for retrospective analysis.
There are no substitutes for good data and solid scientific facts in developing
and testing new rules and regulations. FSIS has compiled some data to persuade its
own management of the merits of SIS-C and has presented arguments to convince
them that change is appropriate. However, enthusiasm for SIS-C was not successfully
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communicated to many long-term field employees of the agency. It is clear that fewer
FSIS inspectors are being used to staff plants under STS-C and SIS-C/PQC. FSIS could
have used surplus inspectors to validate finished product standards, to study the
frequency and numbers of reinspections needed, and to improve surveillance for
microbial and chemical contaminants in SIS-C plants. These steps might have
alleviated anxieties among rank-and-file meat inspectors worried about product quality.
More inspectors could have been trained in SIS-C. Instead of aiming for a new
inspection procedure on a par with the traditional, FSIS could have implemented an
SIS-C program that incorporated the underlying philosophy of the earlier Food and
Nutrition Board studies (NRC 19SSa, 1987a) and made clear technological advances.
The committee believes the planning of such a program should begin with the decision
that traditional inspection should no longer be the standard by which other systems are
judged and that it is more rational to evaluate systems based on the desired
characteristics of the final product.
Plant Managers and Employees
Managers and workers in STS-C plants have an important new role to play in
ensuring product quality. This must be understood by all workers and inspectors--not
just managers, quality control personnel, and certified trimmers. SIS-C plants are food
processing plants--not meat packers or slaughterhouses.
The committee heard much testimony about the characteristics of jobs in
packing plants. These jobs are not viewed as being very attractive, and turnover is
high. Many workers are recent immigrants with poor English language skills and come
from countries with low standards of hygiene and food handling. Thus, FSIS and
industry must establish training standards and a certification program for all plant
employees involved in the slaughter, dressing, and handling of meat products.
FSIS must also establish better employee training and retraining programs in
STS-C/PQC concepts and other planned innovations so that all workers and managers
are committed to the goals, concepts, and standards of new inspection programs.
Conclusions and Recommendations
o Traditional meat inspection, relying on organoleptic detection methods, can
ensure satisfactory meat product quality but is not fully effective in protecting
the public against contemporary foodborne health hazards, such as
microorganisms, hormones, and residues of toxic chemicals and heavy metals.
Therefore, traditional meat inspection should not be used as the gold standard
against which inspection systems or new technologies are judged.
o
The desired characteristics of the final product should be the starting point for
design and evaluation of inspection systems. For meat, desirable final product
characteristics include, but are not limited to, the following:
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Aesthetically pleasingS (free from dirt, hair, bruises, grease, mud, ingesta,
feces).
Free from visible lesionsS (tumors, cysts, hemorrhages, inflammation, or
other evidence of disease or injury).
Have good keeping qualityS (low population of spoilage microorganisms).
Low levels of bacterial pathogens and other infectious agents that can cause
disease in humans.
Hormones, antibiotics, toxins, pesticides, heavy metals, and other toxic
substances, at or below established safe levels for humans.
These desired characteristics of meat products relate to both safety and quality,
which are not mutually exclusive because quality procedures can affect microbial
burdens and thus indirectly influence safety. However, total emphasis on quality only
obliquely addresses the crucial safety issues of preventing microbial and chemical
contamination. The distinction between quality and safety is as follows: safer relates
to the presence of pathogenic microorganisms or levels of chemical residues; quality
concerns aesthetically pleasing appearance, absence of visible lesions, and good keeping
characteristics through low levels of spoilage-causing microorganisms.
All possible efforts should be made to minimize contamination of meats and to
remove contaminated products from the food chain. Now, and for the
foreseeable future, it is not possible to ensure that all raw meat products are
totally free of microbial pathogens that can cause disease in humans. Inevitably,
some portion of the meat supply will be contaminated with some detectable
level of one or more pathogens. Ideally, it is hoped that contamination can be
kept below established safe thresholds. However, as outlined in previous Food
and Nutrition Board reports (NRC, 19SSa, 1987a), such thresholds are difficult
to estimate because microbial populations can multiply rapidly and because
human susceptibility to different diseases is highly variable. The best that can
be done is to assess how closely inspection systems approach the ideal, if
unattainable, goal of total freedom from microbial pathogens.
Both traditional meat inspection and STS-C focus largely on visible lesions. Both
systems partly address the microbial loads that determine keeping characteristics and
sThese characteristics constitute quality. They are desirable but have no primary
effect on human health. Meat quality also includes color, texture, tenderness, juiciness,
marbling, and other desirable characteristics not considered in the report (see Appendix
G).
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levels of pathogenic microorganisms by monitoring plant hygiene and refrigeration and
by trimming carcasses visibly contaminated with feces, dirt, or hair. Except for
occasional sampling, sporadic tracebacks, and voluntary residue avoidance programs,
neither system addresses chemical residues. The major difference between the systems
is that FSIS inspectors enforce efforts to control visible contamination under traditional
systems, whereas in SIS-C, much of this responsibility is delegated to plant employees.
In STS-C/PQC, both aesthetic appearance and freedom from visible lesions are
addressed. Through increased hygiene and emphasis on an effective PQC program,
SIS-C/PQC may reduce contamination with spoilage or pathogenic microorganisms.
Thus, SIS-C/PQC is potentially superior to SIS-C and traditional inspection. In the
absence of total quality commitment from industry, SIS-C alone (i.e., without PQC) is
probably no better than traditional inspection and in some situations, can be less
effective than traditional inspection because the reduced oversight by government
inspectors is not compensated by a total commitment to product quality on the part of
industry.
o
The beef packing industry should aggressively adopt improved quality control
measures. In SIS-C, FSIS expects industry quality control personnel to prevent
problems by identifying and correcting slaughter and dressing procedures during
which carcass contamination or dressing defects occur. The committee found
that some members of the meat packing industry had indeed taken such steps,
for example, by improving employee hygiene (through training and increased use
of rubber gloves, hair nets, aprons, and washing stations) and by wrapping
hindquarters to prevent fecal smearing of carcasses during hide removal. These
procedures, and others identified by frequent product and process evaluation
during slaughter and dressing, help reduce microbial contamination.
The committee found that some plants have exceeded FSIS expectations for SIS-
C/PQC by implementing a comprehensive HACCP system (see Chapter 2) covering
the desirable characteristics of meat products, including chemical residue analyses of
feecistuffs and water, controls on the use of microbials and pharmaceuticals in feedlots,
and rapid microbiological testing of a representative number of carcasses every day.
Unfortunately, industry quality and safety data are not in the public record, nor has
FSIS conducted independent studies to verify and quantity reported reductions in
chemical and microbial contamination.
O Inspection programs have the following limitations:
By definition, traditional meat inspection can only ensure aesthetically pleasing
appearance and freedom from visible lesions.
STS-C also includes only aesthetically pleasing appearance and freedom from
visible lesions. The difference between traditional meat inspection and SIS-C
lies only in the persons responsible for the quality of the product.
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SIS-C/PQC is targeted to aesthetically pleasing appearance and freedom from
visible lesions and, by enhanced attention to basic principles of hygiene, also can
improve keeping quality and minimize contamination by microbial pathogens.
Although not ideal, SIS-C/PQC appears better able than SIS-C or traditional
inspection to meet the characteristics of an effective inspection program.
Moreover, it is the only system of the three that can be readily extended (and
has been extended by industry) to detect and reduce contamination or to
become part of a full-fledged HACCP program that addresses all the desirable
characteristics of products in a comprehensive prevention program rather than as
a result of after-the-fact detection efforts. Although in-plant HACCP programs
cannot decrease intestinal colonization of live cattle by microorganisms, such as
Salmonella, which are pathogenic in humans, they can minimize public risk by
decreasing the degree to which carcasses are contaminated with intestinal
contents and exogenous fecal debris.
STS-C alone, i.e., WIthOUt amp, Should be used only as a temporal transition
phase no longer than ~ year as the plants move from traditional inspection to
SIS-C~QC, because there is no logical basis for making PQC optional for plants
operating at slow speeds, as suggested by FSIS. In this l-year SIS-C transition
period, the following must be achieved:
_% ~ _
Management and employees of both FSIS and the plant must learn to
understand and share the goals of the plant PQC program.
Plant personnel must be monitored closely by FSIS to ensure that the PQC
program is strictly implemented as designed.
Objective, easily understandable, and statistically analyzable data on finished
product standards in the plant must be presented to inspectors to assure them
that the system works and that plant employees are capable of implementing it.
o SIS-C alone, i.e., without PQC, should not be used beyond the transition period
because it includes less government oversight.
0 The scientific bases of traditional meat inspection, SIS-C, and SIS-C~QC are
inadequate or nonexistent. However? FSIS now has access to data from its own
studies and the experiences of the five pilot SIS-C plants, including chemical and
heavy metal analysis, to design an improved system of inspection based on the
proposed rule.
o FSIS should regularly publish data in the scientific literature so that its work and
conclusions can be scrutinized by peers and other experts outside the agency.
The Wesson Study, for example, could have been submitted for publication in
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peer-reviewed scientific literature instead of being published as an agency
monograph without extramural review.
o
o
o
SIS-C and SIS-C/PQC are restricted to fed steers and heifers--the healthiest
portion of the cattle population. Traditional inspection will continue to be used
for cull dairy cows and veal calves, which present the greatest risks from
microbial and chemical contamination, even though this system is not able to
protect consumers from these factors. FSIS should enhance its inspection
procedures and microbial/chemical analyses in the traditional system and
establish compulsory finished product standards to ensure that animals other
than steers and heifers will yield products with characteristics as close as possible
to those described above.
FSIS should tailor its inspection and analysis in a muititiered system based on
the degree of risk to the public's health presented by any one plant. For
example:
Plants with traditional inspection would be given increased FSIS monitoring of
contamination by spoilage and pathogenic microorganisms and chemicals.
Plants with a HACCP system covering all desirable product attributes would be
· . · · -
g~ven minima Inspection.
Plants with STS-C/PQC would have greater FSTS monitoring of contamination by
spoilage and pathogenic microorganisms and chemicals, but decreased monitoring
for visual defects.
Plants with SIS-C (in a 1-year transition period) would receive increased FSTS
monitoring of all desirable product attributes.
In the I-year period of transition from SIS-C to SIS-C/PQC, the purpose of
increased monitoring of ideal product attributes would be twofold:
to increase the level of confidence of inspectors in the competence of plant
employees by providing objective, statistically analyzable data and
to monitor plant employees more closely in the intensive training/transitional
phase.
FSTS should seek advice from an expert consultant group on ways to improve
communications with and understanding by its field inspectors, especially in the
philosophy of food safety. Verbal and written testimony indicates that a major
communication problem exists between FSIS management and field staff (see
Appendix E).
33
Representative terms from entire chapter:
traditional inspection
