Field Operations: The Heart and Soul of FSIS

Good morning. It is a pleasure to be here with you today and have an opportunity to discuss in detail some of the important issues facing the Food Safety and Inspection Service. As anxious as I am to share some of my views with you, I also look forward to hearing your suggestions, ideas or recommendations for how we can all better do our jobs.

I have always believed in frank and open discussion and that is my hope for this morning as well. All of us, in the course of our work, need to be inclusive in the way we perform for the Agency. I think it is essential that we have a firm grasp of not only our own individual performance but of the work being done by our employees. We also must be aware of the views of the industries we regulate even though we will not always agree with them. No one can do this job in a vacuum or a silo. Knowing the landscape is the key to working efficiently and effectively.

Embrace Public Health

By now, each of you has heard or read about my goal for FSIS. And that is for us to be a world-class, public-health agency that is a model for all other public health institutions to emulate. I am here today to say that it is time for us to embrace this goal in EVERYTHING we do, and not just on a philosophical basis. Protecting the public health is our number one priority. That is not negotiable and it must be reflected consistently each and every day we come to work whether in the field or in Washington. Protecting public health is more than filling out forms or reports. It involves taking responsibility and appropriate action; not just taking notes.

Today, I am here to challenge each of you to think, act and respond like the public health officials that you are. We must also be certain that this same mindset is present throughout the workforce, regardless of location, title or pay grade. I recognize this is indeed a challenge but it’s one that we can and must meet.

Last year, in a speech to the American Meat Institute, I challenged industry to become experts at HACCP. Everything they needed to learn in order to perform properly is available in our regs and directives. It is all out there and written in black and white. I distinctly remember saying, "Just as there is no room for junk science; there is also no room for junk HACCP." Well, you can add another phrase to the quote and that would be "and there is also no room for junk inspection."

I think it is fair to say that HACCP has matured to the point where we should all be comfortable with the system approach that is its foundation. We are well beyond the design and implementation phases. Instead, we are in the enforcement stage. We are responsible for making sure that industry is successfully operating under this design. There should be no more surprises or mysteries about HACCP.

Yet we know that there are some plants out there that take a minimalist or cut-and-paste approach to HACCP, tossing aside their plans to collect dust on a shelf. The time for ignorance and excuses is over. Plants must have a living, vibrant HACCP plan in place that works and is validated. We can not tolerate facilities that do NOT even recognize that the risk of pathogens exists.

While plants must take responsibility for producing safe food, it is our responsibility to make sure that they do.

When they do not take responsibility then we must take swift and appropriate action to correct the deficiencies.

Let me give you a fairly simple example of what we expect of you as public health officials. We know that many plants conduct their own laboratory testing. However, when they confirm a positive the emphasis is on diverting the product or calling it back. Well, that may be the correct course of action but there is something obvious being missed.

If a plant is getting positives then it is a symptom that something is wrong with their process. Their system is broken and it needs to be repaired. If they are failing then we, as the regulatory authority, need to be ready to take decisive action. The fix needs to be based on science and its effectiveness must be scientifically validated, even if it requires plants employing outside, scientific expertise that is otherwise not available in the affected company.

In my AMI remarks, I also said that I would hold us accountable for getting the job done just as I would hold industry accountable for its part. I am here to re-emphasize that each of you is accountable not only for your actions but for those of your employees. Yes, we are holding industry to a high standard but no higher than we have set for ourselves. Any failure in the system reflects poorly on us all. And lately, there have been too many illogical and unnecessary failures.

I understand and appreciate that each of us is fallible and that, even with the best of intentions, an occasional, honest mistake will be made. I accept that. But what is not acceptable is when a failure occurs because of ignorance or incompetence for which there is no excuse.

Historical Perspective

For too long, this agency has been the target of criticism from many competing quarters. When did it become so easy to criticize FSIS? Why do we always have the bull’s eye on our backs?

As many of you well know, I have worked in the public health field for my entire career and it didn’t use to be like this. When did it change? You could look back more than a decade to the "60 Minutes" broadcast that introduced the phrase "fecal soup" into the vernacular. But I don’t think it is necessarily one single event that brought us to this stage in our history.

Granted, we are an attractive target as food safety has become politicized over the past decade or more. As our profile has risen, so have the stakes.

Predictably, others use the Agency to further their agenda whether it is industry, advocacy groups, unions, the media or any combination of the above. In fact, they all seemed to merge together in an October 10^th New York Times article on the failure of HACCP and our own inadequacies.

While food safety has become a hot-button issue nationally, too often we have provided our critics with fodder to fuel the flames of controversy.

If you believe everything you read or hear in the media, then you would think FSIS has an unending capacity for error and misstep. This perception must change in a number of ways but there are some immediate things that need to happen.

First, we must instill a sense of pride in our workforce. And that starts with everyone in this room being proud of where you work. This is not just a job. In order to work here, I believe each of us must have a deep and genuine appreciation for our public responsibility.

Second, I am tired of reading articles quoting our inspectors as saying we don’t have the authority to take action against a plant that is patently violating its own HACCP plan or our regulations or statutes. Everyone in this room knows we have the authority, as well as the responsibility, to take action against violators and it is imperative that the entire workforce knows it as well.

If inspectors are not familiar with the core rules and regulations under which we operate then you have a number of choices: you can replace them; reassign them; or retrain them. Doing nothing is not one of your options. Our workforce must know: Inspection must be suspended when there are major failures in a plant. We are there, in the first place, to protect the American public and not the feelings of a shift supervisor or plant official. These discussions with industry are not the Geneva Peace Talks.

Yes, we have to be reasonable and fair but as public health officials we also have to be decisive, effective and thorough.

Too much is falling through the cracks. Things must change in the field as we can not go on like this indefinitely. Once a perception takes hold, whether accurate or false, it begins a life of its own. We not only need to make actual changes in how we work and our effectiveness; we must also destroy the negative perceptions about us.

Once and for all, we must bury this notion that we do not have enough authority or we are not accountable for public health. Those who do not believe this, or do not act on our given authority, will be held accountable from here on out. There is no excuse to allow plants to continue operating when problems abound. I do not want to hear or read our inspectors say that "we can’t shut a plant down." We can and we must make that clear across the board. There should be no question about what to do when we need to suspend or withdraw inspection.

Third, if something is going wrong then each employee should know how to act within our framework immediately or know to ask for guidance if he or she is uncertain about what course of action to take. Employees should be empowered to ask for help when they face uncertainty and that empowerment can only come from you.

But common sense plays a role too.

Is it such a stretch of the imagination to piece together that when a plant embarks on a major construction project that it has significantly changed the environment in which it operates and, therefore, needs to re-assess its HACCP plan to account for the dramatic environmental change?

Or when animals are dying in large numbers in transporters awaiting slaughter – day after day -- that there may be something inhumane about these losses and it is our responsibility to intervene?

Or isn’t it likely that something is amiss in a plant that gets a lot of positives for E. coli O157:H7 and that maybe we should do something about it on a system-wide basis?

I don’t think anyone needs an advanced degree to determine that something may be wrong in these cases. We must let common sense, and the clear authorities under which we regulate, dictate what we do to protect public health.

Each of you is a leader at this Agency and, as leaders, we are all bound, not only to my public health vision, but to our duty to the American people. We live in a world where one day we at FSIS may be on the front lines in the war on terror. These are not hollow words. Our mission is clear. To personalize it, we are all here to protect our families, friends and loved ones as well. Each day, we should leave our offices believing everything possible has been done to make our food supply safe and wholesome. It is unconscionable to walk out of a plant with this obligation in question.

I recognize that there is also a persistent belief that the problems within the FSIS workforce are due to inherent inadequacies in our Washington headquarters. Well, we in Washington are held accountable as well and share in each and every shortcoming. The higher a problem rises the louder and more visible it becomes.

There is no vested or inferred interest on the part of those of us in Washington to having us look bad as an Agency. None.

In fact, we are the magnet for the recriminations and the recipients of the displeasure that may come as a result of any failure whether from the Department, the White House or Congress. Trust me; you do not want to be the one that has to sit before a Congressional subcommittee or the Secretary of Agriculture and explain, yet again, why something went wrong at FSIS or why children got sick from bad meat.

Earlier, I mentioned that I want to hear your views and we have set time aside for that as well. However, we have gone to, and are continuing to go to, great lengths to improve workforce training, make directives as understandable as possible and provide you with the resources you need.

If there is more that we can be doing then I want to hear it today. But what I don’t want to hear are excuses such as:

• "We don’t have the time;"
• "I didn’t know the regulation;"
• "My supervisor wouldn’t let me;" or
• "Washington wouldn’t let me."

Ultimately, you run out of excuses when going down the road of irresponsibility.

Legal Liability

I am also here today to tell you we are doing everything possible to make sure that you have all the tools you need to ensure that public health is being protected. Along with Agriculture Secretary Ann Veneman, the FSIS leadership team is working very hard to put in place an indemnification coverage plan to protect the workforce from nuisance lawsuits from falsely aggrieved companies. The legal pressures directed against us are misguided and unwarranted when we are operating within our jurisdiction and under our statutes.

I believe it is vital to our mission of maintaining public health for our employees to do their job properly without legal harassment and nuisance. You can be sure that we will have an indemnification plan in place shortly.

Let me address another issue head on. There are all manner of skill sets that are required to effectively lead this Agency from top to bottom.

Unfortunately, there is also a sense of entitlement among some that only DVMs can do certain jobs whether in Washington or in the field.

In reality, the people that can "do" the job are the ones who are accountable and respond properly to the challenges; not just those with a particular degree hanging on the wall. I spoke earlier of accountability and knowing whether your employees are performing as needed.

Accountability and knowledge are the hallmarks of a great manager and in order to run an Agency with 10,000 employees we need to have great managers. There will be no privileged class at FSIS. I believe we have assembled an excellent management team with a diverse set of knowledge, skills and abilities and we can overcome our challenges.

That is also one of the reasons we expanded our Memorandum of Understanding with the Public Health Service’s Commissioned Officer Corp.

The officers assigned to FSIS have a wide range of skills and talent that will serve us well in our public health mission whether they are physicians, nurses, microbiologists or veterinarians.

We are also about to advertise for an FSIS Ombudsman and believe this position will be a valuable asset to our employees as well as to industry. I encourage you in the field, who are interested, to apply for this job.

I would prefer that the person selected as Ombudsman have some experience in a plant or District that will bring that point of view to this position.

Hopefully, the Ombudsman will serve as a trip wire and provide us with notice well in advance of an emerging problem or frustration that is not getting the appropriate attention through normal channels.

I promised at the outset to be frank with you. We are together on this journey. Honesty certainly suits this occasion. But this session would not be complete without hearing your thoughts. What can we do to operate more effectively? We have announced numerous training initiatives that are more accessible and coherent than ever. But ask yourselves whether we need to do more or do something different?

How do we collectively drive home the importance of accountability and make it work? How can we better instill a sense of pride in our workforce that will make FSIS employees know, and believe, that what we do is more than just a job? Transforming FSIS into a world-class, public-health agency that is a model for others is a start but I want each of our employees to share our sense of public responsibility and take protecting public health seriously.

I think that through cooperation we can all rise to the challenge before us. But we are living at a time when the stakes and standards have never been higher.

No employee wants to see our public health vision realized more than I and I want that rising tide to benefit us all. Thank you for your patience and I look forward to hearing your views.