In 1997, FSIS, first announced plans in the " Pathogen Reduction; Hazard Analysis and Critical Control Point Systems" (PR/HACCP) final rule (61FR 38806; July 25, 1996) to develop a project and test new models for inspecting certain meat and poultry products. The inspection models project was announced in a June 10, 1997, Federal Register notice, "HACCP-Based Meat and Poultry Inspection Concepts'' requesting public comments on the design and development of new inspection models for slaughter and processing under HACCP systems of young, healthy, uniform animals (62 FR 31553).

There were also numerous public meetings held to solicit public input and comment on the project.

Based on the responses to the Federal Register Notice and input from public meetings, FSIS developed inspection models for the selected market classes and made slaughter process control an industry responsibility subject to FSIS carcass and verification inspection. The models would enable FSIS to:

• maintain and enhance the food safety and other consumer protection benefits of the current carcass inspection system;
• effectively and efficiently oversee, evaluate, and verify industry implementation of the PR/HACCP regulations.

• In 1997, FSIS, first announced plans in the " Pathogen Reduction; Hazard Analysis and Critical Control Point Systems" (PR/HACCP) final rule (61FR 38806; July 25, 1996) to develop a project and test new models for inspecting certain meat and poultry products. The inspection models project was announced in a June 10, 1997, Federal Register notice, "HACCP-Based Meat and Poultry Inspection Concepts'' requesting public comments on the design and development of new inspection models for slaughter and processing under HACCP systems of young, healthy, uniform animals (62 FR 31553).

  There were also numerous public meetings held to solicit public input and comment on the project.

  Based on the responses to the Federal Register Notice and input from public meetings, FSIS developed inspection models for the selected market classes and made slaughter process control an industry responsibility subject to FSIS carcass and verification inspection. The models would enable FSIS to:

• maintain and enhance the food safety and other consumer protection benefits of the current carcass inspection system;
• effectively and efficiently oversee, evaluate, and verify industry implementation of the PR/HACCP regulations.

The HACCP-Based Inspection Models Project is composed of two phases: (1) the Baseline Phase; and (2) the Models Phase.

During the Baseline phase the Research Triangle Institute (RTI), an independent consulting firm, collects organoleptic and microbial data, which indicates the accomplishments of the plant's current traditional inspection system. The Models phase consists of a Transition period and a second data collection period. At the end of the Transition period, when both the volunteer plants and the Agency have made any necessary adjustments to procedures, data are again collected in order to evaluate the achievements of the Models phase and the plants continue to operate under the new procedures as Model plants.

Additional collected data is added to the existing data to establish national performance standards for plants slaughtering each of the market classes included in the project.

The Research Triangle Institute (RTI) collected Baseline data in 16 young chicken plants, 5 market hog plants, and 5 young turkey plants between 1998 and 2000. Over a six-week period, 300 microbial samples were collected and analyzed for Salmonella and for Generic E. Coli in each plant. Similarly in each plant, 2000 carcasses were scored for a variety of organoleptic defects, over a five week period.

FSIS developed and published performance standards on November 2, 2000, for each species involved in the project using the collected data. The performance standards specific for each plant participating in the project provided a scientifically valid measure by which changes in food safety and other consumer protection data can be assessed.

The project involves new roles and responsibilities for participating plants. Each plant must modify its HACCP plan to include at least one critical control point addressing food safety diseases and conditions. In addition, each plant developed a process control plan to address other consumer protection concerns that are not food safety related, such as removing bruises and other quality defects.

New roles for FSIS inspectors have also been developed. To meet these roles inspectors are given two weeks of HACCP training and one week of carcass and verification training. Supervisors are also trained in Statistical Process Control.

With HACCP and other process control programs in place, plants will identify and remove from the slaughter production process carcasses and parts of carcasses that are unacceptable because they are diseased and unwholesome. When volunteer plants assume these process control responsibilities, the FSIS inspection team will be able to implement new slaughter inspection procedures that verify the effectiveness of the plant's modified HACCP and new process control plans.

In pilot plants, slaughter inspection will consist of two types of procedures: carcass inspection and verification inspection.

Carcass inspection accomplishes post-mortem inspection of each carcass after the plant has completed carcass sorting activities. The carcass inspector is stationed on the line at a fixed location and completes the critical determination for application of the marks of inspection.

The verification inspector takes samples of products and plant records and carefully examines them. Verification inspection focuses on the HACCP and process control plans and whether the plant is meeting relevant carcass performance standards.

The Research Triangle Institute (RTI) collected data again after the plants and FSIS had initiated the models phase. RTI has collected microbial and organoleptic models data in 16 young chicken plants and 3 market hog plants from September of 2000 to December of 2001.

FSIS has also collected verification data on the project when a plant enters the model phase. As of this date, FSIS has collected over 1 million samples in Food Safety and 350 thousand samples for the Other Consumer Protection categories. All data collected shows improvement.

Currently the project has 19 Young Chicken plants, 3 Market Hog Plants, and 2 Young Turkey Plant in the models phase of the project. The pending list of Young Chicken plants to enter the project has increased to over 30 plants. Also another Market Hog plant as well as 2 more Young Turkey plants will enter the project in early 2002.

In September 2001 the American Federation of Government Employees (AFGE) filed an appeal to the District Court decision and a new panel of judges were appointed as panel members for the case. The Agency and AFGE also filed briefs.

On Friday, January 11, 2002, the United States Court of Appeals for the District Circuit heard oral arguments in the case of the AFGE v. Ann Veneman, et al. (i.e., the Department of Agriculture). A Justice Department attorney represented FSIS arguing that the HIMP system has been redesigned and is in compliance with the statutes and the prior opinion of the court. The Agency is awaiting the ruling of the court and has been advised that their decision could be rendered within a few months.

FSIS is continuing the HACCP-Based Models Project because the Agency believes that the project has been shown to improve food safety and other consumer protections and expects to publish a proposed rule. The new models capitalize on the food safety and other consumer protection gains garnered by the HIMP project thus far, while still meeting the demands of the inspection laws. Under the Models Project, FSIS is requiring improvements in the protections that are currently achieved under the traditional inspection. Data collected from this project show significant improvements in both food safety and other consumer protections.

Under the agreement the Agency has with the National Joint Council of Food Inspection Locals, the maximum number of plants participating in the pilot is limited to 20 young chicken plants, 5 market hog plants, and 5 young turkey plants. Presently, there are 20 young chicken plants, five market hog plants, and five young turkey plants participating.

MARKET HOGS
Establishment	Company
M85B	Swift Pork Company Beardstown, IL
M360+P360	Smithfield Packaged Meats Corp. Vernon, CA
M791+P791+V791	Clemens Food Group, LLC Hatfield, PA
M1620	Quality Pork Processors Austin, MN
M46491+P46491	WholeStone Farms Cooperative, Inc. Fremont, NE

Access the latest reports that evaluate FSIS findings in market hog slaughter establishments participating in the Hazard Analysis and Critical Control Point Inspection Models Project (HIMP).

• Evaluation of HACCP Inspection Models Project (HIMP) for Market Hogs (Nov 2014; PDF Only)
• Evaluation of HACCP Inspection Models Project (HIMP) (Aug 2011; PDF Only)

• HACCP-Based Inspection Models Project: Results of Baseline and Models Redesign Data Collection
  Presented to the National Advisory Committee on Meat and Poultry Inspection on Jun 5, 2002, by Donald W. Anderson.
• HACCP-Based Inspection Models Project: FSIS Results of Models Verification Testing
  Presented to the National Advisory Committee on Meat and Poultry Inspection on June 5, 2002, by Dr. Columb Rigney.
• Transcript of Meeting on HACCP-Based Inspection Models Project held Mar 30, 2000 (PDF only)

Statement by Dr. Elsa Murano: HACCP-based Inspection Models Project (HIMP) (Apr 1, 2002)

 “On Friday, a three-judge panel from the U.S. Court of Appeals for the District of Columbia unanimously ruled that USDA's modified HACCP-based Inspection Models Project (HIMP) fully complies with the requirements of the federal meat and poultry inspection laws. 

“This pilot project is a new idea, designed to modernize on-line slaughter inspection.  Through HIMP, information on product defects is gathered in real-time, helping plants make immediate corrections when problems occur in their processes.  

“HIMP is one program in our efforts to continually improve and enhance our meat and poultry inspection system.   This court decision will allow us to try new ideas that are based on science and provide a safer meat and poultry supply for Americans.”

New Directions in Food Safety Policy

Remarks prepared for delivery by Dr. Elsa Murano, Under Secretary for Food Safety, before the National Turkey Federation, Jan 15, 2002, New Orleans, LA.

Good morning. It is a pleasure to be with you to talk about new directions in food safety policy. I hope you have had a successful meeting thus far, and let me offer my best wishes for the New Year.

First, let me say what an honor it is to have been selected by President Bush and Secretary Veneman to serve as Under Secretary for Food Safety. To have the chance to really make a difference in the food safety arena is a golden opportunity that I do not take lightly.

When I began the job last fall, I indicated that I would spend some time assessing where we are and what has been accomplished before deciding where we needed to go.

I have determined that we have a strong food safety infrastructure. Within FSIS alone, more than 7,600 inspection personnel verify the safety of meat, poultry, and egg products nationwide. Combined with the resources of other government agencies at the Federal, State and local levels, we have an extensive system of protection.

In addition to this strong workforce, the Pathogen Reduction and HACCP rule has been implemented nationwide, in plants of all sizes. As you know, this rule is a major achievement in that it represents a significant modernization in the way meat and poultry are processed, with emphasis on prevention and control of food borne hazards.

The tragic events of September 11^th certainly have highlighted the importance of maintaining and improving this infrastructure, and of adapting it to new food safety threats as they arise. Intentional harm to our food supply is a unique situation, one that we never envisioned would take center stage in our country.

Yet, whether intentional or unintentional, threats to the safety of our food supply can only be addressed by a strong infrastructure, with systems in place to prevent contamination and address hazards. Thus, we must continue to strengthen this infrastructure if we are to maintain consumer confidence in our food supply and our regulatory programs.

To achieve this, I firmly believe that we need a science-based approach, and my goal as Under Secretary for Food Safety is to see real progress made in this area. We are entering a new stage in the development of our food safety programs, and we must begin by defining in more detail what we mean by science-based.

HACCP is at the core of this approach. The success of the Pathogen Reduction/HACCP rule has been proven in a number of ways.

First, Salmonella testing data shows that since the implementation of the rule, the prevalence of this pathogen has significantly decreased in all product categories, including turkey.

Secondly, small and very small plants have improved in their business practices, having increased the number of audits they perform on suppliers by 20%.

Thirdly, data from the Centers for Disease Control show significant reductions in foodborne illness, which CDC has stated are likely due to implementation of the rule. And fourthly, according to the USDA’s Economic Research Service, the net economic impact of the rule has been an increase of $9.3 billion in household income (1993 dollars) due to reduction in foodborne illness. But we must take HACCP to a new level, and this can be done in numerous ways.

Performance Standards

For example, performance standards are an important verification tool for HACCP. This is not a new message—you have heard it before. And FSIS has many performance standards that are enforced to address product safety, including a zero-tolerance for pathogens in ready-to-eat products, and performance standards for Salmonella at slaughter plants.

However, the recent debate over the Salmonella performance standards in grinding operations, and how they should be enforced, illustrates the type of tough questions that remain. Science tells us that performance standards are needed, since they serve as a measure of the success of food safety programs. However, it is not enough to set just any performance standard—for the wrong standard can mislead us into believing that systems designed to control hazards are working when maybe they are not. Thus, we must set performance standards that are reliable, and that are accurate in terms of reflecting when control of hazards has been lost. Only with such standards can enforcement be justified.

These tough issues have led us to seek input from the scientific community. Both the National Advisory Committee on Microbiological Criteria for Foods and the National Academy of Sciences are studying the issue of performance standards, and I am anxiously awaiting their results. The Advisory Committee will be meeting next week, and I invite you to attend the public sessions to learn about their conclusions and recommendations regarding Salmonella performance standards specifically, as well as other related issues.

The work of these expert groups is more than just an academic exercise. Their expert opinion will go a long way towards helping us determine how to select the right standards, and what compliance really means in terms of public safety.

I must emphasize that Salmonella testing in grinding operations has not stopped. We are using it as one way to verify whether either the HACCP or sanitation standard operating procedures implemented by industry are successfully controlling hazards reasonably likely to occur. As you know, our inspectors are charged with such verification activities. Thus, record reviews, visual monitoring of plant personnel, and testing for Salmonella are the tools they will use to determine whether HACCP and sanitation systems are working.

Workforce of the Future

It is because of the important role FSIS employees play that FSIS has underway a Workforce of the Future Initiative. A HACCP-based food safety system requires an inspection workforce that is well trained and prepared to protect the public health, from supervisors to inspectors on the slaughter line.

FSIS needs to increase the proportion of public health and scientific professionals and make available more frontline personnel with scientific and technical expertise in our meat and poultry facilities.

As an example, we recently introduced the consumer safety officer (CSO) occupational series into our workforce. In addition to the 35 already selected, we are requesting an additional 75 CSOs as part of our FY 2002 budget. CSOs will verify that plants have validated their HACCP plans as well as sanitation and microbiological testing programs. They will have the primary responsibility for conducting in-depth reviews on plants that have shown, through various verification activities, that a review of their HACCP plan or SSOPs is warranted.

We are also looking to improve the role of veterinarians in FSIS. The report of a blue-ribbon task force on the future role of veterinarians was published last year. Dr. Bonnie Buntain, who has been selected as FSIS’ Chief Veterinarian, will lead the implementation of the task force’s report, which includes new strategies to recruit and retain these valuable professionals.

These are important steps, but not enough. I’m afraid we’re leaving behind the 6,000 or so line inspectors who are so important to our mission. They, too, must be able to operate in the new, more science-based FSIS. They need to understand HACCP and how it enhances their authority. We intend to review training procedures for plant inspectors and enhance HACCP training to ensure that inspectors clearly understand their responsibilities in the wake of the Supreme Beef court decision.

Novel Technologies

In addition to performance standards and workforce modernization, a third area I believe deserves more attention is the application of novel technologies to reduce contamination of meat and poultry products. This is necessary to make a quantum leap to the next level of consumer protection.

I noticed that one of the sessions on your agenda addressed new technologies in pathogen reduction, so I applaud your interest and your initiative in continuing to inform your members of ways in which they can significantly improve the safety of their products.

There are many technologies available, but they differ in their effectiveness, ease of use, reliability, and cost. Partnerships between industry and academia are crucial in order to continue to increase the arsenal of weapons against food borne hazards.

As an Agency, FSIS needs to do more to promote the application of technologies that have been validated as effective in reducing pathogens. We must not shy away from delivering this message whenever possible, and from being proactive in encouraging industry to seek approval for new decontamination methods. How we go about all this requires some discussion. For example, should FSIS mandate that interventions be included in HACCP plans for plants that have trouble meeting HACCP goals? I welcome your comments.

Risk Assessment

Risk assessment is another tool that will enable us to use a science-based approach in our decision-making. Now that we are gaining more experience in this area, we can better use the data currently generated by FSIS through its regulatory programs to formulate sound policy.

Where information is lacking, we must work with researchers to fill the gaps. The analyses we make must be complete, and the models that are generated must stand the rigor of the peer-review process.

HIMP

In addition to moving forward with HACCP, we are continuing with novel ideas such as HIMP to address the on-line slaughter process. I like to think of HIMP as a total food safety and process control system, and I appreciate the turkey industry’s active participation in this pilot project. As you know, under HIMP, volunteer plants take a more active role in the carcass sorting process, while our inspectors concentrate on more intense inspection and verification activities. The true value of this pilot project is that it is demonstrating how real-time data-gathering can help plants maintain control over product, and how increasing the time that inspectors can spend in verification activities is improving the use of their abilities and expertise in detecting deviations.

As you also know, HIMP is still in its infancy, with FSIS continuing to evaluate it and tweak it to improve it. Just last month, we made changes regarding the point along the processing line at which re-worked product should be reintroduced. With the changes, the plant personnel now place the re-worked carcasses just before they pass by our inspector so that he or she can inspect before they proceed through the line.

FSIS has received numerous comments through public meetings and Federal Register notices, and the General Accounting Office is about to release its own review of HIMP. We welcome all of these comments and are always willing to consider changes that will result in improvements.

For example, this year, we will publish a Federal Register notice the HIMP program for young chickens, and the proposal will include the following improvements.

First, we will propose mandating formalized training for plant personnel that participate in HIMP, something that the Agency had considered independently of the GAO recommendations. We welcome your input on how to implement such a program.

Second, we will propose phasing in the implementation of HIMP over time. The program would also be voluntary, and we would select plants based on certain criteria. This is an idea we have been entertaining for a while, and are glad to learn that it is included in the GAO recommendations.

Third, we would propose that participating plants be required to use statistical process control to control quality defects. Statistical process control does not apply to food safety defects because they already are set at zero.

In addition to these proposals, we will be looking for ways to improve how we receive input from our employees on the program. FSIS employees have provided valuable input during the course of the project, and we want this to continue.

As always, we seek the input of all interested parties, and vow to continue with a process that is transparent and inclusive. We intend to hold a public meeting to present new data from the project and to solicit additional input, so we very much invite your participation.

Biosecurity

The last topic I want to address has been at the top of our agenda since September 11^th—biosecurity. It is not a new issue but has received heightened attention because of the tragic events of September 11^th , and the possibility that the food supply could be the focus of a terrorist act. I like to remind audiences, however, that keeping contaminants out of the food supply has been the job of industry and government for decades.

I constantly get asked the question, “What is USDA doing for biosecurity that’s new?” My answer is that a lot of what USDA needs to do is already being done. We have a long history of success in dealing with food emergencies. That is the result of the strong infrastructure already in place to protect animal health and the public health.

Despite the strong existing system, we know that even a localized event that does not cause significant harm could greatly undermine consumer confidence nationwide. That is why USDA is taking a multi-faceted approach that includes both short- and long-term strategies.

USDA will receive $367 million to strengthen essential programs and services related to biosecurity issues, with some of those funds being earmarked specifically to FSIS.

A critical part of our activities is improved coordination at all levels of government and with our stakeholders. USDA has formed its own Homeland Security Council to coordinate activities with Governor Ridge’s Office of Homeland Security. Within this group, the Under Secretary for Marketing and Regulatory Programs and I are co-chairs of a sub-council charged with protecting the food supply and agricultural production.

This is basically the same group formerly known as FERRET—the Food Emergency Rapid Response and Evaluation Team—that you may have heard of prior to September 11^th. It is charged with coordinating activities among the various mission areas within USDA so we can better prepare and respond to terrorist activities that may affect no only food, but also agriculture.

USDA also is working to strengthen its relationship with food safety agencies outside USDA. Given the fragmentation of our food inspection system in the United States, real cooperation among agencies is critical.

My office is committed to achieving such cooperation by working with the Food and Drug Administration, the Centers for Disease Control and Prevention, the Environmental Protection Agency, as well as state and local health agencies, to share information and strengthen coordination of activities from farm to table.

For example, we are working on a couple of initiatives with FDA that will be truly groundbreaking in this area, and hope to have an announcement in the near future, once the details are worked out.

One initiative I can mention is the establishment of the Food Threat Preparedness Network, also known as PrepNet, which is co-chaired by the Administrator of FSIS and the Director of the Center for Food Safety and Applied Nutrition at FDA. Members include EPA, APHIS, DOD, CDC, and state and local health agencies.

The focus of this new group is preparedness as well as rapid response. PrepNet is coordinating the application of respective statutory authorities where appropriate. In addition, it is conducting an assessment of needs with plans to fill the gaps. The sharing of laboratory capabilities and expertise with specific food borne hazards is also underway. Such joint activities are long overdue, and I am committed to keeping this train moving forward.

You may be wondering how FERRET and PrepNet can cut through the red tape of bureaucracy and get some real work done on biosecurity. Here is where F-BAT comes in. You may have heard about F-BAT—the Food Biosecurity Action Team. It’s the folks within FSIS who do the work of protecting our food supply. This is something they’ve done as part of their duties at FSIS and are now focusing their expertise and experience towards food biosecurity. You might say that F-BAT is the “arms and legs” of FERRET within USDA, and of the intergovernmental entity PrepNet, as it relates to meat and poultry.

In conjunction with F-BAT, FSIS is adding new veterinary medical personnel in the district offices who will serve as points of contact on biosecurity issues in each office as part of their professional responsibilities.

Closing

In closing, you can see that we have a full agenda ahead of us, and I look forward to working with all of you. One thing I do want to make absolutely clear is that FSIS is a public health agency. Such a statement, however, must be backed up with actions. I invite industry as well as consumers to grade us by our accomplishments, and to be participants in the process that guides us to achieve them. I do want to encourage you in the strongest way possible to help us in our efforts towards consumer education, for only with an educated public will food safety truly reach the table.

Redesigned Slaughter Inspection System Improves Food Safety (Jun 7, 2001)

WASHINGTON, June 7, 2001--The U.S. Department of Agriculture's Food Safety and Inspection Service recently announced that the revised design of its HACCP-based inspection models project continues to produce results showing dramatic improvements in food safety and other consumer protections, according to FSIS verification data now available for young chickens.

"The redesigned system of inspection that we are testing has shown marked reductions in defects in young chickens as compared to the traditional inspection system," said Thomas J. Billy, FSIS administrator. "While no food safety or non-food safety defects are acceptable to FSIS, this project is showing important food safety gains."

Under the HACCP-based inspection models project, FSIS has established performance standards for food safety and non-food safety defects that require improved performance by industry. FSIS conducts inspection to ensure that these standards are met and that plants are producing food that is safe and wholesome for consumers. Participating plants must revise or develop new process control systems to meet these new performance standards that address both food safety and other consumer protection concerns.

Under the revised design, FSIS has placed a carcass inspector at a fixed point just before the birds enter the chiller. This inspector is the final government checkpoint for consumer-ready product. FSIS also continues to have an off-line inspector to verify that plants are appropriately handling any problems and to ensure the adequacy of the overall design and execution of the establishment’s HACCP and process control procedures.

Approximately 20 plants that slaughter young chickens, hogs, and turkeys are voluntarily participating in the project, but data from plants operating under the models are available only for young chickens at this time. The poultry data are available for fourteen plants.

Two categories of defects are considered food safety related because they could pose a health hazard to consumers. In these food safety categories, FSIS inspector verification checks found a 99.9 percent reduction in defects over traditional slaughter inspection. All five categories addressing conditions that do not pose a food safety hazard showed improvements with four of the five categories showing a greater than 50 percent reduction in defects.

Research Triangle Institute, an independent consulting firm, continues to collect data assessing the adequacy of the revised design of the models project. Their data is expected to be released later this year.

In order to implement any nationwide changes to the models project, a change in the poultry regulations will be required. FSIS is currently initiating the drafting of a proposed rule in order to begin making these regulatory changes.

FSIS Publishes Performance Standards For HACCP-Based Inspection Models Project (Nov 3, 2000)

WASHINGTON, Nov. 3, 2000--The U.S. Department of Agriculture’s Food Safety and Inspection Service has published performance standards for food safety and non-food safety conditions that slaughter plants participating in the HACCP-based Inspection Models Project must meet. The performance standards for young chickens, which account for the majority of participating plants, were previously released at a public meeting held in March; the standards for young hogs and turkeys have not been released previously.

"This project raises the bar for food safety and other consumer protection concerns and so far the participating plants have been rising to the challenge," said Thomas J. Billy, administrator of USDA’s Food Safety and Inspection Service.

Under the pilot project, which began in 1999, volunteer plants extend Hazard Analysis and Critical Control Point (HACCP) systems to slaughter line activities, which are not now covered under HACCP. Plants sort carcasses to remove food safety and non-food safety conditions and must meet performance standards established by FSIS for these defects. FSIS inspectors conduct on-line carcass inspection and verification inspection to ensure that plants are meeting the standards. Only plants that slaughter young, healthy chickens, hogs, and turkeys are eligible to participate in the pilot project. Up to 30 plants that slaughter young chickens and hogs are currently participating, although fewer than this number are actually testing models at this time. No turkey plants are currently testing the models.

No food safety or non-food safety defects are acceptable to FSIS. While no system is perfect, the models project is an effort to reduce and eliminate defects that pass through traditional inspection. Under the models project, performance standards are based on improving what is achieved under the current, traditional method of inspection. When plants enter the project, they must improve their process in order to meet the new, tougher standards.

Preliminary data from both an independent third party and FSIS in-plant checks indicate that the new system dramatically improves the safety of products and increases overall consumer protection.

The performance standards were published in the Nov. 2 Federal Register. There is no formal comment period for this notice; however, comments are welcomed and should be submitted to FSIS Docket Clerk, Docket #00-042N, U.S. Department of Agriculture, Food Safety and Inspection Service, Room 102 Cotton Annex Building, 300 12th St., S.W., Washington, DC 20250-3700.

Statement by Thomas J. Billy at Press Briefing (Aug 31, 2000)

I would like to thank all of you for coming today to hear about some modifications we have made in the HACCP-Based Inspection Models Project. I continue to be excited about this project and the resulting food safety gains. I believe we have found a solution where FSIS can meet the demands of the Federal Meat Inspection Act and Poultry Products Inspection Act while continuing to capitalize on the food safety gains garnered by this project.

As FSIS Administrator--and as a consumer--I believe the customer deserves a safer and more wholesome product. When we embarked on the models project, for the first time we measured the accomplishments of the current system. While traditional inspection is good, it could be better. Too many food safety defects are passing through the current inspection system. And, other defects that are not food safety issues but are still unacceptable are also too frequent in our current system. While perfection under any system is impossible, we must strive to improve. I will not accept less--nor should any consumer. The data collected shows that we can do better and therefore we must make every effort to improve our current system.

The models project raises the bar for food safety and other consumer protection concerns. With this pilot project we measured how many defects pass our inspection system, put them into categories, and set pilot performance standards that these plants must achieve. This does not mean that defects unacceptable under the traditional inspection systems are now acceptable. But, under the models project, we are demanding an improvement over what our inspectors are currently achieving. Thus the pilot performance standards are based on the 75th percentile of what is achieved under our current, traditional method of inspection. When plants enter HIMP, they must therefore improve their process in order to meet these new, tougher, standards.

Just as under traditional inspection, federally funded FSIS inspectors are continuously present and inspect each carcass. And, the pilot project includes more verification to ensure standards are met, including four times as many food safety checks.

Plants have the responsibility to meet the pilot performance standards, and our inspectors have the responsibility and authority to ensure that they do so.

Thus far under this project we have made significant food safety gains. Last month, we released some data from RTI, an independent third party, that show significant gains. We also have here today some new data based on FSIS in-plant checks. Our own FSIS inspectors in seven HIMP plants recorded these data. It is taken over a much longer time frame than the RTI data we released last month and therefore the numbers reflect not only substantial but improved performance in most areas.

In the sixteen plants included in baseline the traditional system achieved a 0.1 percent rate for infectious conditions and 1.5 percent rate for fecal contamination. Despite these findings, we set the tolerance for food safety at zero. Under the models project in which plant sorters address these defects with FSIS oversight and verification inspection, those numbers have been reduced to an average of nearly zero and 0.2 percent respectively.

For OCP-1—animal diseases such as airsacculitis—the performance standard based on traditional inspection is set at 1.7 percent. FSIS inspector data shows the seven plants are achieving a 0.9 percent rate. In EVERY CATEGORY, important gains have been achieved—the plants are performing better under the pilot project than plants achieved under traditional inspection.

It would be irresponsible to turn away from such marvelous gains.

That said, let me turn to the legal challenges we are facing with this project.

Union leadership challenged FSIS in DC District Court. FSIS initially prevailed, but the decision was overturned on appeal. The decision has been remanded to the original DC District Court. This morning we met with union leadership and lawyers and presented changes we will make to the project to bring the project into compliance with statutory requirements.

In redesigning this project, we wanted to ensure that we did not turn our backs on the important gains achieved, and that our inspection force still has the capability of both inspecting carcasses and checking the plants’ systems. Also, to meet with the appellate court's interpretation of the Federal Meat Inspection Act and Poultry Products Inspection Act, we decided to assign a federal inspector to a fixed position on the line to make critical determinations on each carcass.

We have handed out three charts today, to help you visualize how inspection works under traditional inspection, under the pilot project, and the revisions we have just made.

Under traditional inspection, FSIS inspectors identify and condemn certain abnormal conditions that affect the entire carcass disposition such as septicemia/toxemia and extensive airsacculitis. Establishment personnel are responsible for the identification and removal of all localized (trimmable) conditions included in the finished product standards (FPS). Examples of these conditions are sores, breast blisters, bruises, localized airsacculitis and feathers. Twice each shift, we check 10 birds for zero-tolerance on fecal contamination, and twice each shift we check 10 birds for finished product standards.

Under the initial models project design, inspectors are not tied to a fixed point on the line. Oversight inspectors are mobile and concentrate on where they see problems occurring at any point along the slaughter line. Verification inspection involves removing birds from the line and performing checks for both food safety and other consumer protections. Food Safety checks involve 10 bird sample sets eight times per shift. Inspectors have two-way radios and communicate with each other when problems with the plant's system are seen. If an inspector sees a possible problem, he or she calls for an immediate test to check the plant process.

Under our revised design, we have placed a carcass inspector at a fixed point just before the birds go into the chiller. This inspector will be the final checkpoint for consumer-ready product. We will also continue to have an off-line inspector to verify that plant personnel are appropriately handling any defects and to ensure the overall design and execution of all of the establishments HACCP and process control procedures. We will still be conducting four times as many food safety checks than occur under traditional inspection.

On August 25, 2000, AFGE, on behalf of the National Joint Council of Food Inspection Locals, filed a motion requesting the US District Court to enjoin the models project. If the injunction is granted, inspectors would be reassigned to fixed locations on the slaughter line and would perform traditional inspection duties. FSIS would be forced to revoke existing HIMP related promotions for more than 200 field employees. The agency believes that the demonstrated improvements in food safety under HIMP do not warrant the sweeping action requested by the union. The agency also believes the changes we are discussing today bring the project into compliance with statutory requirements. We expect to begin implementing these changes September 18.

In closing, I want to emphasize that we cannot turn our back on improving inspection. While the union leadership has begun a campaign of misinformation, not all the inspectors in the plants are in agreement. I will quote from an inspector who posted a message on the union web page:

" … If we can further improve our inspection through more micro checks, more food safety checks and the same amount of checks as FPS then what is better. Also the product is now getting sorted more than before; not less and we still have the chance to look at all the carcasses that are on the line. … "

Another inspector said:

"I am entitled to my opinion that we are not serving the American public in the best way by inspecting using an outdated system, whereby we cannot see the microorganisms that are causing 5000 deaths or more a year in this country. …"

I agree. We would not be responsible if we turned our backs on these demonstrated food safety gains.

Statement by Thomas J. Billy at Press Briefing (Jul 19, 2000)

I have scheduled this press briefing to stop what I consider to be a campaign of misinformation. While I recognize that these are harsh words, I cannot allow irresponsible journalism to misrepresent to the public the gains in food safety and other consumer protection concerns that we are achieving.

Reports in the media stating that the Food Safety and Inspection Service is putting out new rules permitting animal carcasses with defects to enter the food supply are absolutely false. The notion that we are now allowing product to bear the mark of inspection that wasn't permitted to bear the mark before, is a plain misrepresentation of the facts. The union leadership misrepresented the facts when talking with the media, and their statements conflict with those we have received from inspectors in the pilot plants who support the new system. If the media had contacted our office to receive our input before publishing these articles, we would have been happy to present the facts. Because they didn’t, I am presenting them now.

We are pilot testing a new system of inspection that raises the bar for food safety and other consumer protection concerns. Before the HACCP-based Inspection Models project began, we had not ever measured the accomplishments of the traditional inspection system we have carried out in slaughter plants since 1906. Now we have, and the data tells us there is plenty of room for improvement. Too many defects are getting through the traditional slaughter inspection system. This includes defects that are food safety related, and defects that are not food safety concerns but that are unacceptable to the public. Consumers deserve better.

With this pilot project, we have put both types of defects—food safety and other consumer protection—into categories, and set performance standards for them that plants must achieve. This does not mean that defects unacceptable under the traditional slaughter inspection system are now acceptable, as has been reported. The things we condemn under traditional slaughter inspection are the same things we condemn under the new system. Just as with the traditional system, FSIS provides continuous inspection under the pilot. The pilot also adds enhanced verification to ensure that these standards are met.

Plants have more responsibility under the new system to ensure their operations are capable of meeting these standards. But it is still our job to inspect, to verify, and to decide what products have earned the mark of inspection. We are not standing on the sidelines watching others play the game.

The new system also allows plants to take advantage of new technology to improve food safety, and that's why we've gotten such good results so far. Dr. Beckman, an inspector-in-charge at one of the pilot plants, who is here today, told me that the plant he is assigned to has made major technological improvements, and the result has been a better product.

If you look at the preliminary data we have analyzed, some of which is represented on this chart, you can see the promising potential of the new system we have designed.

For example:

• For the food safety 1 category, the new system resulted in a 100 percent decrease in the number of defects.
• For the food safety 2 category, under the pilot, defects were reduced by 92 percent.
• For the other consumer protection category one, defects were reduced by 45 percent.

These are spectacular results, and additional data is presented in the backgrounder we have available here today.

In addition, we collected Salmonella data to compare results to the current performance standards that were established under the Pathogen Reduction and HACCP final rule. You will recall that we reported our second year results for large plants in March 2000, and the national Salmonella prevalence for young chickens was 10.3 percent. For the seven poultry plants operating under the new system for which we have complete data, the Salmonella prevalence was 5.5 percent. This is significantly below the performance standard of 20 percent, and below the prevalence achieved so far under HACCP. It demonstrates that FSIS' strategy to improve food safety is working.

The data from the seven plants show that our effort to raise the bar on other consumer protection concerns is working as well. It is our public health and regulatory obligation to continue our modernization efforts.

This project is still in the pilot testing stages. We have made no permanent changes, nor have we even proposed permanent changes yet. The reference in the articles that the public has until August 29 to comment on proposed changes related to this project is incorrect.

We have pursued this project through a thoroughly public process, with four public meetings held so far. We indicated right from the start that we are open to comments, and in fact have been receiving them from a variety of sources since June 1997. A number of you have attended each of these meetings. All of our reports and results have been shared with the public and are on our website at www.fsis.usda.gov. When we are ready to go forward with a proposal, we will do so through notice and comment rulemaking.

If you would like more information, I encourage you to talk to plants participating in the project, to our own inspectors-in-charge in pilot plants, and to other organizations to get their viewpoints. We can direct you to individuals who have volunteered to serve as resources.

I will now take questions.

New Slaughter Inspection System Improves Food Safety (Jul 17, 2000)

        WASHINGTON, July 17, 2000--The U.S. Department of Agriculture's Food Safety and Inspection Service announced today that its HACCP-based inspection models project is beginning to produce results showing dramatic improvements in food safety and other consumer protection concerns, according to preliminary data now available for young chickens.

        "What this project is about is getting closer to perfection. The system of inspection that we are testing has reduced food safety defects in young chickens by at least 92 percent in plants that are participating in the project" said Thomas J. Billy, FSIS Administrator. "The data are preliminary, but they are very significant results that we want to share with the public."

        On June 30, a three-judge panel of the U.S. Court of Appeals for the District of Columbia reversed a lower court ruling supporting the project and sent it back for further proceedings.

        "We are very disappointed by the court's decision," said Billy. "The preliminary data show that it is possible to design a system of inspection that is superior to the one currently in place in terms of improving food safety, and we have a public health obligation to continue our modernization efforts." The agency is exploring all options and is continuing the project pending further proceedings.

        Under the HACCP-based inspection models project, FSIS has established performance standards for food safety and non-food safety defects that require improved performance by industry. FSIS conducts continuous inspection with verification to ensure that these standards are met and that products can receive the marks of inspection. Participating plants must revise or develop new process control systems to meet these new performance standards that address both food safety and other consumer protection concerns. Approximately 30 plants that slaughter young chickens, hogs, and turkeys have begun participating in the project, but data from plants operating under the models are available only for young chickens at this time. The poultry data are complete for seven plants, and additional data for for nine additional poultry plants will be forthcoming. The data were collected by Research Triangle Institute, an independent consulting firm.

        Two categories of defects are considered food safety related because they could pose a food safety hazard to consumers. In the first category, which includes septicemia and toxemia, the new system led to a 100 percent reduction in defects in birds that passed inspection. In the second food safety category, which includes fecal contamination, defects were reduced by 92 percent. For the five categories addressing conditions that do not pose a food safety hazard to consumers, improvements were documented in four of the five categories.

        Billy noted that the agency has received messages from both inspectors and veterinarians assigned to plants participating in the project who expressed disappointment with the recent court decision and believe, based on their own experiences, that the new system is superior to the one the Agency is using in all other poultry plants.

        "One veterinarian said that the project was a step forward for inspection. An inspector with 19 years of experience with the agency said the birds she has seen are much cleaner than before, and she would like to see the project continue for the protection of the consumer. Another inspector said simply that 'the system works'."

        A backgrounder with more detailed results is available.

Inaccuracies in Statements and News Articles Concerning the HACCP-Based Inspection Models Project (Jan 2002)

Myth: Under this pilot project, USDA inspectors are no longer inspecting product on the front line, but instead are just monitoring and overseeing plant operations.

Fact: USDA inspectors inspect and make a critical appraisal of each carcass. Carcass inspectors are placed at a fixed location on the slaughter line – just before birds go into the chiller – and continue to play a crucial role in protecting the public health by ensuring the safety of the meat and poultry supply. In addition to the carcass inspector, USDA also has an off-line verification inspector who selects a sample of carcasses and does a hands-on examination to ensure that plant personnel are appropriately handling any defects and to ensure the overall execution of a plant’s procedures.

Myth: The HIMP pilot is producing more contaminated product than is produced under traditional inspection.

Fact: Just as product produced under the HACCP inspection system, meat and poultry produced under the HIMP pilot is subject to the Federal Meat Inspection Act and the Poultry Products Inspection Act and their accompanying regulations. By locating carcass inspectors at the end of each slaughter line, USDA inspectors can and do stop the line when carcasses with fecal contamination or other food safety defects are found. Additionally, under HIMP, USDA inspectors actually conduct more product verification checks – 80 carcasses per line per shift under HIMP as compared to 20 carcasses under traditional inspection – to verify that the inspection system is working as intended.

Myth: The only reason that USDA is going forward with this inspection system is to allow plants to run their production lines faster.

Fact: HIMP creates an environment for innovation with new technologies. USDA is continuing this pilot project because preliminary results have shown marked reductions in food safety and non-food safety defects as compared to traditional inspection. Additionally, over 70% of inspection personnel working in HIMP plants believe that product safety is the same or better than it was under traditional inspection. While line speeds are not regulated under this project, USDA inspectors continue to have the responsibility and authority to step in to correct a situation if they feel that plant personnel are failing to appropriately handle defects and failing to properly execute their Pathogen Reduction/HACCP procedures and/or process control procedures. This may involve stopping the slaughter line.

Myth: Faster line speeds under the pilot project are resulting in product regularly leaving the plants with increased levels of fecal matter.

Fact: Data collected by Research Triangle Institute, an independent consulting firm, as well as verification data collected by USDA, indicate that fecal contamination has dramatically decreased under the HIMP system, as compared to the traditional inspection system. Under the HIMP system, USDA inspectors conduct off-line verification checks for fecal contamination four times more frequently than under traditional inspection. USDA inspectors also inspect each carcass at the end of the slaughter line for fecal contamination and have affected carcasses removed. While no system is perfect, and no food safety or non-food safety defects are acceptable to USDA, the HIMP system has increased the safety of poultry products.

Myth: USDA is moving forward with changing and expanding the HIMP pilot before receiving public comment and publishing proposed rulemaking.

Fact: USDA will not be moving forward with changing and expanding the HIMP pilot prior to rulemaking. USDA also intends to have a public meeting on the pilot project before beginning rulemaking. If additional changes to the pilot project are needed, they will be made. USDA already announced three proposed improvements to strengthen the HIMP pilot, which will be included later this year in proposed rulemaking in the Federal Register. (These improvements include: mandating formalized training for plant personnel that participate in HIMP; phasing in the implementation of HIMP and increasing participation in the HIMP program by allowing plants to volunteer for the project, with participants being required to adhere to specific criteria set by FSIS; and mandating that participating plants use statistical process control for quality defects.) As part of this process, USDA will continue to seek input from all interested parties – including public health, industry, and consumer groups as well as the general public – to strengthen the program. Regulatory changes will only be made when full sets of data have been collected and evaluated, and the data provide a reason for change. Notice and comment rulemaking for each species, with opportunity for open public comment, will be conducted before any changes are made.

Myth: The level of food poisoning in this country indicates that the traditional HACCP system of inspection, upon which the HIMP system is based, is a failure.

Fact: Data indicate that Pathogen Reduction/HACCP is successful in improving the safety of meat and poultry products. FSIS’ data show significant reductions in Salmonella prevalence across all meat and poultry product categories to which the Salmonella performance standards apply. In addition, since the implementation of HACCP, the Centers for Disease Control and Prevention have reported reductions in the incidence of foodborne illness associated with meat and poultry products and several of the pathogens the Agency is targeting.

Myth: USDA had its own inspectors collect project data after realizing that data from the independent contractor were not favorable.

Fact: USDA front-line inspectors collect verification data in HIMP plants daily as part of their regulatory duties. These USDA verification inspectors collect product samples to verify that plant personnel are appropriately handling any defects and to ensure that plants are meeting the performance standards set for the pilot. These verification checks involve data collection. This data has been collected, by in-plant USDA inspectors over a longer time frame than that collected by the contractor. USDA first reported this data on its web site in June 2001.

To date, only partial results from RTI, in 11 out of 16 young chicken plants where RTI collected data, have been released. USDA will base its decisions on this project on complete sets of data from RTI, as well as other sources.

Myth: Problems with the project will continue to grow once the project is incorporated into the inspection system.

Fact: FSIS has been continuously evaluating and making improvements to HIMP. These continuous improvements are succeeding in improving the pilot project. Plants that are permitted to operate under HIMP would be held accountable for meeting the performance standards and all other regulatory requirements.

GAO's Report on the HACCP-Based Inspection Models Project (Jan 2002)

 What is FSIS’ response to the recommendations contained within the GAO report on HIMP?

A: FSIS appreciates that GAO’s intent in its recommendations is to strengthen the Agency’s ongoing efforts to enhance public health through innovative, science-based programs and activities. FSIS will consider the report’s recommendations – in addition to suggestions from employees, industry, and the general public – and will address them as we seek public comment for any proposed regulatory changes.

The HIMP study design was established to measure the accomplishments of the traditional inspection system with the accomplishments of the models inspection system. Data collection conducted by Research Triangle Institute, an independent consulting firm, has indicated that HIMP has improved the safety of poultry products and increased overall consumer protection, as compared to traditional inspection.

Moreover, FSIS inspector verification data has shown that the redesigned system of inspection that we are testing has shown marked reductions in defects in young chickens as compared to the traditional inspection system. While no food safety or non-food safety defects are acceptable to FSIS, this project is showing important food safety gains.

 

Q: Does FSIS agree with GAO’s recommendation that only plants with a good history of regulatory compliance be eligible to participate in the inspection program?

A: Yes. As part of FSIS’ efforts to evaluate and continuously seek improvements for the HIMP pilot, the Agency is considering several improvements to the pilot project. Among these improvements is the consideration to phase in the implementation of HIMP over time. The program would also be voluntary. Plants volunteering for inspection under HIMP would need to demonstrate that they have successfully performed under an HACCP-based inspection system before being allowed to participate in the voluntary inspection system. This is an idea the Agency has been entertaining for a while, and are glad to learn that it is included in the GAO recommendations.

 

Q: Does FSIS agree with GAO’s recommendation that formalized training should be required of plant personnel?

A: Yes. Another improvement FSIS will consider for the HIMP pilot is to mandate formalized training for plant personnel. This is something that the Agency had considered independently of the GAO recommendations. In keeping with the Agency’s appropriate role in an HACCP environment, FSIS would allow plants flexibility in selecting a formal training program.

 

Q: Will FSIS consider suggestions from Agency inspectors and veterinarians when developing rulemaking on HIMP?

A: FSIS employees have provided valuable comments and suggestions during the course of the pilot program, particularly inspectors working in HIMP plants, and FSIS will continue to examine ways to improve how it receives this information. In addition, USDA will continue to seek input from all interested parties – including public health, industry, and consumer groups as well as the general public – to strengthen the program. Notice and comment rulemaking for each species, with opportunities for open public comment, will be conducted before any regulatory changes are made.

 

Q: How does FSIS respond to GAO’s conclusion that the Agency did not employ a random sample of plants when selecting participants for this project?

A: FSIS’ use of volunteer plants is a legitimate and valid practice. In many real-world applications, especially those involving animal experiments, it is impossible or impractical to use truly random samples. In this specific instance, because this is a pilot project and not mandated by rulemaking, FSIS could not require plants to participate in this project and therefore solicited volunteers.

Although not randomly selected, the volunteer plants participating in the HIMP study are representative of industry (i.e., diversity in geography, corporate structure, management styles, numbers of evisceration lines, product distribution patterns, inspection systems in use prior to the pilot, and other variables).

 

Q: Does FSIS agree with GAO’s conclusion that design and methodology limitation of the project design compromise the overall validity and reliability of its results?

A: No. As previously stated, FSIS disagrees with GAO’s conclusion about the limitations of design and methodology. The Agency believes that the HIMP study design was structurally sound, and could support future regulatory changes. Additionally, the design was previously peer reviewed by an external expert and discussed at public meetings.

The HIMP study is a commonly used "before and after" quality measurement design – one that has been used in many real world applications – especially those involving animal experiments. Such applied studies have been previously conducted by the Agency and independent researchers, and are found throughout peer reviewed literature.

Consequently, FSIS believes any data collected under the project is reliable and valid.

 

Q: Is FSIS considering GAO’s recommendation that plants be required to implement statistical process controls to manage and control production?

A: FSIS believes that statistical process control systems, which help to determine whether a plant’s production processes are performing within established performance standards, are important tools for plants to use to manage and control their production. Another proposed improvement that FSIS is considering for the HIMP pilot is to mandate that participating plants use statistical process control for quality defects. Statistical process control does not apply to food safety defects because they already are set at zero.

Inaccuracies in News Articles Concerning HACCP-Based Inspection Models (HIMP), (Jul 2000)

MYTH: The federal agency overseeing food inspection is imposing new rules reclassifying as safe for human consumption animal carcasses with cancers, tumors, and open sores.

FACT: Cancers, tumors and open sores have never been acceptable in our inspection program and they’re not acceptable now under HIMP. There is no such rule.

MYTH: HIMP lowers food safety standards.

FACT: Food safety standards have not been lowered. In fact, there are more food safety checks under HIMP than under traditional HACCP inspection.

MYTH: HIMP relies on scientific testing of samples rather than on traditional item-by-item scrutiny by federal inspectors.

FACT: Under HIMP as under regular HACCP, a Federal inspector inspects all carcasses and makes the determination as to whether it’s adulterated.

MYTH: Defective and diseased carcasses are being approved for human use under the pilot program.

FACT: FSIS policy is and remains that defective and diseased carcasses are not permitted to enter commerce. Regrettably, no inspection system involving humans is foolproof. For the first time in the history of inspection, we had a third party quantify the number of defective and diseased carcasses getting past traditional slaughter inspection versus slaughter inspection under HIMP. The data clearly show a dramatic reduction in the number of defective and diseased carcasses entering commerce. (See table in Backgrounder)

MYTH: Even if an inspector sees bad meat going down a processing line, inspectors were told not to remove it and the consumer will take care of the bad product.

FACT: It is not acceptable to FSIS for consumers to receive bad product. The carcasses that are condemned in a traditional plant are condemned in a HIMP plant. The carcasses that are trimmed in a traditional plant are trimmed in a HIMP plant. Inspectors are required to defer stepping in and taking action before the plant has the opportunity to let the system work, which under HIMP, is to have company employees remove the product. However, if the company does not do it, the inspector then is required to step in and correct the situation. This may involve stopping the line.

Hazard Analysis of Critical Control Points-Based Inspection Models Project (HIMP) pilot (DRAFT Jun 2005)

Update on the HACCP-Based Inspection Models Project--In-Plant Slaughter (Mar 2000)

FSIS has developed new inspection models for plants that slaughter young, healthy, and uniform animals and is testing the models in volunteer plants. The project is a natural extension of HACCP in all meat and poultry plants and will allow FSIS to better focus on public health concerns.

Currently, 24 plants are participating in the project - 16 that slaughter young chickens, five that slaughter market hogs, and three that slaughter young turkeys. No beef plants are participating in the project at this time.

Under the project, FSIS has established performance standards for food safety and non-food safety conditions that plants must meet. In order to meet these standards, plants are extending their HACCP systems to address the food safety conditions and developing process control plans to address non-food safety conditions. Plants are responsible for identifying and removing carcasses that do not meet these standards.

FSIS inspectors conduct oversight inspection and verification inspection to ensure that plants are meeting regulatory requirements and are producing food that is safe for consumers.

FSIS has contracted with Research Triangle Institute, an independent consulting firm, to collect both microbiological and organoleptic (sight, smell, and touch) data as volunteer plants enter the project. The data document the accomplishments of the traditional inspection system. A report on baseline testing for 16 plants that slaughter young chickens was released at the Agency's March 30^th public meeting. A complete set of baseline data for market hogs should be completed and released this spring.

Once each plant completes a transition to the new plant controls and slaughter inspection procedures, data are again collected to provide a "before and after" picture. The achievements of the new system must meet or exceed the achievements of the current system in order for FSIS to consider the new system successful. Data collection under the new models is underway in two plants that slaughter young chickens and two plants that slaughter market hogs and will begin in other plants as the project proceeds.

The project is being carried out through an open public process that allows all interested constituents the opportunity to provide input