(Initially, I gave a spontaneous comment that the agency’s willingness to hold this public hearing constituted a remarkable improvement in FSIS attitude towards tracebacks to the source)

My formal comments were as follows:

I’ve found it ironic the last two years that FDA, in spite of having inspectors in plants as infrequently as once every 5 – 6 years, has successfully traced outbreaks back to spinach farms, pepper farms, melamine in China, peanut butter, etc.

In stark contrast, although FSIS has inspectors in every plant every day, the agency typically fails to trace enteric pathogens back to the slaughterhouse of origin.

It’s not that FSIS cannot accomplish tracebacks.  It doesn’t WANT to.

Odd, because FSIS can trace animals with residue violations back to one solitary farm, and aggressively posts all evidence on the agency website. 

I recently created a PowerPoint which describes the OVERWHELMING differences between the true HACCP program authored by Pillsbury, compared to the allegedly “science based” program authored by FSIS.  After I presented it to the Stock Show in Rapid City, a livestock producer stood during the Q & A and stated that the PowerPoint would make vegetarians out of meat eaters.  I responded that all these Ongoing Outbreaks and Recurring Recalls are reducing consumer confidence in meat……….not my PowerPoint.

I also told the rancher that until FSIS develops the courage to perform Tracebacks to the slaughterhouse of origin, we are virtually guaranteed multiple recurring future outbreaks and recalls.  Since the Stock Show, we have had more recalls.

One reason Tracebacks aren’t accomplished is because of artificial restrictions mandated by the agency.  One example:

When inspectors collect ground beef samples for analysis at USDA labs, inspectors do NOT document the slaughterhouse of origin where the meat ORIGINATED until AFTER the USDA lab concludes that the sample has been confirmed as positive for E.coli 0157:H7 several days later.  This grossly unscientific delay in evidence gathering has numerous drawbacks:

(1)     It intentionally obfuscates the evidence.

(2)    Prevents expedited tracebacks to the origin of contamination

(3)    Insulates the SOURCE from accountability

(4)    Sends all pathogen liability downstream to the further processing plants, along with the previously-contaminated meat

(5)    And last, but not least………this cover-up imperils consumers.

 I’d like to show you one easy corrective action to prevent recurrences of this public health debacle:  I have in my hands an agency email dated July 26, 2002, sent from the agency’s Office of Field Operations national staff to managers of all of the agency’s District Offices.  The email says in part, and I quote:  “At the time the sample is taken, the IIC will obtain from the establishment, the name, point of contact, and phone number for the establishments supplying the source materials for the lot of ground beef being sampled”.  End quote.

This was a simple procedural change, accomplished by an email, without the need for extensive public hearings or a rulemaking process.

Unfortunately, the procedure was rescinded two months later.  An agency official stated at a public meeting that the agency rescinded it “FOR LEGAL REASONS”.  I can assure you these litigation threats against the agency did not emanate from small and very small plants.

This example is but one of many common sense solutions, which if implemented, would enable FSIS to perform Tracebacks to the SOURCE of contamination, enabling the agency to “FORCE THE SOURCE” to implement meaningful corrective actions to prevent recurrences.

If FSIS is indeed sincere in its sudden desire to Traceback to the SOURCE of contamination, I respectfully suggest that the agency must include owners of small and very small plants on its team to develop MEANINGFUL Traceback Policies.


NOTE:  my 4-minute time limit expired, so my final two paragraphs were not included in my comments at the meeting.