UNITED STATES-USDA AND FDA BOTH APPEAR DISSFUNTIONAL.
The current peanut butter outbreak provides us yet another opportunity to observe the predictable results of allowing humans to police themselves. Following the Jack In The Box E.coli outbreak in 1993, USDA mandated that all federally inspected plants implement a Hazard Analysis Critical Control Point (HACCP) Plan. Under HACCP, USDA embraced a "Hands Off" non-involvement inspection role, mandated that the industry police itself, while the agency disbanded its previous command and control authority. Sounds eerily like the deregulated environment surrounding Peanut Corporation of America and its two plants in Georgia and Texas.
The House and Senate are deliberating whether food inspection should be removed from FDA, and coupled with USDA, or create one agency responsible for all food. Primary focus should not be placed on which agencies should be responsible for food inspection. Instead, we must focus on the predictable failure of food inspections, regardless of the agency involved, as long as the HACCP Hoax is allowed to exist.
My comments are always the synthesis of numerous statements made to me by meat plant owners, as well as USDA inspectors and veterinarians across America. When comments from both sides always mirror each other, I know their statements are correct and unbiased. Well, both sides agree that HACCP has insulated the biggest slaughter plants from accountability, has forwarded all liability for contaminated meat downstream to victimized destination facilities, and has removed authority from inspectors to take action when sanitation non-compliances are observed at the large slaughter plants. How can USDA police the industry when the agency promised it would no longer do so under HACCP? How can an inspector document ongoing fecal contamination when the agency promised our industry that USDA would embrace a "Hands Off" non-involvement role under the HACCP umbrella?
Any inspector attempt to require plants to prevent, eliminate or remove recurring visible fecal contamination would constitute an illegal and unethical return to "command and control", which USDA promised our industry it would discontinue upon HACCP’s advent. Visual evidence of pathogens has been discredited as being non-scientific, a throwback to the allegedly archaic organoleptic inspection system which supposedly contributed to the Jack In The Box outbreak, since invisible pathogens cannot be visually (organoleptically) observed. Ongoing visible fecal contamination does not constitute a problem to FSIS leadership, which contends that HACCP plants have multiple hurdle pathogen intervention steps which have been validated by impartial third party entities to essentially remove all pathogens, virtually sterilizing all meat. Yeah, and I’m Darth Vader’s fairy godmother too. While HACCP Plans reflect theory, outbreaks reflect real life. And real death.
HACCP is a Trojan Horse. The hidden enemy inside the horse is deregulation, which was the primary goal of USDA and its closest ally, that is, the biggest packers, when HACCP was designed. The outside of the horse was and continues to be brightly painted with the words "Science Based Inspection". Science fiction and political science admittedly, but not true science.. Outbreaks and deaths emanating from deregulated peanut plants can also be anticipated from the large beef slaughter behemoths which have been liberated by HACCP’s laissez faire mentality. It is no surprise that all our outbreaks and recalls of meat products have originated from HACCP plants, where the fox is watching the henhouse, while USDA can’t watch the fox.
Public health, food safety, USDA field force’ esprit de corps and honor, and the viability of innocent downstream entities which purchase from source slaughter plants would all benefit from a return to meat inspection, and to jettison the tried and failed idea of deregulation. Have we learned nothing from the banking and investment industries?
After the JITB outbreak, we should have maintained the old organoleptic meat inspection program, and coupled it with a huge increase in USDA-conducted microbial sampling, which would have and still will quickly reveal where these pathogens are ORIGINATING. When USDA started publicly publishing Salmonella positive test results in poultry plants two years ago, the industry responded with production line improvements resulting in a dramatic reduction in adverse Salmonella test results from 17% lab positives down to 7%. Interestingly, these industry sanitation improvements did not occur until the agency revealed the ugly truth of Salmonella’s incidence within poultry HACCP Plants.
It’s time the agency dramatically increase its lab testing for Salmonella and E.coli in all large beef slaughter plants, and publicly post all lab results. USDA adroitly avoids such sampling, because the HACCP Hoax has placed artificial restrictions on agency activities, and because the big packers would monolithically oppose any agency attempt to increase its microbial sampling, and especially to release lab results which supposedly are proprietary to the slaughter establishments. Endless litigation is a certainty.
The solution to contaminated peanut butter, produce, poultry and beef is not found in which government agency is best equipped to do the work. Instead, what is required is a national willingness to admit that deregulation is a white-washed sepulcher: although its external features are brightly burnished with a "scientific" image, its interior is filled with increasingly common outbreaks and obituaries.
Are we Americans willing to be classified by USDA and the big packers as being Luddites, allegedly resistant to "science based" technological improvements"? Consumers have two formidable adversaries: the well-heeled multi-national packers, and a recalcitrant USDA which will not retreat from its current semi-retirement status at the largest packing houses. The HACCP Hoax must be jettisoned by both USDA and FDA, and replaced with agency "Hands On" inspection authority. Only then will the appropriate government agency have the ability to force the fox to maintain sanitary conditions.
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