The Jack in the Box E. coli outbreak of 1993 prompted the imposition of a new
regulatory system on the meat and poultry industry designed to help eliminate
future deadly food-borne illness outbreaks. The new system, Hazard Analysis and
Critical Control Point (HACCP), shifted the responsibility for ensuring meat
safety from USDA inspectors to the meat companies themselves and instituted
microbial tests for harmful bacteria. Since the implementation of the HACCP
regulations, however, controversy has erupted over whether the new rules place
too much power in the hands of the meat industry to regulate itself and
whether the microbial standards are appropriate or workable measures. FRONTLINE asked several leading experts to discuss the controversies surrounding the new system and the federal case that calls into question the USDA's use of salmonella testing to close down meat-processing plants.
THE HACCP SYSTEM
Chief, food-borne and diarrheal diseases branch of the Centers for
How was the Jack in the Box E.coli outbreak different to previous
The 1993 outbreak was one of the formative events in food safety at the end of
the 20th century. ... It was the largest outbreak of E. coli O157 we've
had in this country [and] it became the point of change for a lot of people in
industry, in the regulatory agencies, and for us here at CDC. ...
It was apparent that there needed to be changes throughout the system. If we
couldn't have confidence in taking our kids for a hamburger at a fast-food
chain, what could we have confidence in? It really rocked the whole food safety
system, and it shook up consumer confidence. ...
What sort of changes are having a positive effect on the spread of
Over the last five years, there's been a real transformation of the way that
meat inspection occurs. There's been a shift away from the visual inspection of
carcasses, and a shift towards process monitoring that reduces the amount of
contamination occurring in the plant. There have also been important changes in
the way animals are slaughtered that reduce the likelihood that the meat is
going to be contaminated in the first place.
Professor and chairman of the department of
epidemiology and preventive medicine at the University of Maryland Medical
The core inspection system that we had prior to 1995 was based on what we call
organoleptic inspection, inspection that you can do with your senses, your
hands and your eyes and your smell. This was a system that was actually
developed back in 1906 in response to problems with dead and diseased or dying
animals coming into the food supply. It was a very effective system for getting
rid of diseased and dying or dead animals because you could see that the
animal was dead before it came in for slaughter. The problem is that things
change, and in the 1990s, the problem with our food supply was not diseased,
dead, or dying animals coming in for slaughter. The problem was contamination by
microbes, by bacteria, such as E. coli O157:H7. You can't see bacteria. ...
Can you describe the genesis of HACCP?
What we said was, "We're going to change the ground rules here, guys." Up until
now, the inspector was the one that was in charge in the plant. The inspector
was the one responsible, and the factory just did its thing, and they really
weren't responsible for safety. There was the feeling that safety is the
responsibility of the USDA inspector and that [the producer's] responsibility
was limited to making a good product and trying to keep costs down. So we came
back in and said, "That's not quite right." Safety needs to be a primary
responsibility for the company. The company needs to really know what its
problems are. It needs to know what hazards are associated with its product. It
needs to figure out the best way for its plant to try to minimize those risks,
and put in place what we call a Hazard Analysis and Critical Control Point
And so what we did was mandate that the slaughterhouses, the processing plants,
had to put together a HACCP plan; they had to work through the science; they
had to figure out what their hazards were; they had to write it down and figure
out how they were going to try to decrease risks.
[HACCP shifts] the responsibility from what has been called a "command and control"
type system -- where the government simply comes in and says, "You have to do it
this way" -- to a system that says, "You're ultimately responsible as the plant
owner for the product that you produce, and for the safety of that product. And
you've got to put in place a system that is safety-oriented, that is designed
to reduce the hazard of the product you're producing."
We said, "You're going to have to start doing some microbial testing and the
government is going to come in periodically and do a random sample of your
product, and we're going to see whether or not you are indeed maintaining an
appropriate level of microbial contamination, or you are within an appropriate
standard." And that was unheard of in the industry. You looked at the carcass.
But the concept of actually culturing that carcass was something that was
fairly new for much of the industry. That was information they didn't really
want to know.
So what we did was actually set standards. Now, how do you set a standard?
What do you use? There are an awful lot of questions that came up, and there
were an awful lot of days that were spent sitting around the table bouncing
ideas around, trying to work through and develop an appropriate system.
Ultimately, what we put in place was a system that's based on salmonella
testing on the part of the government. So, essentially, the government has the
right to come into a slaughterhouse or a processing plant and test product to
see what the level of salmonella contamination is. And if that level is too
high, then the government can tell the plant they need to reassess their
current HACCP system and, ultimately, if that level of salmonella stays too
high, the government has the ability to shut down the plant.
[Editor's Note: Since this interview with Morris was conducted, a federal court decision, Supreme Beef Processing v. USDA, discussed below, held that the USDA does not
have the authority to shut down a meat-processing plant based on salmonella
Undersecretary of food safety, USDA
HACCP has injected process control, if you will, into the system. So
what we as inspectors do is we make sure that the plant people are controlling
their steps in their processing of that product, and monitoring that control to
make sure that the end result -- the meat that's served on your kitchen table
-- is as safe from contaminants as can be ensured.
So it's a way that's given us a lot more control over inspection. It has put
our inspectors more in a verification and inspection mode. It has certainly
brought science into the system, because we do microbial testing as part of our
inspection ... .
Can you explain how HACCP works?
... The easiest way I can explain it to you is if you think what happens in
your own kitchen. You're going to cook a roast for your family. You go to the
market and you buy the meat, bring it into the home. You're going to
refrigerate it and you want to make sure it's refrigerated at the proper
temperature. You get ready to prepare it. You're going to wash your hands
before you do that.
You're going to make sure the countertops are clean and cutting boards are
clean, that your knife is clean. ... After you season the meat and do whatever
you need to do it and you put it in a pot and you're going to cook it, you make
sure that that cooking is properly done, so that it's the right internal
So all these things that we know inherently by common sense: refrigeration,
keeping things clean, cooking to the right temperature -- these are critical
control points. These are points that we have to have control over to keep
things safe. And so HACCP is the same thing.
Imagine now in a food-processing plant, a meat processing plant, a poultry processing plant ... It's the same kind of a concept. What are the steps that these guys or women are doing in
those plants that they have to have control over? And it's the same kinds of
things. It's keeping things in a sanitary condition, keeping them clean, what
manipulations they do with the meat with their utensils that they do it in such
a way that they don't contaminate the meat. ... It's a commonsense system.
Does it make sense to have moved towards a regulatory system that gives
companies more authority over the inspection process?
The HACCP system does not give the plants any authority, [rather it gives them]
responsibility. The authority is ours; we're the ones with the authority. We
are the ones who look at their sanitation programs. We're looking at their food
safety HACCP program. We're the ones looking at their records. We visually
monitor them as they do their day-to-day operations, as well as look at their
records. We do microbial testing to verify that everything is working as it
should. And we're the ones who shut them down -- so the authority is completely
ours, not the plants'. ...
But has the role of the inspector actually changed since the introduction of
HACCP? There seems to be disagreement from different parties here in terms of
how much they're actually on the line.
... Having someone on the line looking, hoping that they're going to see
bacteria -- that's never going to happen. They're microscopic. So what our
inspectors do is they utilize other tools. They're there all the time. We have
inspectors in every plant in the United States every day -- 7,600 inspectors,
more or less. And so the way their role has changed is that they certainly are
more science-based. They are not simply looking at what is visibly OK, but they
are engaging in holding the plants accountable for what they do to make sure
that the product is as clean as possible.
In addition to that, the microbial testing that we do has added that element of
science. Now we can look at the invisible bacteria that might be there, and
utilize that information as a tool to say to us, "If there's bacteria here,
according to these tests that we just conducted, perhaps it's an indicator that
we need to look more closely at some of the things that the plant is doing."
CEO of the American Meat Institute
Does HACCP leave too much power in the hands of plants to regulate their own
behavior? It's been criticized for letting the fox guard the chicken coop.
... Anyone who thinks that HACCP is tantamount to self-regulation does not
understand HACCP as a process control technology, and does not understand
the inspection system that exists within the United States. HACCP says to us in
the industry, "You're primarily responsible," which is appropriate, "for
ensuring the safety and integrity of your product." But that is not tantamount
to having no oversight.
We have federal inspectors in our plants everyday. We do not operate in the
meat and poultry industry without an on-site oversight presence, a continuous
inspection presence, in our plants. That's an important and valid role for the
federal government to be playing. And in some of the larger plants, it's not
one or two inspectors; there are literally dozens of USDA inspectors on site
everyday in all parts of our operations, ensuring that we are fulfilling our
primary responsibility for maintaining the safety and the integrity of our
nation's meat supply.
But some of those inspectors have said that, given the new system and given
the fact that they don't have the same authority on the line, they haven't been
able to do their job as well.
I reject that. That's an inaccurate portrayal of the role the inspectors are
playing. I do fully appreciate that, as the government embraces and fully
implements a HACCP-based inspection system, the role of that inspector will
change. I do think the government needs to do a better job in explaining to the
inspector the new role they're going to have. But in no way is it a diminution,
or a lessening, of their regulatory and enforcement authorities.
SUPREME BEEF v. USDA
U.S. secretary of agriculture, 1995-2001
One of the key things in HACCP was testing for certain pathogens like
salmonella or E. coli. So if you came into a meatpacking plant and you found
evidence of salmonella or E. coli over a period of time and over a certain
number of tests, then you made the judgment that there was a problem in that
plant, the problem of sanitation or something else.
The industry said no. There was no way statutorily that we could basically shut
the plant down or stop production just based upon a number of tests for those
pathogens, when you couldn't prove how it got into the plant or the product on
the way out didn't have the pathogens in them. And we said, no, if you go in
and test and it is there, then it is there. And you have got to figure out why
-- you've got to clean it up. Most did clean it up, by the way. But we were
sued on this, [in Supreme Beef Processing v. USDA] and we basically lost the
What do you think will be the effect of the Supreme Beef decision on food
I think it's a serious blow to food safety because repeated evidence of
salmonella in a meat or poultry plant will no longer be enough to cause the
USDA to take enforcement action to close that plant down if they don't correct
the problem. That means, theoretically, you could still have active salmonella
in a plant, and that's not good, that's not healthy for consumers.
Why has the industry fought the salmonella standard?
I think that they view the USDA regulations as imposing a standard on something
that they can't control. That is, if the evidence [of] salmonella comes in
through some third party source that they have nothing to do with, [and]
they're operating a clean plant themselves, why should they be held
responsible? Why should the government take punitive action against them? I
think that's what's driving them.
[Elsa Murano], who we spoke to, says that she doesn't think that this decision will affect food safety. She says we're still doing the testing. It
becomes an indicator as to where there are problem plants. And then the old
rules, or the other rules or regulations available to the inspectors, will be
enough to shut down a problem plant. Do you agree with that?
If the USDA enforces those standards where they take repeated tests, and ...
send the inspectors back in if there are repeated problems, theoretically
closing the plant based on sanitation problems and that kind of thing, maybe it
will work out OK. But you've got to go through about 15 steps to get there
under what the USDA is now doing as a result of the decision, rather than a
quicker process to root out the pathogens much faster under what we did. ...
I quoted to Elsa Murano your statement that you think this was a serious
blow to food safety. And she said that she thought that Secretary Glickman was
wrong; that she is [herself] a scientist and that she knows that this is not a
serious blow to food safety.
Well, she and I have never discussed this matter before. A lot of scientists
who I think are probably equally as qualified [as she] agreed with me at the
time we issued these rules. So you know, obviously, there are differences of
opinion on this thing. But I must tell you, I think most people would agree
that the food would be safer if the means to identify pathogens were done
faster ... .
Patrick Boyle of the American Meat Institute said that the beef industry is
not fighting standards that are meaningful and improve the wholesomeness of the
product. The beef industry has reservations about unscientific standards that
have no relation to the safety of their product.
Well, there's a difference of opinion there. The question [is, Is] repeated
evidence of salmonella -- which is a food-borne pathogen that can make people
sick [if the meat is improperly cooked], but that does occur naturally in some
of our foods -- a marker of more serious food-borne illnesses? And if so, then,
should the companies take remedial action, or else be subject to being closed
down or be forced to comply? And, in my judgment, I think the answer is yes.
Some people in the meat industry felt otherwise. They sued, and they won. But I
think that that doesn't mean Congress shouldn't go back and try to rectify the
problem. ... Every scientist believes salmonella is a public health hazard.
Every scientist believes that you can get sick from salmonella; no difference
there. The question was, what is the power of the government to regulate it?
One of the more disturbing things about the court decision in the Supreme Beef
case was, what the judge basically said was, well, if there is salmonella in
this meat, consumers [should] cook it out. That's all you need to do. ... Wash
your hands, cook it out, and smile. That was essentially what a big part of the
judge's decision was. Well, the problem with that is, to a large extent,
consumers eat a big chunk of their meals out, so they can't control the cooking
process at all; somebody else is doing it for them. The consumer should not
have to bear the full responsibility for the problem. ...
And the Supreme Beef decision took away the USDA's authority to shut down a
In the case of salmonella, they took away the authority. The government can
still take action if you have a plant that's filthy, or full of contamination
generally. So you can go in and look and see if all those things occur. What
the Supreme Beef decision said is, repeated evidence of salmonella in the meat
supplies is not enough to shut the plant down. ...
Director of the Food Policy Institute at the Consumer
Federation of America
In the one case where USDA did, in fact, try to close down a plant
[based on repeated failure of the salmonella testing], a federal court stepped
in and said, "You know, the law never anticipated this kind of testing." ...
[As a result of that decision] there's a real question about whether or not the
department will be able to continue to set and enforce limits on
disease-causing bacteria in meat and poultry products. ...
But the company in Texas [Supreme Beef] that the USDA tried to close down had
20 percent of its product contaminated with salmonella. And a Federal District
Court Judge said, "That's OK. You don't have the power to stop that." And the
United States Senate has now said, "We're not going to take the steps to make
sure the USDA has authority to close down that plant." So there are plants out
there with 20 percent and maybe greater amounts of their product contaminated
with salmonella bacteria. ...
How significant is the Supreme Beef decision?
It is hard to overrate its importance. It could be interpreted as saying there
is no amount of disease-causing bacteria in raw meat or poultry that would
cause it to violate the law. There is no amount that would make it unacceptable
for the USDA seal of approval. ...
[When the HACCP regulations were being developed] we [the Consumer Federation
of America] said to the department, "You have to show us that food coming off
the end of the line in a plant that has an HACCP program is cleaner, safer, and
less likely to cause food-borne illness than food that was produced in another
plant." And the department decided that that was a worthwhile provision here,
and set up this objective measure. That's the salmonella standard. It was only
a beginning point. We expected that it would be expanded and that it would be
tightened. Instead, what appears to be happening is that the one objective
measure may well be abolished.
With that objective measure, the USDA has data that shows that the number of
birds contaminated with salmonella and the number of carcasses contaminated
with salmonella has dropped. So that's good news. We can't tell that fewer
people are getting sick as a result because it's just too soon. But it's a
reasonable expectation that if there is less salmonella, fewer people are
likely to get ill. If the objective measure of performance is removed, we will
oppose continuing with the HACCP program. I don't know what we can support in
its place. The old inspection system wasn't adequate. But without this
objective measure, the new system is a farce. ...
I am angry about the Supreme Beef decision. And I am both angry and
disappointed at the USDA's reaction to it. The Bush administration went to
court in October and defended salmonella performance standards. They argued
that they were legal and that they should be kept. And then the decision came
down and the USDA said they are not important at all, we don't need them."
And although the decision specifically dealt only with ground beef, the
department has chosen not to continue to enforce the standards on carcasses or
in ground poultry. They could do that or at least they could try to do that
until they are told not to, but they have said it is not important. ...
Let me read you something that Patrick Boyle at the American Meat Institute
said about Supreme Beef. He said that it is not the beef industry that is
fighting standards that are meaningful, that improve the wholesomeness of the
product. The beef industry has reservations about unscientific standards that
have no relation to the safety of our product.
Mr. Boyle has no scientific studies that refute the value of the
salmonella standard. ... They don't have any science that says that they are
not scientific. They have asserted that they are not scientific. I could go
into detail and say all of the reasons why, but they basically just assert it
is not scientific.
Is the issue about whether these are scientific or not?
No. The real issue here is, Does the meat industry have a responsibility to
control the presence of disease-causing bacteria in raw meat and poultry?
Historically, they did not. Since 1995, however, they have. Supreme Beef takes
us back to the time where they had no legal responsibility to control the bugs
that make people sick. We are really not arguing about science, we are arguing
about whether the industry has the responsibility for turning out a product
that has relatively low levels of pathogens. ...
What I really don't understand about Patrick Boyle's argument is that 95 to 98
percent of the plants tested for salmonella passed on the first test, only five
failed three times and two of those were owned by Supreme Beef. Everybody in
the industry passed this test. Why is Patrick Boyle defending the bottom
dwellers who would take no steps to meet a standard that wasn't very high? Why
is he defending them?
Why do you think he is defending them?
Damned if I know. ...
Undersecretary of food safety, USDA
Will the USDA [appeal the Supreme Beef case]?
We don't have plans at this time to do that. The Supreme Beef decision is one
that, when we looked at it, did not take away our authority to enforce our
regulation. We still can shut down plants, and we have been since the Supreme
decision came out in December. ... We continue to test for salmonella. But we
use those results to point us to what we may have to do in order to see what
the plant may be missing in their implementation of HACCP.
As an example, if you take your blood pressure, that's the same thing as our
microbial testing. Taking your blood pressure indicates that you maybe need to
look at your diet, your exercise, your overall health, because that's where you
need to maybe make some changes to improve your blood pressure. So similarly,
the salmonella tests that we do alert us to looking at the food-safety
programs, the HACCP, the sanitation of a plant, because something might need to
be fixed. And again, the authority's the same, in the sense that we still can
shut down plants. But we shut them down based on their failure to meet those
food-safety standards, and not only on the tests. ...
[The] former secretary of agriculture says that this Supreme Beef decision
is a serious blow to food safety. Is he wrong?
I think Secretary Glickman has misunderstood the Supreme Beef decision.
I'm a scientist. I've been working in food-safety research for many, many
years, more than I can tell you. And I know that he's mistaken in his
conclusion, from a scientific point of view. ...
CEO of the American Meat Institute
You have fought putting set microbial standards in there to reinforce the
No, that is not true. The initial proposal from the government in the mid-1990s
recommended using salmonella as a process control indicator. Over many, many
years involving microbiological tests, which we conduct on an ongoing basis for
all sorts of bacteria in all of our plants, our experience was that salmonella
is not a very good indicator. It's rarely found in beef.
But we don't want salmonella in the beef. Why not set standards as to what
is an allowable amount, and then work to get it below that?
The government proposed using salmonella as an indicator organism. We suggested
there are much more useful and meaningful indicator organisms. So in that
regard, we did not believe salmonella was the best choice for the government to
make. ... The point is to try to develop processes that give you some reliable
assurance of the absence of pathogens. Using generic E. coli, for example, is a
reliable indicator organism, and if the generic E. coli numbers are low, there
is a direct correlation with likelihood that any pathogenic bacteria would be
low, or not present. ...
That's not true with salmonella. And basically when the experts looked at it
and presented the evidence to a federal district court judge [in the Supreme
Beef case] concluded, based upon the science that was presented and the lack of
persuasive arguments from the government to suggest otherwise, [that] failing the salmonella performance standard really tells you nothing about the safety and wholesomeness of the raw product, or the cleanliness of
the facility in which the product is processed. ...
Given all the industry has done in the last 10 years to improve the
technology to go after food-borne illness-causing pathogens, why are you
fighting, and have continued to fight, this one case that defends somebody who
had at one test up to 50 percent of their ground beef contaminated with
salmonella? If you goal is to, as you said, to improve the quality and the
safety of the meat, why fight this case?
The goal is to produce safe product in clean facilities. We do that. What the
court concluded is that just because you have salmonella in raw uncooked ground
beef in no way suggests, as a raw uncooked product, that it's adulterated, or
that the plant that's producing it in unsanitary. ...
Undersecretary of food safety, USDA
Why do we see so many recalls?
If you look at the data on recalls, let's say for this year, even 2002, the
vast majority of the recalls that are done are as a result of our inspectors
finding contaminants. They're not as a result of people getting sick. No one's
gotten sick yet. We find the contaminants. We tell the company. The company
recalls the product -- the vast majority. So, if anything, it proves that our
system of inspection is working, because we're there identifying problems on
the plant. ...
How we handle recalls is we try to get all the data as quickly as we can, to
try to recommend to the plant that they issue a recall. No plant has ever
refused a recall. When we recommend them to recall, they immediately do it. And
the thing to do is to recall as quickly as possible, obviously, to retrieve as
much product as possible. ...
Should the USDA have mandatory recall authority?
I don't think we need mandatory recall authority. ... Companies always have
complied. But let's say that there's one company out there that decides, "I'm
not going to do it." We have detention authority. We have seizure authority by
law, not to mention the fact that we can certainly put out a press release, and
certainly companies don't want to have bad press. That's a fact. But the
detention and seizure authority that we have enables us to, even if a plant
decides not to do a recall, to detain that product, to seize that product from
the market. And that's something that other agencies in the government don't
U.S. secretary of agriculture, 1995-2001
Is it significant that the USDA does not have mandatory recall authority?
It is significant that the USDA doesn't have mandatory recall authority, and we
have tried to get that in legislation.
Explain to me what that means.
Basically, that means that if there's a contaminated product out there, the
government itself can order the product back rather than having to go to the
companies, and they themselves taking the step without the imprimatur of
government in calling the product back.
Now the truth of the matter is, in most cases [when] I was there, the companies
did quite well in the recall process. They moved quickly. They have no interest
in having contaminated product out there. It's an enormous liability problem
for these companies, so they will move quickly.
They have fought the government having this power because the companies have
felt the government would be too willing to use this power; and we could
theoretically destroy the reputation of a company by ordering recalls, where
maybe the problem could be solved in another way.
I just think it's another tool, another power that the government needs. After
all, the government can order through the Consumer Product Safety Commission
the recall of defective consumer products such as: lamps, electric blankets,
tricycles, you name it, but it can't order the recall of contaminated meat. ...
Director of the Food Policy Institute at Consumer
Federation of America
I think the government should have mandatory recall authority. I sat in rooms
and negotiated voluntary recalls with companies. And their lawyers would
quarrel and quibble and hold out for day after day, and by the time you finally
got them to recall the meat, guess what? A lot of it had been eaten. ...
Patrick Boyle says that there has been no company that has not gone along
with a voluntary recall requested by the USDA.
Ultimately, but they delay. And if you [ask for a recall], say, on that ground
beef, and somebody says, how do you know? How much do I have to recall? How do
you know that it was that lot and this lot? And you delay five days or six
days, 30 percent of it's gone, and the company never gets that back. Somebody
ate it, and they got paid for it.
The government has the authority to recall baby carriages and a lot of other
consumer products. None of those products come to you with a U.S. government
seal of approval. I do believe that getting the seal of approval from the U.S.
government, getting that imprimatur of acceptability, imposes more
responsibility on the meat industry than on those people who don't get a seal
of approval. It's the only product that the government approves for you in
advance. Yes, I think they ought to be able to recall it. ... You can recall
bath seats and toys and whistles and lots of other things, but not the food
that we know kills 5,000 people every year. ...
CEO of the American Meat Institute
One of the ways that people have proposed to improve this situation, given
that E. coli-contaminated beef does get out, is to give the USDA recall
authority. They do not have mandatory recall authority in this day and age.
Doesn't that seem like the minimal protection the consumer deserves?
It seems like a nonevent to us, frankly. USDA, in their 100 years of regulating
the meat industry, cannot point to a single instance where, at their
suggestion, a company refused to initiate a voluntary recall. In fact, the vast
majority of recalls occur in the United States at the instigation of the
company -- they discovered some flaw in the process. They informed the
Department of Agriculture about the flaw. They informed the government about
the recall that they're going to announce.
In a small number of cases, the government, because of the intense regulatory
system under which we operate, may detect a flaw in our system and bring the
flaw to the attention of a company, and request a recall, or suggest a recall.
In every instance where the government has requested a beef-related recall, the
company has voluntarily complied. Now, that does not sound to me like a problem
that needs to be fixed.
Former Secretary of Agriculture Dan Glickman says he thinks that was one of
the most significant problems. Why don't you agree that the government should
have that power? They have the power to recall baby carriages. Why not
contaminated ground beef?
In all due respect to former Secretary Glickman, who may have said lack of
mandatory recall authority is a problem ... there wasn't a single instance
during his tenure at the Department of Agriculture, or during the tenure of any
of his many predecessors at the Department of Agriculture, when the government
became aware of a food-safety related problem involving beef and suggested the
company should consider a recall [and they refused]. ... in every instance, the
company voluntarily recalled the product.
And even if the company were to refuse to voluntarily recall a beef product ...
the government then has the authority under current law to go into the
marketplace and detain that product. They can go into grocery warehouses,
restaurants, retail stores, and pull the product from the marketplace.
But hasn't it been hard in the recalls -- that do take place with some
frequency -- to actually get the meat back? The efficiency of the system has
made it very difficult to get the meat back. By the time we learn about it,
it's too late.
Actually, what occurs in real life when you initiate a recall, because our
records are so thorough and communication technology is so sophisticated, we
can get the information out immediately to our customers. And through our
customers, they in turn can notify the individual consumers.
Your customers being?
Grocery stores, restaurants. Also, if the product is one that has made its way
to consumers, the company issues a press release, and the Department of
Agriculture issues a press release, which we see on occasion in the news. So
consumers can learn through the media if a recall is underway. We inform our
customers, restaurants and grocery stores, immediately that a recall is
underway. [It's a] fairly sophisticated and successful system. ...
I assume you may end up getting back 20 percent of the actual recalled
That may occur in an instance where the company has recalled product at the
request of the government that may have been produced as far back as six
months. But that product has a shelf life of two months, or a month and a half.
It is highly unlikely that a perishable product with a shelf life of two months
is still in the marketplace, or even still in our refrigerators, six months
after it's been processed. ...
So it's not unrealistic, if the government wants to recall product going back
six months, and that product only has a two-month shelf life, only to get about
two months' worth of production back through a recall. The rest has been
consumed. And frequently in some recall situations, consumed without a single
instance of any reported instance. ...
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