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Ensuring Meat Safety
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

photo of TauxeDr. Robert Tauxe
Chief, food-borne and diarrheal diseases branch of the Centers for Disease Control

read the interview How was the Jack in the Box E.coli outbreak different to previous outbreaks?

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 food-borne disease?

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.

photo of morrisDr. Glenn Morris
Professor and chairman of the department of epidemiology and preventive medicine at the University of Maryland Medical School

read the interview

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 (HACCP) system.

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 testing alone.]

photo of muranoElsa Murano
Undersecretary of food safety, USDA

read the interview 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 temperature.

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." ...

photo of boylePatrick Boyle
CEO of the American Meat Institute

read the interview 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

photo of glickmanDan Glickman
U.S. secretary of agriculture, 1995-2001

read the interview 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 lawsuit. ...

What do you think will be the effect of the Supreme Beef decision on food safety?

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 plant.

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. ...

photo of foremanCarol Tucker Foreman
Director of the Food Policy Institute at the Consumer Federation of America

read the interview

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. ...

Elsa Murano
Undersecretary of food safety, USDA

read the interview

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. ...

Patrick Boyle
CEO of the American Meat Institute

read the interview You have fought putting set microbial standards in there to reinforce the HACCP regulations.

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. ...

RECALL AUTHORITY

Elsa Murano
Undersecretary of food safety, USDA

read the interview 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 have. ...

Dan Glickman
U.S. secretary of agriculture, 1995-2001

read the interview 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. ...

Carol Tucker Foreman
Director of the Food Policy Institute at Consumer Federation of America

read the interview

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. ...

Patrick Boyle
CEO of the American Meat Institute

read the interview

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 meat?

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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