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photo of boyleinterview: patrick boyle

What is the American Meat Institute?

... We're the largest national trade association for the meat industry. We represent almost 300 companies. Collectively, they account for about 95 percent of the beef, pork, lamb, and veal produced in the United States, and about three-quarters of the turkey processed in the United States. ...

For the last five or six months, we've actually tried to go to some of the leaders of your industry, and go into their plants, and talk to them, and they won't. Why?

That's an interesting question. It's based upon some unacceptable experiences that we have had with the media over the years. We are an industry [that], for whatever reason, seems to attract a lot of media attention -- much of it sensationalized, in our opinion. ...


Patrick Boyle is the CEO of the American Meat Institute, a meat industry trade organization. He says that the levels of disease-causing bacteria in America's meat supply is decreasing, and that there is no evidence that the centralization of the meat industry has given rise to greater risk of large-scale food-borne illness.

We've had a number of companies that have opened the doors, brought in the media, brought in TV cameras, spent hours of senior management time explaining our processes, explaining our investment in technology, explaining our advances in food safety -- only to find when the story airs or is printed, there's none of that contained in the story.

What's the purpose of AMI?

We are a trade association for the industry. We represent their interests before the government, both the Congress and the executive branch. We spend some time interacting with the media, like yourself, on their behalf. We do a lot of education and training in the area of food-safety and worker safety. We have an ongoing food safety research program to make our products even safer. In fact, in the last three years, our members have contributed about $3.5 million to focus on E. coli and listeria-related research. ...

I've been told you're very powerful on [Capitol] Hill.

We're very active on the Hill, because there are a lot of pieces of legislation that affect our sector of the economy. We're very active with the regulatory agencies. There are a lot of regulatory agencies that are involved in meat and poultry processing facilities, involved with our workers, involved with our environmental standards. So we're active. ...

One of the things that I understand is something that the industry talks about, and wants to talk about, is what's happened in the price of meat and beef. If you look over the last 30 years, one statistic that I read said that the price of beef today is about half, in real dollar terms, what it was in the 1970s. Does that ring true to you?

... Meat is a relative bargain today compared to where it was 10-20 years ago.

How'd you do it? Every other cost has gone up.

It has a lot to do with efficiencies -- doing what we do even better and more efficiently; ... squeezing costs out of the process; adding value to the product. America in general is a tremendous food success story. ... We pay the lowest percentage of our per capita income on food than any country in the world. In the mid-1980s, it was about 12 percent. Today it's below 9 percent. And meat, which is a large part of our diet in this country -- meat and poultry -- is less than 2 percent of our disposable income. That's a great success story. We have high quality, reliable, abundant, and low-cost food in the United States. We're very fortunate.

The incidence of E. coli in beef is less than one percent.  We obviously want it to get to zero out of every 100 tests, but today it's less than one percent.

Historically, going back to the early part of the 20th century, we would raise our animals in the Midwest, ship the live animals to major metropolitan areas like Kansas City, Omaha, and Chicago -- all of whom still have remnants of their stockyards today. We would process the animals there; sell them in sides of beef, carcass form, sides of beef, to local butcher shops. We would cut them into steaks and roasts and sell them to consumers.

After World War II, two developments occurred. The local butcher shop began to expand into grocery stores and regional grocery chains. At the same time, we developed technology to ship refrigerated foods. And with the advent of grocery stores wanting to buy their meat from a single source, and with the ability to ship processed meat as opposed to live animals in rail cars, the packing houses moved out of the metropolitan areas and built new facilities in the heartland, close to where the animals were being raised. ...

The next significant development in the evolution of the beef industry in the United States involved the transformation and the transition from shipping carcasses of beef to shipping boxes of beef. The industry discovered that it was much more efficient to have the processing continue at the next step in the meatpacking plant, and reduce the side of beef to a piece of tenderloin, or a length of New York strip steak, and ship a whole box of tenderloins to a grocery store that only wanted tenderloins, as opposed to shipping that side of beef with some parts they may want for their customers, some parts of beef they may not want for their customers. It allowed us to be more responsive to the grocery store. It allowed them to be more responsive to their individual customers and their local markets. And it allowed us to do that at a lower cost. ...

There is a third major transition, which is occurring even as we speak. It began about a decade ago, but it's really accelerating in the last year. It's a natural continuation of the transformation from shipping carcasses to shipping boxes of beef. We're now going to ship case-ready steaks, case-ready roasts, which are going to be packaged in consumer units in the meatpacking plants in the Midwest part of the country.

What do you mean, "case ready"?

Right now, when a box of beef comes in the back of a grocery store, it may contain six New York strip lengths of steak. The meat cutter in the grocery store will trim off some additional fat and slice them into one-inch strip steaks, put them on a Styrofoam tray, overwrap them in some plastic, put the label on it, and put it in the meat case for the consumer.

That trimming and cutting and packaging into the individual consumer unit is increasingly occurring in the meatpacking plant. So when the box shows up at the back of the grocery store today, all the people in the meat department will have to do is open the box, and there will be the New York strip steak, one steak in a pack, wrapped and labeled, and just go directly into the case. ...

Everyone talks about one of the most important things to understand about the meat industry is how highly concentrated it is -- 84 percent of the slaughter is controlled by only four companies in beef. Have we gotten back to the days of the "beef trust"?

... Most business sectors in the United States economy are fairly concentrated, comprised of three or four market leaders that in general have about a 60 percent, 70 percent, 80 percent market share. You see that happening in the banking business, and it's been a long-standing structure in the automobile industry. ...

So in that regard, in terms of the overall economy of the United States, the beef industry is not much different in its economic structure. But what is important to understand is that it is a dynamic, evolving, highly competitive sector of our nation's agricultural economy. Four companies account for more than 80 percent of the beef capacity in the United States. Those four companies, by the way, are the ones who have made beef available at a significantly lower cost today in real dollars than it was available 20 years ago.

But 30 years ago, only one of those big four were actually in the beef industry. Within the last 30 years, three of the other big four have actually grown up as startup companies, or expanded as a result of acquisition, to the market share levels that they have today.

It's a vibrant competitive industry. If you ask the CEOs of the four largest beef companies, one concern that they have is the upstart companies that are coming into the business, the small regional new entries that are coming into the beef industry, who one day may have the agility, the acumen, and the competitive instincts to achieve the market share levels that the larger companies have today.

In this process of concentration, you talk about moving out to where the animals are. What you've had is not only concentration of the business, but concentration of the animals themselves. You have these very large feedlots -- 100,000, 120,000 cattle.

One of the problems scientists talk about is that that concentration of animals has led to, both in terms of the way the animals are raised, but also in terms of the grinding of the meat, the problem of E. coli and other pathogens spreading more widely throughout the industry. ...

Has that been a problem related to that concentration?

I'm not sure that concentration has exacerbated our food-safety concerns in the beef industry. ... Dealing with pathogens is a significant problem. I'm not sure that a significant cause is the concentration of cattle feedlots in our industry. E. coli O157:H7, the primary pathogenic concern within the beef sector today, 20 years ago that pathogen, if it existed -- and there's some debate whether it did exist -- was not known. ... We have done a fairly good job in responding to a pathogen that first became widely known in 1992 or 1993. We've invested tens of millions of dollars in what we call intervention strategies, which are basically new technologies that are in place in beef-processing plants to further reduce the incidence of E. coli in the beef supply. If you look at USDA test results that go back to the early 1990s on E. coli O157:H7, you will find a consistent decrease in the incidence of that pathogen -- which is already at very low levels, but is even at lower levels between 1994 and 1999. ...

But we still see recalls all the time.

If you look at USDA figures -- and I'm not attempting to minimize the food-safety challenge -- but if you look at USDA figures, the incidence of E. coli in beef is less than 1 percent. We obviously want it to get to zero out of every 100 tests. But today it's less than 1 percent. That's a reduction from as recently as the mid-1990s. So that's progress. And the progress is attributable to the investments in new technologies that we've implemented in our plan.

Part of the challenge is that there are only two technologies available today that we know in the industry can guarantee that the ground beef is pathogen-free, E. coli-free, bacteria-free. One is to cook the product. We sell a lot of precooked ground beef out of our plants. But most of the ground beef in America is cooked in restaurants or in our own kitchen. That is one technology, one step that is available, sure-fire.

Cooking as a technology?

As a process. The other technology would be irradiation. Some companies are irradiating raw ground beef; some have yet to embrace the technology. Some consumers and retailers -- and frankly, some beef companies -- are concerned about the market response to that technology. But today there are only two steps or technologies that we know will eliminate the E. coli in beef. And that's cooking it properly when we handle the food; or irradiating it before we purchase the food. That doesn't seem like a particularly good option for the consumer, that either they have to have the meat irradiated, or they have to cook it really well done. ...

It's reasonable, as long as we can't get to perfection in terms of the presence of E. coli in raw uncooked product, raw uncooked hamburger. It's reasonable to ask the consumer to bear some responsibility for using that product in a reasonable and safe way. And that means cooking it properly.

But doesn't it seem that there should be a way we could fix it earlier, [rather] than at the end? Because oftentimes consumers aren't in control of where the product is cooked, or how it's cooked.

If we have seen the rise of E. coli because of this consolidation, because of this concentration, and the way that the meat is ground together and all of that, don't we need to go back there to fix it?

I'm not sure I agree with your premise, that we've seen the rise in E. coli because of concentration. If you ask microbiologists, some of them suggest that this strain of E. coli -- which probably did not exist 20 years ago -- mutated as a result of reductions in other competing bacteria that had been eliminated through advancements and through safety technologies in the 1980s. So I'm not sure it has to do with concentration. And there are other explanations. ...

Ideally, we do want to get to the point where the technologies available in our plant give us the opportunity, give us the assurance that when we distribute this product, it is E. coli-free. We've achieved significant progress toward achieving that goal. The present incidence is less than 1 percent, based upon government test results.

But as an industry, we do want to get even better. We do want to get closer and closer, and ultimately to zero risk. ...

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. ...

We've seen the salmonella rates going up from the 1940s, 1950s, 1960s, up to the 1990s. We've seen the E. coli and the damage that it's done. Those are probably two of the most obvious health effects [of the consolidation of the meat industry]. And there are very high levels of food-borne illness. One in four Americans sickened some time during the year with food-borne illness, 25 percent to 30 percent of those estimated to be from meat; 5,000 deaths. Those are high.

You mentioned two pathogenic bacteria, E. coli O157:H7, and salmonella. In terms of the meat and poultry supply, we began testing for E. coli O157:H7 in the early 1990s, both industry and individual companies, as well as the federal government as part of the inspection program.

If you look at their data, the incidence of E. coli in all ground beef has decreased from the early 1990s to the late 1990s. If you look at government data on salmonella in raw meat and poultry products, it has decreased dramatically throughout the 1990s.

[According to] the public health data from the Centers for Disease Control ... the incidence of salmonellosis, which is the disease attributed to salmonella, has remained relatively stable, although it's decreased somewhat, even though we've had a dramatic decrease in the amount of salmonella on raw meat and poultry products. Salmonellosis has slightly decreased as a food-borne illness in the United States, largely attributable to progress made in the shell egg industry in eliminating a particular strain of salmonella, salmonella [enteritidis], which is uniquely in shell eggs.

Salmonella [on] raw meat, down dramatically this decade. Salmonellosis as a food-borne illness, down somewhat. Those are good trend lines.

E. coli O157:H7 in ground beef, down significantly in this decade. The incidence of E. coli-related illness probably about stable, which suggests that just reducing or eliminating pathogens on raw meat and poultry products, in and of itself, is not really going to have the kind of public health impact that we would hope. There are other factors at work. There are other sources that enter the food supply, ones which we come in contact through nonfood sources that cause public health illness in the United States. ...

We've made significant reductions in the presence of salmonella in raw beef, in the presence of E. coli in ground beef. We're not to zero yet, but the trend lines are very positive. And they're a direct result of the investments that we've made in achieving and implementing a much more sophisticated process in the beef industry. ...

Secretary Glickman had said that the food supply, the meat supply, is safer today than it was 10 years ago, but because of the concentration in the industry, the way the meat is so efficiently prepared and distributed, if something goes wrong, the risk is monumental. And with new pathogens like E. coli appearing, doesn't that system make us more vulnerable?

That system also makes us more efficient. That system also gives us greater resources to identify and reduce and ultimately eliminate the kind of food-safety concern that you raise. And at the same time, that system has given us the ability to respond to our customer needs and consumer preferences.

But look at the Jack in the Box incident in 1993 -- something we weren't expecting [that] had a devastating effect here. Look at Japan, with BSE [Mad Cow Disease]. I would think that you would be up nights worrying about this, because something like that goes wrong, ... the consumer will stop buying beef.

In terms of 1993, [the] Jack in the Box in the Pacific Northwest, the first significant outbreak of E. coli -related food-borne illness attributable to undercooked beef, undercooked hamburgers. ... No one involved in that tragedy is unchanged. Everyone has changed their personal habits, the way restaurants prepare beef, the way we process the product in the beef plants around the country. ...

You mentioned BSE in Japan. It has had a very disruptive effect on beef sales in that country. It's a similar situation that unfolded in the United Kingdom, going back to the late 1980s. Of course we are concerned about BSE possibly appearing in the United States. But to date, it has not. That's just not luck; that is the result of a many-year multifaceted effort to make sure that our herds remain BSE-free.

For example, in the late 1980s, when the United Kingdom discovered BSE in their cattle herd, we immediately banned the import of livestock and meat products from the UK so that we were not importing the problem.

In the mid-1990s, we implemented feed restrictions to make sure that the rations we feed our cattle do not become a conduit for transmitting the disease. There is some indication that that's how it spread throughout the United Kingdom.

Over the last five or six years, we've had a very aggressive live animal surveillance program to test every suspect animal for BSE. To date, we've done tens of thousands of those tests, all of which fortunately have come back negative. We continue to test a larger number of potentially suspect animals to make sure that we do remain BSE-free. You never can say "never." At least, professionals in the risk assessment business will say, "Never say 'never.'"

Experts at Harvard University recently completed a multi-year risk assessment at the request of the federal government to see whether or not we have a likelihood of experiencing BSE in our animal population, or our livestock population. They conclude the risk is very low. And the risk is very low because of the three major steps that I just outlined for you: import control; feed restrictions; and a very robust live animal surveillance program. ...

Everyone is very clear about the enormous impact of the Jack in the Box outbreak in 1993 on the industry, both commercially and in terms of regulation. So when the new HACCP process was being developed, the American Meat Institute lobbied against setting standards, microbial standards, for salmonella testing in beef. Why?

It's not true. ...

By way of background, HACCP was first developed in the 1970s by Pillsbury as the most effective process control approach that they could develop to manufacture food for NASA to make sure it was perfect for our astronauts in space. The meat and poultry industry began to experiment with HACCP-based principles in the mid- to late-1980s. By 1990, the industry itself had concluded that this was an improvement over the previous quality control programs that we had been utilizing in the past.

So the American Meat Institute, as the industry's national trade association, embarked in 1990 on a massive multi-year education and training initiative, to train our industry employees on HACCP principles, how to write a HACCP plan, how to implement it, how to continue to refine it and improve it. We have trained thousands of employees in our industry over the last 10 years on HACCP.

In the mid-1990s, based upon our experience with HACCP in our plants, it was the American Meat Institute, on behalf of the meat and poultry companies we represent, that formally petitioned the Department of Agriculture to ask of them -- to urge them -- that they incorporate this program in their federal regulations, so that every plant within the country would be required under federal regulation to develop and implement and operate pursuant to a HACCP plan. We were very supportive of HACCP. We were the first ones there. ...

But you have fought putting set microbial standards in there to reinforce HACCP.

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. ...

I understand there's been this argument as to what's the better indicator. But salmonella is a pathogen that nobody wants in their food. The government was saying with this new HACCP regulation that we want to find the best ways of controlling these pathogens that we don't want in our food. "Let us set this standard. We're going to give the companies more control over the inspection process, because they're probably the best people to do it. But to guarantee that, let's set a standard for something we clearly don't want in the food." At the time salmonella was believed to be the most frequently occurring food-borne illness. Jim Walsh offered an amendment trying to effectively block those regulations from going in.

My recollection is that Congressman Walsh offered an amendment, the purpose of which was to have the department basically consult more broadly with interested parties and experts before it finalized its regulation. And indeed the department did that.

Because you did not like the salmonella standards that would allow only a certain percentage of salmonella in the beef?

I don't recall it that way. Our first knowledge of the salmonella performance standard was in the final regulation, so we couldn't have opposed it in the notice and comment process. We did indicate to the government that there were better bacteria that they could identify.

Nonpathogenic bacteria?

Yes, that are present.

But isn't the point to go after pathogens?

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], the judge 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 your goal is to, as you said, 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.

But how can we stop it? Don't you want to stop it? Don't you want to lower the incidence of salmonella?

We have. If you look at the USDA data over the last decade, there has been a dramatic reduction in the incidence of salmonella in a raw uncooked product in beef, pork, chicken, turkey. The trend line is very positive and favorable. We are making very good progress in reducing salmonella in raw uncooked products. From a public health perspective, the issue is whether there is salmonella on the cooked product that we eat. It's not on whether there's incidence on raw product.

We've spoken with Dave Theno, one of the industry's leaders, who has been instrumental in developing HACCP systems that everyone in the industry respects. He says that this testing for salmonella and the other pathogens is essential to making HACCP work. Do you think he's wrong?

I'm not going to dispute the premise that microbiological testing -- and there are many different microbiological tests that companies conduct -- matter. [As a matter] of fact, I will strongly endorse the premise that microbiological testing, a robust, systematic, frequent series of microbiological tests, is a very effective means for us to control our process and make further improvements in the safety of our product.

So why not test for the pathogens we know make people sick, which is the problem in the end?

Salmonella on a raw uncooked product is not, in and of itself, a public health risk. And according to not just a federal court, but an appellate court, salmonella on a raw uncooked hamburger does not make it adulterated. It does not mean that the plant is not operating in an unsanitary way. ...

The beef industry spends a lot of money promoting beef as a wholesome product. This fight surely does not help that effort. Why is it so important to you?

There's a principle here, and it's a principle that underlied our petition almost 10 years ago to implement HACCP as a regulatory requirement for meat and poultry plants. And the principle is, there are increasingly valid scientific tools and methodologies, technologies that we can utilize in making our products safer and more wholesome. The salmonella performance standard has no scientific underpinnings. It has no relevance in terms of the wholesomeness of the product or the cleanliness of the facility.

Tell that to a consumer buying beef. ... How does the consumer know what is safe meat or not?

What the consumer should know is that the beef industry has made demonstrable progress in achieving significant reductions in all bacteria on raw beef products, pathogenic and nonpathogenic. That progress is quantified and confirmed by ongoing USDA tests. And we continue to invest millions of dollars in making further improvements in the safety and the wholesomeness of our beef products. ...

We conduct thousands and thousands of microbiological tests in our beef plants around the country, because they do give us the ability to better control our process, to improve the safety of our products. We're committed to microbiological testing. We're the industry that asked the government to develop and implement a HACCP regulation. We are making significant progress in improving the integrity and safety of our products. Government test results show that year after year.

For the consumer, I would suggest that there is still a responsibility, even with all this improvement, to handle the food in a proper manner. And that means, cooking it properly; keeping it chilled before you cook it; store it properly. It is a safe and wholesome food supply, but it is not a zero-risk supply. And there are some responsibilities at the end of the process that still exist, and frankly probably always will exist.

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.

Actually, one of the fundamental reasons that HACCP has been so strongly embraced, by both industry, government, and during the rulemaking process, consumer organizations, and why long-term it's going to be the approach that allows us to continue to make improvements ... [is that] at its fundamental core, it recognizes that the primary responsibility for assuring the safety and integrity of the food supply is in the hands of those who actually produce the food.

I don't mean to suggest that government doesn't have an important role to play. But it's a secondary role of oversight, confirmation, compliance, and enforcement when that may be necessary and appropriate. But the fundamental principle of HACCP is that the primary responsibility resides with the producer of the product. That is a positive development, and that's one of the reasons that we've been able to make our product safer over the last 10 years. And it will give us the process, the approach, the tools, the responsibility, to continue to make our products even safer in the future.

Right now that idea is being challenged in another area with Enron, where self-regulation has obviously had disastrous consequences. What do you say to reassure people that the self-regulation you're asking for within the meat industry isn't going to turn into another disastrous situation, particularly when we no longer have these salmonella standards?

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.

Can they stop the line now the way they used to?

They can stop the line. They can shut down a plant. They can prevent a plant from starting up if they don't think the pre-operational sanitation program was adequate. And they can even suggest -- and have always received an affirmative response -- if a recall were in order. ... Their enforcement tools have not changed post-HACCP. ...

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