The Government Accountability Project's investigative findings included evidence that the public was being exposed to E. coli O157:H7 for two years before the 2002 ConAgra recall finally happened, an event triggered because John Munsell was courageous enough to blow the whistle on them, despite enormous personal cost. According to the report, "Starting in late summer 2000, FSIS repeatedly discovered that ConAgra had been receiving products returned from customers as E. coli O157:H7 positive. Each time, the agency allowed the tainted beef to be cooked and reentered into commerce, without warning the public or imposing systematic corrective action."
The report also found that "The regulatory double standard is a microcosm of why the integrity of HACCP is at risk. The ConAgra-USDA cover up sustains a pattern of using HACCP as a vehicle to obstruct its staff from enforcing food safety laws at big business, while bullying small business such as family firms."
Putting Knowledge and Experience Out to Pasture
One of Taylor's objectives in mandating HACCP was to reduce and eventually eliminate inspectors' traditional role at plants and to limit them to auditing paperwork completed by plant personnel. Instead of being able to remove from the line any feces-covered carcass, inspectors are now instructed to "let the system work." As Taylor writes, "USDA will focus on verifying through its inspection activity that every company-designed HACCP plan is appropriate and working properly and that each company is meeting its food safety performance standards."[12] But auditing paperwork completed by company personnel showing its record of meeting performance standards is hardly the same as having the authority to immediately remove obviously contaminated product.
Another objective of Taylor's deregulation program was to reduce personnel. Taylor maintains that "For USDA, taking an HACCP approach will permit more efficient deployment of inspectors, allowing them to focus on the most important food safety concerns in the plants they monitor."[13] "Efficient deployment" translates into allowing inspectors to retire and not replacing them. Furthermore, when new inspectors are hired, they are trained only in HACCP.
In a report entitled "Federal Meat Inspectors Spread Thin as Recalls Rise," OMB Watch discovered that "While Congress has appropriated significantly more money since the early 1980s, the agency has not spent proportionally for personnel. In the early 1980s, FSIS spent about 69% of its appropriated funds to pay its employees. However, the percentage has steadily dropped. By FY 2007, the agency only spent 57% on employee compensation. And correlated with this decline is a drop in the number of agency workers."[14]
While the number of workers declined, however, their responsibility increased -- dramatically. OMB Watch notes that "in FY 1981, FSIS employed about 190 workers per billion pounds of meat and poultry inspected and passed. By FY 2007, FSIS employed fewer than 88 workers per billion pounds, a 54% drop."
As a consequence, OBM Watch
reports that "The ability of processors and manufacturers to circumvent the
FSIS inspection process is aided by widespread inspector shortages. According to The Baltimore Sun, "inspectors interviewed said that because of
vacancies in the ranks, inspectors are often forced to do the work of two or
three staff members, making it all the more difficult for them to catch the
signs of disease either in the animals before slaughter, or in meat that has
been butchered.'"
In a highly informative report "Safety Last: The Politics of E. Coli and Other Food-Borne Killers," The Center for Public Integrity interviewed James Marsden, who was also interviewed by Moss for his New York Times' article. According to the Center for Public Integrity, Marsden made the important observation that "there is a distinction between animal-disease protection and prevention -- which is what USDA inspectors have been doing for decades -- and food-safety protection, which is what HACCP seeks to address. Animal disease protection is making sure that diseased cattle with tumors, abscesses, and other problems don't get into the food chain. Food safety is making sure that bacteria don't get into it. Both should work together."[15]
Marsden also speculated that "Maybe [those in the industry] see this as an opportunity to say we can use HACCP and food safety as a way to deregulate the meat and poultry industry."[16]
A tragic consequence of the decline in the number of inspectors is the corresponding decrease in the agency's ability to meet critical needs, such as adequately performing ante-mortem inspections that ensure animals entering the plants are healthy enough to walk through the doors on their own accord. The only parties that benefit from this situation are the meat and poultry cartel players; Americans suffer and even die without real inspection or meaningful enforcement.
Down but Not Out at Hallmark/Westland Meat Company
The one-sided focus on HACCP has a profound effect on the USDA's traditional role in animal-disease protection. According to testimony given in April 2008 to the House Committee on Oversight and Government Reform by Stanley Painter, the Chairman of the National Joint Council of Food Inspection Local Union of the American Federation of Government Employees, the scandal at the Hallmark/Westland Meat Company in Chino, California, "highlights one of the problems that we have attempted to raise with the agency ever since 1996 when Hazard Analysis and Critical Control Points (HACCP) inspection system was put in place. There seems to be too much reliance on an honor system for the industry to police itself. While the USDA investigation is still going on at Hallmark/Westland, a couple of facts have emerged that point to a system that can be gamed by those who want to break the law."[17]
Painter says that "the bottom line is that if plant management creates a culture for their employees to skirt around FSIS regulations, they can usually find a way to do it because inspection personnel are usually outnumbered."[18]
Without enough inspectors, public safety is dependent on company personnel to alert the veterinarian if an animal is "down" and removed from the slaughtering process, a requirement necessary to ensure downed cattle, a source of mad cow disease, are neither abused nor used for slaughter and get into the food supply. Video shot by an investigator for the Human Society of the United States proves the honor system isn't a viable substitute for the presence of government inspectors. Showing acts of extreme cruelty, the video also documents the plant's workers were guilty of violating the Humane Slaughter Act.
For the Love of Money


