There are Lies, Damned Lies, and then there’s “Science”

We’ve heard the expression “Figures don’t lie, but lies figure“.  We can start with a lie, then contort figures to justify our lies.  Same is true for science.  Science can be twisted, contorted, and massaged to validate whatever we believe. 

The link below will take you to a recent article printed in Food Safety News, authored by James H. Hodges, Exec. VP of the American Meat Institute.  Mr. Hodges’ beliefs about “science”, coupled with responses from readers, provides an educational insight into how folks can use their own version of “science” to produce diametrically opposing conclusions.  One aspect frequently overlooked in defining “science” is that common sense will always have a place at the scientific table, even when a government bureaucracy precludes incorporating common sense in such discussions.

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Does High Risk Meat Get USDA Endorsement?


Ever wonder why we continue to experience ongoing foodborne illness outbreaks and recalls in spite of the plethora of “science based” antimicrobial practices at use at slaughterplants, over which USDA provides dutiful scrutiny?  A major reason for continued sicknesses can be found in the following article, which was published this morning on Food Safety News.  You will find this to be educational and interesting. 

John Munsell

Posted in Tracebacks to the SOURCE of contamination | Leave a comment

USDA Inspected & Passed HIGH RISK Meat

The Hannaford chain of grocery stores in the northeast recently experienced a recall of ground beef products which were laced with an antibiotic-resistant strain of Salmonella.  Like most other retail chains, Hannafords purchases all their meat from outside source slaughter plants. 

Salmonella and E.coli are  “Enteric” bacterium, which is defined as originating from within animals’ intestines, and is thus present in manure.  Live beef arriving at slaughter plants frequently carry a sizeable amount of manure on their hides, creating an obvious risk during hide removal on the kill floor, where airborne enteric bacteria can easily become attached to beef carcasses.  And, when hides touch an exposed carcass, bacteria are directly deposited onto carcasses.  Retail chains, Hannafords being but one example, do not have intestines or manure-covered hides on their premises.  Therefore, we can conclude that Salmonella found in meat at retail meat markets was in all likelihood deposited onto carcasses on the kill floor, and the contamination did not occur at the retail meat market. 

Furthermore, the current recall of Hannaford meat covers seven states, with 29 reported illnesses.  The meat was processed at various Hannaford locations, in several states.  What is the probability that each of these Hannaford stores simultaneously INTRODUCED this one specific strain of Salmonella into their products, causing the outbreak?  Answer:  ZERO.  However, it does reveal that one of Hannaford suppliers suffered from a monumental breakdown in sanitary dressing procedures on its kill floor on one or more days, producing unsafe meat which was sent to the various Hannaford stores during this brief moment in time.

How does USDA view this Public Health dilemma?  USDA has concluded that Hannaford’s high risk practices likely lead to this outbreak.  Admittedly, Hannaford didn’t maintain grinding logs, which if used could have delineated the one source of contaminated meat.  Also, when the Hannaford meat cutters processed incoming meat, such as chucks and rounds, Hannaford kept the trimmings and put it into ground beef.  Totally legal, as the industry has done this since time immemorial.  My plant produced ground beef from trimmings for 59 years, under the watchful eye of USDA inspectors, and their supervisors, none of which objected.  Can you imagine buying a half of beef for your home freezer, only to be told that you cannot get any ground beef off that half, because USDA piously proclaims that ground beef produced from trimmings are “High Risk” for bacteria?

The fact remains that if Hannaford has maintained perfect grinding logs, the outbreak would still have occurred.  The outbreak was NOT the result of a lack of grinding logs, but the presence of salmonella in meat which Hannaford had purchased from a source slaughter provider.  And, even if Hannaford had tested the trimmings, and the lab result was negative for Salmonella, no guarantee for safe meat could be issued because labs frequently do not detect the Salmonella.  Even the largest beef slaughter plants issue disclaimers that even though their meat is tested, and tested negative, that the plants cannot issue a guarantee of safe meat because a silver bullet has not been developed to develop pathogen-free meat.  And, does USDA expect every retail meat market to conduct expensive microbial testing on every batch of ground beef produced?  Consider this fact:  the largest packers test every 10,000 lb batch of trimmings by collecting 1 – 2 lbs of trim for lab analysis.  It would only be equitable if every retail market tested 1 – 2 lbs of ground beef every 10,000 lbs.  Would be quite infrequent.  What’s good for the goose (the source slaughter plant), is good for the gander (the retail meat market).

Please also note that when USDA inspectors collect ground beef samples at USDA-inspected establishments for Salmonella analysis, the agency allows up to a 7.5% incidence of positives before the agency will commence enforcement actions at the plant.  USDA’s aloof stance is that if only 7.5% of your ground beef is laced with Salmonella, consumers won’t be endangered.  However, if 8% or more of your ground beef has Salmonella, then only then will public health be imperiled.

CDC statistics show that ten times as many Americans die from Salmonella than from E.coli.  USDA’s response to such lethal statistics?  First of all, 7.5% Salmonella won’t hurt anyone.  Secondly, the agency assesses all liability for Salmonella & E.coli laced meat to the downstream further processor, such as Hannaford.  USDA also issues a Pass Card to the large, source originating slaughter plants.  Only when this travesty of food safety justice is aggressively resolved will we Americans experience a lower incidence of foodborne outbreaks.

Bottom Line:  Hannaford’s processing of trim, and lack of grinding logs, did NOT introduce Salmonella into their ground beef.  Nevertheless, USDA now accuses Hannaford’s allegedly “High Risk” practices to be the cause of the current outbreak.  This is but the latest in countless examples of USDA’s refusal to conduct tracebacks to the SOURCE, that is, to the large slaughter plants.  USDA’s insistence on assigning all pathogen liability to the downstream further processor virtually guarantees American consumers of future recurring outbreaks.

The link below will take you to a blog by Bill Marler, which reveals how USDA blithely blames Hannaford for this outbreak.

John Munsell

Posted in Tracebacks to the SOURCE of contamination, Uncategorized | 2 Comments

Will closure of 5 USDA/FSIS District Offices Impact Food Safety?


USDA/FSIS announced on January 9, 2012 that it would close 5 of its 15 District Offices, as part of a consolidation which would decrease the agency’s budget and save taxpayer dollars.  This financially prudent move prompted the following statement by Andrew Lorenz, deputy district manager of the agency’s office in Minneapolis, one of the five offices to be closed:

                “They wiped out the entire Midwest”, as quoted in an AP article on January 10, 2012.

Such a statement resonates with some folks, who question if closure of these five offices could adversely impact food safety imperatives.  Such fears should be dispelled, which these brief comments will address.

About 20 years ago, FSIS had a district office in Billings, Montana with authority over Montana plants, including mine.  This office was eliminated, with duties consolidated into the Minneapolis district office.  This consolidation had NO adverse impact on the ability of Montana plants to produce safe food.  This current FSIS consolidation will likewise not adversely impact food safety or public health.

One of the ten remaining district offices is in Denver, Colorado.  The entire states of Montana and Wyoming are much closer to Denver than they are to Minneapolis.  When the Minneapolis office is closed, Minnesota plants can be more efficiently covered by the remaining office in Des Moines than the Minneapolis office could ever have covered plants in Montana or Wyoming.  But this issue should not be decided primarily by physical juxtaposition of district offices to meat establishments.  Rather, the primary focus of consolidation should be on FSIS’ actual physical presence and inspection of production at every meat establishment.

For example, let’s examine my plant, which I sold in 2005, and is still in full-time production.  There are five levels of agency oversight at this plant, as follows:

  1.  The in-plant inspector, who is there every day.
  2. The inspector’s supervisor, who is a SVMO, a Supervisory Veterinarian Medical Officer.  This SVMO lives 3.5 hours away, and comes to this plant every 3 weeks or so.  Whenever the plant kills an animal with potentially questionable health conditions, the SVMO must inspect it.
  3. The SVMO’s supervisor, who lives 2 hours away, and comes to the plant once a year or so.  This position is called a Front Line Supervisor (FLS).
  4. The deputy manager of the Minneapolis district office, who is the afore-mentioned Andrew Lorenz.  I don’t believe Mr. Lorenz has yet to visit our local plant.  And prior to Mr. Lorenz’s arrival, I would guess that I received visits by deputy managers only once every several years.
  5. The manager of the Minneapolis District Office.  I don’t remember my plant EVER being visited by any manager of the Minneapolis District Office.  I have seen the last two managers of the Minneapolis district office in Montana for general meetings, but not at my plant.

Therefore, when the Minneapolis district office closes, all of the “Hands On” inspection at this plant will remain as is, with no interruption, as levels 1 – 3 above will remain intact.  The only change will be that levels 4 & 5 (which are not involved in inspecting meat in the least) will be moved from Minneapolis to another existing district office, which I presume will be Denver. 

The bottom line is simply that we taxpayers are paying for a redundancy of levels 4 & 5 across this country, as well as the expenses of running district offices, including space rent, utilities, phones, etc.  Reducing the number of district offices from 15 to 10 will have zero impact on meat inspection, but will eliminate layers of costly and duplicative bureaucratic waste. 

Additional layers of new bureaucratic positions have been created in recent years, such as “Humane Handling Specialists”.  These folks visit slaughter establishments to ensure plants are treating livestock humanely.  The minority of plants slaughter, while a much higher % of plants only process.  As such, the majority of plants in these districts do not require oversight for humane handling of livestock.  I respectfully submit that agency verification of individual plant’s compliance with humane handling requirements can easily be conducted by agency personnel in layers 2 & 3 above, saving additional budgetary dollars which are being wastefully spent for the new position of Humane Handling Specialists.

Around 6 years ago, a new FSIS division was created entitled OPEER, meaning Office of Program Evaluation, Enforcement and Review.  This new division generated additional new positions, to perform work which had previously been handled by non-OPEER individuals.  OPEER has four regional offices, all in the same buildings (but in different offices) which house four of the ten district offices which will still remain.  Perhaps OPEER duties can be reassumed by the same agency folks who performed this work prior to the creation of OPEER?  Budget cuts and taxpayer outrage is the mother of inventions and innovations, which FSIS must proactively embrace.  In my most recent visit to the Minneapolis District Office, I paid a visit to the OPEER office in the same building, but no one was in.  It is important to realize that the OPEER office in Minneapolis is not one of OPEER’s four regional offices.  This means that in addition to OPEER’s 4 regional offices, OPEER has many more offices throughout the country, all requiring taxpayer expense.  Maybe now is the time to eliminate OPEER, and reassign its duties back to previous FSIS entities to better utilize existing talent, absent additional and unnecessary personnel positions. 

A review of America’s map, and the locations of the ten remaining district offices reflect a paucity of agency bureaucratic coverage in the western third of America.  Again, this FSIS reorganization does NOT reduce actual inspection coverage in the western states, but merely reduces the level of costly bureaucratic supervisory oversight.  District offices which will remain in Alameda, California and Denver, Colorado will now cover a larger geographical territory.  This means that Denver and Alameda officials will have more states and plants to cover, but not to visit.  Why do I say this?  Please refer to my previous list of five layers of FSIS personnel with authority over my plant, and see that levels 4 & 5 (from the district office) rarely visit plants in the field.  Why should they?  The agency already has three levels of inspection oversight at all plants, so why should we burden taxpayers with the travel costs of district office personnel who infrequently bless remote plants with their presence? 

I respectfully suggest that layer #3, that being the position of a Front Line Supervisor as described above, could be eliminated, with duties transferred to deputy district office managers, currently the #4 layer described above.  Only in America can we deceive ourselves into thinking that plants need three layers of inspection oversight, in addition to two layers of headquarters’ non-inspection bureaucracy.  With the development of technology, including laptops for all inspectors, now is the time that FSIS closely scrutinize its multiple layers of redundant oversight, many of which require government vehicles, while accumulating  motel room costs, meals, etc.

I heartily congratulate USDA Sec Tom Vilsack, Under Sec Dr. Elisabeth Hagen and Administrator Al Almanza for the foresight and courage to tackle wasteful government spending, and design FSIS reorganization which will still protect public health while being a better steward of taxpayer dollars.  Corporations are forced into such painful decisions when economic reality dictates change.  Government entities must likewise appropriately respond.  We are fortunate that in this case, FSIS can accomplish sizeable budget reductions without jeopardizing public health or safe food goals.  These top three officials deserve our support!

 And contrary to self-serving statements of some, the entire Midwest is not being wiped out, nor is any other segment of America.

John W. Munsell, Manager

Foundation for Accountability in Regulatory Enforcement (FARE)

212 S. Jordan

Miles City, MT  59301




Posted in USDA/FSIS Budget Cuts | Leave a comment

How can USDA-style HACCP be improved?

As history has unfolded, our ongoing outbreaks and recurring recalls have created sizeable discussion in our meat industry about the efficacy of USDA’s current style of HACCP.  The article accessible at the link below, published by Food Safety News, discusses HACCP.  I contend that the responses to the article, including some from me, bring out into the open the substantial shortcomings existing in USDA’s program. 

Not only will you enjoy this, but I’m confident you’ll be more educated about the deregulation of the meat industry’s largest plants as a result.

John Munsell

Posted in HACCP | Leave a comment