December, 2009

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FDA, FSIS TALK TRACEABILITY ~~ government agencies

Thursday, December 31st, 2009

from FOOD SAFETY NEWS DISCUSSION
by John Munsell ~~ 12-30-09

After implementing policies for many years which complicate, if not make impossible, tracebacks to the source, USDA/FSIS seems to indicate it is willing to consider a midstream change in its attitudes, and policies, regarding Tracebacks to the TRUE ORIGIN of contamination.The December 9 issue of Dow Jones also refers to the upcoming January USDA hearing, but no specific date has been set. One of many concerns I have is that the agency may well attempt to produce yet another prosaic Notice/Directive/Policy which multiplies words, but accomplishes nothing, the primary objective being to disingenuously and piously portray USDA as America’s ultimate public health agency. The agency’s historical refusal to traceback to the origin is readily understood.

First of all, it is pertinent to note that E.coli and Salmonella are “Enteric” bacteria, which by definition means that they emanate from within animals’ intestines, and by extension proliferate on manure-covered hides. Retail meat markets (insert Lunds/Byerlys et al), restaurants (insert Sizzlers and dozens others here), and the majority of meat processing plants (review this century’s recalls) do NOT slaughter, thus do not have animal intestines or manure-covered hides on their premises. Therefore, it is reasonable to conclude that the vast majority of E.coli and Salmonella-laced meat is caused by sloppy kill floor dressing procedures. Well, why doesn’t USDA aggressively trace back to the slaughter plant origins? If tracebacks were successfully accomplished which reveal that the contamination ORIGINATED at a slaughter plant, a public backlash would discredit both the agency and the slaughter establishments. Why? Because successful tracebacks would reveal (1) that the big slaughter plants continue to ship tonnages of contaminated meat into commerce, bearing the official USDA Mark of Inspection; and (2) the tracebacks would reveal that the agency is asleep at the wheel at the biggest plants, by official agency design. Why do I state that? Because the current form of meat inspection, which is called Hazard Analysis Critical Control Point (or HACCP) deregulated the largest slaughter facilities. Prior to HACCP, the agency promised the industry that under the HACCP protocol, (1) the agency would maintain a “Hands Off” non-involvement role, (2) the agency would no longer police the industry, but the industry would police itself, (3) the agency would disband its previous command & control authority, and (4) each plant would write its own HACCP Plan, and the agency could not tell the industry what must be in their HACCP Plans. True to its word, USDA has fully lived up to its pre-HACCP promises, but only at the deregulated largest plants. In stark contrast, the agency has used HACCP to hyper-regulate the small plants. These differences are begging for a movie or book to expose the agency’s true intentions, which are focused on justifying USDA’s semi-retirement at the biggest plants, while hagriding small plants out of existence.

Today, 88% of feedlot-fattened steers and heifers are killed at the Big 4 packer plants, which enjoy political clout and the economic wherewithal to force USDA into paralysis. The agency lives in fear, knowing that if it attempts truly meaningful enforcement actions at the big packers, the agency will be defending itself in court, and for good reason! Realizing that USDA promised to maintain a “Hands Off” non-involvement role under HACCP, that it would no longer police the industry, and would jettison its previous command-and-control authority, the agency has knowingly painted itself into a corner which prevents it from forcing changes onto non-compliant big plants. USDA fully deserves to lose such litigation, and will, so chooses to avoid litigation. So, to circumvent this delicate problem, the agency has implemented policies (some of which are not written) which prevent tracebacks to the origin.

We should not be surprised when we continually experience these ongoing outbreaks and recurring recalls, because both (1)USDA and (2)litigation have focused its sanctions against the downstream destination facilities (restaurants, retail meat markets, and further processing plants) which have unwittingly purchased meat which was previously contaminated with invisible pathogens. Until USDA is willing to Force the Source, rather than Destroying the Destination, America is virtually guaranteed ongoing outbreaks.

USDA is totally opposed to putting Bill Marler out of business, and in fact is Mr. Marler’s ultimate ally by promoting the rights of the big slaughter plants to continue producing enteric bacteria-laced meat with virtual impunity. Why does USDA appear to have experienced a sudden change in heart regarding Tracebacks? I propose that since successful tracebacks have been accomplished for melamine-laced products, spinach to a mere handful of California farms, as well as tracebacks of lettuce, peppers, peanut butter, etc, USDA’s historical inability to traceback to the slaughter plants of origin has become monumentally conspicuous in comparison. And think of the irony of this historical fact!

Although FDA has inspectors in produce plants only once every few years, the agency has successfully accomplished these tracebacks. USDA on the other hand, has inspectors in every meat plant every day, yet is strangely unable to match FDA’s success in performing tracebacks. Perhaps the Obama administration is to be credited with the USDA’s born-again metamorphosis in its alleged desire to suddenly perform tracebacks to the origin of contamination. I can guarantee everyone one thing: we had best be closely watching every statement USDA makes in its January hearing, because the agency’s past performance in this area proves that USDA fears big packer clout more than it fears public health outbreaks.

John Munsell

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NAIS: Life Support ~~ Dead on Arrival

Thursday, December 31st, 2009

No sooner have most people pronounced NAIS dead-on-arrival, than a number of recent events may have breathed life back into the U.S.A.’s National Animal Identification Scheme. A combination of market forces aligned with a simplified tracking technology, and some rare positive news may have reinvigorated USDA’s moribund, voluntary animal traceability initiative.

First the news headlines. Even though the U.S. House of Representatives had voted to cut off funding for the NAIS as part of the Farm Bill, a joint House-Senate conference committee agreed a few weeks ago to continue funding the program to the tune of $5.3 million for fiscal year 2010-2011. This funding is a reduction from the $14.2 million authorized for last year and less than the $14.6 million the Senate approved, but the program will continue. However, a growing number of Congressional members have made it clear they want to see effective leadership from USDA to dispel some of the more egregious NAIS rumors running unchallenged in the countryside (e.g., backyard farmers with only a few chickens for home use or sale to friends will have to tag and track each animal). They also want to expand the number of farms and ranches that have registered with the NAIS premises database from the current anemic 13% to closer to the 90% needed for an effective national system.

The second piece of news for NAIS supporters is that U.S. District Judge Rosemary M. Collyer in Washington, D.C., dismissed a civil suit filed by the Farm-To-Consumer Legal Defense Fund and a group of Michigan cattlemen against the USDA and the Michigan Department of Agriculture (MDA) over the National Animal Identification System (NAIS). The group’s suit, filed last September, sought to enjoin the implementation and enforcement of NAIS. The suit was dismissed primarily because Judge Collyer ruled the program was voluntarily adopted by state departments of agriculture and was not federally mandated. Should NAIS become mandatory, sorry — the judge has already ruled.

Even with a bit of good news, the large opposition anti-NAIS forces continue to rally their troops by claiming that NAIS is overly burdensome, and is unnecessary because existing livestock records, such as brands, ear tags, veterinary logs and auction barn records do a good and economical job of tracking cattle movements. Dr. George Teagarden, the Kansas state veterinarian, agrees that the current record-keeping system can be used “to find the animals in question, but it can be months after the fact.” According to Dr. Teagarden, this time lag isn’t nearly fast enough and he cautions, “A highly contagious animal disease will devastate this country.” He underscores this dire prediction by noting that in Kansas in a single month cattle from all 48 of the Continental U.S. states arrive at least once a month. The speed of commerce is too fast to be handled by the paper-based system.” Dr. Teagarden is also aware that history does not record any such “devastating” disease to affect Kansas since Foot & Mouth was eliminated in the late twenties. His pandemic prophecy is not a fear to the majority of livestock producers in Kansas or the nation, however those hovering inside the beltway still listen.

Apparently, a number of national governments agree with Dr. Teagarden, and recently several have made or are poised to move their systems from voluntary to mandatory. Within the last few months these key countries have made major moves towards mandatory traceability; moves that are likely to impact USA policy and USA producers.

It is important to understand the difference in other countries. Australia and Canada produce 60% more beef than their country consumes and absolutely must protect and increase export sales. Totally different, the US in 2008, according to the NASS, exported $2,876,906,000 in wholesale beef, but imported $4,764,392,000. For 21 years the US has not produced enough beef to feed the nation. The difference in the urgency to export US beef is drastic. If the US exports more beef, they, in turn must import that exact amount more to feed the nation. In that respect, the US is depending on imports and has no surplus for export at all. All beef export from the US is simply a trading process that does not profit producers, but only those directly related in the selling and buying.

Brazil. Brazil, also producing much more than is being consumed, has just announced that by 2011 all livestock producers will be required to participate in a mandatory traceability system. The new system will rely on simpler technology than the current, voluntary SISBOV system which is RFID-based, and every segment of the Brazilian supply chain, from cow-calf operator to slaughter facility including transporters will be required to provide a complete chain of custody records. Real-time electronic record-keeping is not being mandated, but standardized record-keeping whose data can be transmitted via Internet portals to centralized databases will be used. The SISBOV system will continue to exist for those who want to use it, but the expectation among Brazilian officials is that most producers will use the standardized, simplified paper-based system. On a world export basis, the countries with the most compliance costs will be the least competitive.

Korea. South Korea has instituted a traceback system on domestically raised beef, and has indicated that it would require traceback on imported product by 2010.

Japan. The Japanese government has had a domestic animal identification system in place for several years, and on three different occasions the then-minority political party, the Democratic Party of Japan, had unsuccessfully tried to pass legislation that would require the same level of traceability for imports. In August the DPJ successfully became the controlling party for the first time in a long period, and newly appointed Prime Minister Yukio Hatoyama has vowed to once again try to revise the Beef Traceability Law. He doesn’t have control of the Upper House of Parliament, but he may be able to persuade his two coalition partners to go along.

How do these foreign government actions impact the U.S. meat industry? The Brazilian action probably has less direct impact on the US than do the Asian actions, because the Brazilian action was aimed at broadening acceptance of Brazilian beef in the EU. There will be some impact, though, because the largest of the Brazilian meat companies, JBS, is also one of the major U.S. meat producers so there will likely be some technology transfer from Brazilian ranches to their U.S. counterpart.

A major key to Brazilian acceptance of a mandatory livestock traceability system by Brazilian legislators was the simplification of the system of initially registering an animal and then tracking its movements from birth to export. The predecessor voluntary system in Brazil known as SISBOV is an RFID-based identification system with real-time electronic data collection and transmittal. While effective, this system is technologically sophisticated and beyond both the economic means and technological understanding of a large percentage of Brazilian producers. Embracing and actively promoting a simplified registration and tracking system by USDA, we believe, will go a long way towards helping reduce opposition to NAIS.

Even with all of these developments, make no mistake — NAIS is still on life support, and it may still die. But when the marketplace speaks and producers begin to learn the US is and has been a net import country, and no export markets are necessary at all, NAIS becomes even closer to true and lasting death!

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Politicians Soaked by Ignorance

Friday, December 25th, 2009
National Association of Farm Animal Welfare, Dec. 23, 2009 — Ag.Ed@nafaw.org
Milk ProtestAround the nation politicians are making laws and enforcements about things they know not of. Such is the case with National Animal Identification, Ohio’s Issue #2 and numerous leverages to increase taxes and clamp down on farm production.
“Every man is a fool when he is doing something he don’t know nothing about.” Will Roger’s quote was never more true than today when the halls of legislation in Washington DC are filled with elected elites that have no understanding of agriculture. To play it safe, if you don’t understand it—leave it alone.

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NAIS privacy not black and white issue

Wednesday, December 16th, 2009
As NAIS becomes a less relevant, useless, bad USDA idea, BEEF Magazine, and other smaller circulation media, grope in the dark hunting some simple benefit, or some lack of pain to encourage NAIS implementation. A wheel barrow load of ideas have been falsely exploited wrongly promising virtues of, profitable source verification, export sales expansion, world trade compliance, useful carcass data for breeders, and even (ho ho ho) economy of application.  All of these fail to hold water, as this article reveals, the NAIS proposed data is “FOR PRIVATE USDA EYES ONLY.”  None of the above promises, virtues, claims or assumptions are of any value to US ranchers, nor ever were.  USDA has squeezed the NAIS purpose down to, “nothing more than information from a phone book,” according to USDA’s chief veterinary officer, John Clifford.
Snicker through this December 14, 2006 Iowa Farmer Today article, from their archives, resurrected from the dead, for the December 2009 issue, designed to entice livestock producers to fear not, and try to dance with NAIS one more song.  The thrust — bring in enough attorneys and it can be simplified enough to be palatable?    What!!!
Darol Dickinson, www.naisSTINKS.com

Financial Sense Editorials

NAIS privacy not black and white issue

By Gene Lucht and Jeff DeYoung, Iowa Farmer Today
Thursday, December 14, 2006 8:27 AM CST

Privacy has been a central issue in the debate over whether to make a National Animal Identification System mandatory or voluntary.

“It’s a legitimate concern,” says Doug O’Brien, a staff attorney at the Drake University Agricultural Law Center in Des Moines.

But, O’Brien, who also works at the National Agricultural Law Center at the University of Arkansas, says the issues are not black and white. Instead, they are shades of gray. Many could be addressed in the drafting of legislation that could be written to implement a national system.

“It’s fairly complicated,” O’Brien says of an ID program. “The ground is shifting on this.”

But, in the debate over a mandatory vs. a voluntary plan, privacy has been a driving factor.

John Clifford, USDA’s chief veterinary officer at the Animal and Plant Health Inspection Service (APHIS), agrees privacy has been a central issue.

“Confidentiality is definitely a concern to the private sector,” Clifford says. “We will have the premises identification database, which is nothing more than information from a phone book.

“Federal law will protect the confidential information from disclosure. We will have access to that data in the event of an occurrence.”

O’Brien says that could be addressed in a mandatory system.

There are really two confidentiality issues, he explains. The first is over whether information about animals and their owners could be gotten from the government through a Freedom of Information request. The federal Freedom of Information Act requests would appear to apply to any information gathered by the government about animals.

But, O’Brien says there are nine exemptions to the act that are stipulated in the law, and several could reasonably apply to this situation. For example, there is an exception for confidential business information. Another protects released information that would make it difficult to run a program. These items have been factors in the federal price-reporting law.

Those concerns could be addressed by writing specific statute language that would prohibit such release of information.

The second concern is the potential for government agencies to share the information gathered for a government program.

Again, that could be handled through specific language in a new ID law or it could be part of language to be included in contracts between farmers and the government, O’Brien says.

There are privacy concerns with private ownership of information in a voluntary program.

Farmers might want to make sure federal code or contracts with those private groups would ban the selling of sharing of that information with private groups that might try to use the information for their private gain.

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FDA, FSIS TALK TRACEABILITY ~~ government agencies

Tuesday, December 15th, 2009

from FOOD SAFETY NEWS DISCUSSION

by John Munsell ~~ 12-13-09

After implementing policies for many years which complicate, if not make impossible, tracebacks to the source, USDA/FSIS seems to indicate it is willing to consider a midstream change in its attitudes, and policies, regarding Tracebacks to the TRUE ORIGIN of contamination.

The December 9 issue of Dow Jones also refers to the upcoming January USDA hearing, but no specific date has been set. One of many concerns I have is that the agency may well attempt to produce yet another prosaic Notice/Directive/Policy which multiplies words, but accomplishes nothing, the primary objective being to disingenuously and piously portray USDA as America’s ultimate public health agency. The agency’s historical refusal to traceback to the origin is readily understood.

First of all, it is pertinent to note that E.coli and Salmonella are “Enteric” bacteria, which by definition means that they emanate from within animals’ intestines, and by extension proliferate on manure-covered hides. Retail meat markets (insert Lunds/Byerlys et al), restaurants (insert Sizzlers and dozens others here), and the majority of meat processing plants (review this century’s recalls) do NOT slaughter, thus do not have animal intestines or manure-covered hides on their premises. Therefore, it is reasonable to conclude that the vast majority of E.coli and Salmonella-laced meat is caused by sloppy kill floor dressing procedures. Well, why doesn’t USDA aggressively trace back to the slaughter plant origins? If tracebacks were successfully accomplished which reveal that the contamination ORIGINATED at a slaughter plant, a public backlash would discredit both the agency and the slaughter establishments. Why? Because successful tracebacks would reveal (1) that the big slaughter plants continue to ship tonnages of contaminated meat into commerce, bearing the official USDA Mark of Inspection; and (2) the tracebacks would reveal that the agency is asleep at the wheel at the biggest plants, by official agency design. Why do I state that? Because the current form of meat inspection, which is called Hazard Analysis Critical Control Point (or HACCP) deregulated the largest slaughter facilities. Prior to HACCP, the agency promised the industry that under the HACCP protocol, (1) the agency would maintain a “Hands Off” non-involvement role, (2) the agency would no longer police the industry, but the industry would police itself, (3) the agency would disband its previous command & control authority, and (4) each plant would write its own HACCP Plan, and the agency could not tell the industry what must be in their HACCP Plans. True to its word, USDA has fully lived up to its pre-HACCP promises, but only at the deregulated largest plants. In stark contrast, the agency has used HACCP to hyper-regulate the small plants. These differences are begging for a movie or book to expose the agency’s true intentions, which are focused on justifying USDA’s semi-retirement at the biggest plants, while hagriding small plants out of existence.

Today, 88% of feedlot-fattened steers and heifers are killed at the Big 4 packer plants, which enjoy political clout and the economic wherewithal to force USDA into paralysis. The agency lives in fear, knowing that if it attempts truly meaningful enforcement actions at the big packers, the agency will be defending itself in court, and for good reason! Realizing that USDA promised to maintain a “Hands Off” non-involvement role under HACCP, that it would no longer police the industry, and would jettison its previous command-and-control authority, the agency has knowingly painted itself into a corner which prevents it from forcing changes onto non-compliant big plants. USDA fully deserves to lose such litigation, and will, so chooses to avoid litigation. So, to circumvent this delicate problem, the agency has implemented policies (some of which are not written) which prevent tracebacks to the origin.

We should not be surprised when we continually experience these ongoing outbreaks and recurring recalls, because both (1)USDA and (2)litigation have focused its sanctions against the downstream destination facilities (restaurants, retail meat markets, and further processing plants) which have unwittingly purchased meat which was previously contaminated with invisible pathogens. Until USDA is willing to Force the Source, rather than Destroying the Destination, America is virtually guaranteed ongoing outbreaks.

USDA is totally opposed to putting Bill Marler out of business, and in fact is Mr. Marler’s ultimate ally by promoting the rights of the big slaughter plants to continue producing enteric bacteria-laced meat with virtual impunity. Why does USDA appear to have experienced a sudden change in heart regarding Tracebacks? I propose that since successful tracebacks have been accomplished for melamine-laced products, spinach to a mere handful of California farms, as well as tracebacks of lettuce, peppers, peanut butter, etc, USDA’s historical inability to traceback to the slaughter plants of origin has become monumentally conspicuous in comparison. And think of the irony of this historical fact!

Although FDA has inspectors in produce plants only once every few years, the agency has successfully accomplished these tracebacks. USDA on the other hand, has inspectors in every meat plant every day, yet is strangely unable to match FDA’s success in performing tracebacks. Perhaps the Obama administration is to be credited with the USDA’s born-again metamorphosis in its alleged desire to suddenly perform tracebacks to the origin of contamination. I can guarantee everyone one thing: we had best be closely watching every statement USDA makes in its January hearing, because the agency’s past performance in this area proves that USDA fears big packer clout more than it fears public health outbreaks.

John Munsell

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