Subject: WHO'S INSPECTING OUR FOOD ???
Date: April 19, 2007 at 9:42 am PST
Food & Water Watch – 1400 16th Street, NW Suite 225 Washington, DC 20036
www.foodandwaterwatch.org - T: +1.202.797.6550 – F: +1.202.797.6560
April 18, 2007
Dr. Richard Raymond
Under Secretary for Food Safety
Room 227E
James L. Whitten Building
12th St. and Jefferson Drive SW
Washington, DC 20250
Transmitted via facsimile: (202) 690-0820
Dear Dr. Raymond:
We are writing about the apparent lack of transparency by the Food Safety and Inspection
Service (FSIS) regarding the extent to which the agency is meeting its statutory mandate
for daily inspection in all meat and poultry processing plants. The efficacy of FSIS
inspection is a critical issue because foodborne illness remains a significant public health
problem. The recent release by the Centers for Disease Control of its FoodNet data
indicates that the incidence of salmonellosis and illnesses associated with E. coli O157:H7,
both associated with meat and poultry products, have not declined significantly in the past
decade.1 We believe that a fully staffed inspection workforce can help achieve further
reductions in foodborne illness, but it is becoming obvious to us that FSIS has failed to
adequately address its staffing deficiencies.
The agency’s public statements about whether it is meeting the mandate of the law have
been vague and irreconcilable and the agency has failed to provide concrete information to
the public and to Congress. You and other agency officials continue to claim that the
Agency conducts daily inspection in all processing plants. For instance, in your recent
testimony before the House Subcommittee on Agriculture, Rural Development, Food and
Drug Administration, and Related Agencies Appropriations, you assured the subcommittee
that the Agency’s plan to implement risk-based inspection (RBI) is “not about saving
money or decreasing FSIS’ inspection force” and that under RBI “we’re still going to go to
each plant every day.” Similarly, at the 2007 USDA Agricultural Outlook Forum, FSIS
Deputy Assistant Administrator Daniel Engeljohn’s presentation claimed that the agency
inspects nearly 6,000 processing plants “daily.” To put it bluntly, these statements are
false, and the agency is aware they are false. Yet agency officials continue to mislead the
U.S. Congress and the public.
There is abundant evidence that the agency has not been meeting the daily inspection
mandate for quite some time. In fact, at the same congressional hearing in which you
promised continued daily inspection, you admitted to Congress, for the first time, that the
1 Preliminary FoodNet Data on the Incidence of Infection with Pathogens Transmitted Commonly Through
Food - 10 States, United States, 2006 http://www.cdc.gov/mmwr/preview/mmwrhtml/mm5614a4.htm
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agency had done a recent survey and determined that several hundred plants have been
officially under less than daily inspection for over 30 years. You were forced to issue
Notice 22-07 on April 2, 2007 to correct that situation. However, according to information
we have been receiving for years from FSIS inspection personnel, that is likely just the tip
of the iceberg. Significantly, there is evidence there are likely an equal or greater number
of plants that are, unofficially, not visited daily because the Agency has refused to fill longterm
inspector vacancies.
When agency officials have been willing to admit “unofficial” lack of daily inspection,
they claim it is due to rare, intermittent glitches, such as an inspector calling in sick. This is
not only misleading – it is false. Instead, there are numerous inspectors throughout the
country who have had to cover multiple-plant assignments for days or weeks at a time
because the agency does not fill vacant inspector positions, making it impossible for the
remaining inspectors to visit every plant every day. Evidence of this problem includes:
• Last summer, we alerted you that one inspector in the Albany District had been
instructed to cover multiple assignments – he was responsible for inspecting 18
plants each day. The plants spread from the lower Hudson Valley in New York to
Connecticut. It does not take a manpower specialist to figure out that daily
inspection was not being performed for those plants.
• In the Beltsville employee feedback session that the agency conducted in last year
in preparation for the unveiling of its risk-based inspection proposals, it was
revealed that an inspector in the Philadelphia District was covering 26 processing
plants in his/her assignment. Daily inspection was not being provided for all plants
in that assignment.
• Last July we informed you that there were inspector vacancy rates of between 9 and
13 percent in several FSIS districts, with a 70 percent vacancy rate for assignments
within the city of Chicago.
• In February 2007, we learned of inspector vacancy rates of between 10 and 22
percent in several FSIS districts which we have shared with FSIS management
staff;
• Last year, the agency narrowly avoided having to furlough inspectors because of
lack of funds.
We would like to remind you that we have a pending Freedom of Information Act request
regarding inspector vacancy rates that you promised two months ago would be answered
imminently. We still have not received an official response from the agency. The
information this request should provide could reveal even more inspector vacancies.
Attached to this letter, we have included new information we have collected recently from
frontline inspectors describing recent failures to provide daily inspection in specific
circuits or plants.
Unfortunately, all of this information is anecdotal because the agency has repeatedly
refused to collect data pertaining to lack of inspections. The agency has ignored
recommendations in 2000 and 2004 by USDA’s own Office of Inspector General to collect
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information about which inspection tasks are not performed specifically because inspectors
did not have time.2 The agency has also repeatedly ignored our recommendation that it
implement routine recordkeeping procedures that would enable the agency to accurately
determine when and where daily inspections are not occurring.
In a recent consumer meeting with FSIS administrators, Food & Water Watch staff again
asked why the agency did not keep records of whether it was able to meet the mandate for
daily inspection. Agency managers told us that this information is not relevant to the
agency’s management controls. Each time we come to you with information about
specific plants not receiving daily inspection, however, agency officials ask us to assist
them by pointing out where this is happening. As you are aware, frontline inspection
personnel are extremely reticent to go public with information critical of the agency
because of the agency’s past record of punishing whistleblowers. Therefore, we do not
have a constant flow of this information, and it should not be our job to collect it. For this
and other obvious reasons, we believe that it is unreasonable, if not altogether farcical, that
the agency refuses to use its daily information management system to collect this
fundamental staffing information.
It is also obvious to us that agency management officials have continued to mislead the
public and U.S. Congress about the agency’s ability to provide continuous inspection in all
facilities under its jurisdiction even though the agency has had policies and at least
anecdotal information to the contrary. At the House Agriculture Appropriations
Subcommittee hearing on March 29, a veteran member of the subcommittee expressed
surprise to learn that there were hundreds of plants that had not been receiving daily
inspection. Although agency officials have known this for years, we are not aware that
FSIS administrators have ever informed Congress.
There are numerous reasons we believe it is essential for you implement immediately a
reporting system to record whether and where daily inspections are occurring.
First, we disagree that this information is irrelevant to the agency’s management controls.
We believe it is essential for the agency to determine if it is meeting its mandate under the
federal inspection statutes. Your recent admission that hundreds of plants were not
receiving daily inspection and the agency was forced to conduct a “survey” to reveal that
information indicates to us that you do not have satisfactory management controls in place
now.
Second, you are pushing ahead with a radical new inspection approach that will result in
less inspection in at least some processing plants. You claim that the variation in
inspection levels will be based on agency data of previous inspections at all plants
nationwide. But it has become obvious that the agency cannot even determine what
inspection personnel are doing now. With your current data management system, you
cannot demonstrate that these plants have been receiving daily inspection, and you are not
2 “Food Safety and Inspection Service – HACCP Implementation” USDA Office of Inspector General.
Report 24001-3-At. June 2000. Pg. 60-62. And “Audit Report” USDA Office of Inspector General. Report
24001-4-At. September 2004. Pg 5.
Food & Water Watch – 1400 16th Street, NW Suite 225 Washington, DC 20036
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capable of demonstrating that they will receive daily inspection under a risk based
inspection system, which has been your guarantee as you have tried to convince consumer
organizations to accept your proposals.
Finally, it seems unconscionable that the agency is not collecting staffing information so
that Congress is fully apprised of the agency’s activities and needs.
For all of these reasons, we urge the agency to take all appropriate measures to collect this
basic and necessary information.
Should you have any questions regarding this matter, please feel free to contact me at
(202) 797-6550.
Sincerely,
Wenonah Hauter
Executive Director
Cc:
Senator Tom Harkin, Chairman of Senate Committee on Agriculture, Nutrition and
Forestry
Senator Saxby Chambliss, Ranking Member of Senate Committee on Agriculture,
Nutrition and Forestry
Senator Herb Kohl, Chairman of Senate Subcommittee on Agriculture, Rural
Development, Food and Drug Administration, and Related Agencies Appropriations
Senator Robert Bennett, Ranking Member of Senate Subcommittee on Agriculture, Rural
Development, Food and Drug Administration, and Related Agencies Appropriations
Representative Collin Peterson, Chairman of House Committee on Agriculture
Representative Robert Goodlatte, Ranking Member of House Committee on Agriculture
Representative Rosa DeLauro, Chairwoman of House Subcommittee on Agriculture, Rural
Development, Food and Drug Administration, and Related Agencies Appropriations
Representative Jack Kingston, Ranking Member of House Subcommittee on Agriculture,
Rural Development, Food and Drug Administration, and Related Agencies
Appropriations
http://www.foodandwaterwatch.org/food/foodsafety/meat-inspection-1/FSIS_USDA_Vacancy_Ltr.pdf
Attachment
The following are excerpts from emails that Food & Water Watch’s Senior Policy Analyst,
Felicia Nestor, received from federal meat and poultry inspectors between March 30th and April
16, 2007 concerning the impact of staff shortages on inspection.
I have one plant that has not received daily visits at times because of slaughter duties. I also
know that there are at 2 others with plants that are in the same position. If it helps we are from
Minnesota. I know of a slaughter/processing plant that has a couple vacancies (been that way for
awhile) and when someone is needed for the slaughter floor the processing side is forgotten
about. No time to do both even though they are the same plant.
Est. [Number redacted] should have two [processing inspectors] on first shift as they do on third.
But the first shift processing inspector has to cover a Hog Plant [location redacted]. The
processing inspector at [the Establishment] has to give breaks to each of 9 line inspectors during
the day plus perform all the HACCP inspection tasks. I'm sorry to say that I don't get all the tasks
done during some of the days. The IIC doesn't help with the task unless he's by himself and then
he only does half of the [critical food safety checks]. Well in a nut shell, at times it's HELL at
[the Establishment].
I am assigned to nightshift (10pm-6:30am) at [location redacted]. My supervisor wants to put
down that some procedures have not been performed because we have been short for over four
weeks now, however a couple of years ago when they were short-staffed she and the [processing
inspectors] at that time did so. My supervisor got a nasty email from the [location redacted]
District office that told her they were not to do that. The District Office made it clear to her they
didn't care if it wasn't done, it still had better be marked as performed. We've had several nights
when my supervisor is the only person on the floor. I use part of my breaks off of the line to
complete procedures to assist her in getting things completed on our procedure sheet.
At this time me and the other processing inspector on nightshift are having to alternate
filling in on the line because one of the line inspectors was moved to dayshift. . . In the
meantime, no one has been detailed to cover his position on the line so the processing inspectors
are having to swap out to cover his line position. In the meantime, we can’t perform all of our
tasks.
Regarding inspector shortages, I can start with the 3 plants to the north of me just last week.
There has been a vacancy in [location redacted] for over a year and they pull the inspector from
the [location redacted] circuit when they run short. Just last week he had all 3 of his plants go
without inspection for 3 days and in my 3 years here there are at least 100 days they have used
him there and his plants have gone without inspection.
On my plants, I usually have an all day kill on Wednesday and I have 1 or two plants that
only get covered when my supervisor is around (he does make an effort) and the first year and a
half they were not covered at all before he got here. I have been on vacations and asked to
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change my kills. A relief person shows up to do kills only if there are any and the other plants get
no inspection for the week. In Nebraska if they were short I did the kill and the processing went
unstaffed many times.
On the days I worked over 11 hours it was because I was filling a vacancy on the day shift. That
inspector had retired and I was interested in moving to days after 6 years on the night shift. The
problem was that there was no one to do the night shift patrol, so I worked the day shift (with
one plant going overtime that means 10 hours plus the 1/2 hour pre-operational sanitation) and
then I had to cover one of the night shift plants on a call back. So after a 10 1/2 hour day I still
had an 80 mile round trip and 2 hours of the second shift to cover at the night shift plant. Twice I
was too bushed to do it, so I went home and slept a few hours then worked from 2100 to 2300
hours. It sounds bad, but it actually worked better for me.
I have been fighting for several years to get a full time [processing inspector] assigned to the
[name redacted] slaughter plant. There is one that is supposed to stop daily but is unable to
because of his other assignments. The agency is going to say that it doesn't go uninspected
because there is a vet there that is performing these duties. This vet is EIAO [Enforcement,
Investigation and Analysis Officer] trained but the [slaughterline inspectors] over there have told
me that he doesn't even perform the fecal checks that he is scheduled to perform. I also know
that this same "patrol" when the inspector is performing slaughter duties in [location redacted] or
[location redacted], not only does the [name redacted] plant not get visited but the processing
facility in [location redacted] goes without inspection. I don't have specific dates but I know it
happens weekly.
I'm a Consumer Safety Inspector in [location redacted]. I am currently on second shift on a patrol
assignment, and with the 4 establishments on my assignment, I drive 170 miles every night. In
early [month redacted], one of the second shift inspectors was on annual leave, and I was
assigned 2 additional plants to cover. Due to the amount of driving I do nightly on my own
assignment, I was not able to cover all 6 plants in one night. On Monday night, I had to skip my
headquarter plant, and on Tuesday, I skipped a different plant that was on my assignment in
order to cover the 2 additional plants that had been added to my assignment for those 2 nights. It
would have been impossible for me to make it to all 6 plants in one night. We currently have 2
vacancies in our circuit, which I realize is very common, but my concern is that as of [date
redacted], we will also have 2 inspectors on annual leave each week until the end of the year.
This creates a hardship on all of us who are doubled up and now expected to cover each plant on
our assignment, or if we don't, we will be breaking the law.
It appears that most plants are getting at least visited but as you can tell from the replies that's
ALL that's getting done. We are having to battle disciplinary actions out here in the field for our
bargaining unit employees because they have little to no time and are either making mistakes due
to lack of time or getting nothing worth while done within the plants other than meeting the
mandate that they show up. This should [allow you] to question Dr. Raymond's claim that
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inspectors will be allowed to spend more time in problem plants. There is NO such mandate in
the regulations right now that stipulates that an inspector spend a predetermined amount of time
in a plant other than the PBIS schedule which is just a guide that can be deviated from by the
inspector when they feel the need be. How can they stand in front of Congress and claim they
will put inspectors in problem plants for more time when they can't or won't even put them into
numerous plants now to tell if there are problems or not?
[From a slaughter inspector]. Our inspection personnel are not sent to other plants. We don't
have enough as it is. We have three vacant spots waiting to be filled.
In the [location redacted] circuit we have a vacant 2nd Shift. That assignment has been handled
by the 1st Shift [processing inspector] doing call-backs and work 12 hours a day. He does what
he can and the F[ront] L[ine] S[upervisor] is okay with that. This assignment is approximately
60 miles north of [location redacted]. With that being said there are plant/shifts that are not
covered. They are 3rd shift at [location redacted] and 2nd & 3rd shift at [location redacted].
Up until about 2 years ago, in plants that worked less than 5 days a week, the inspector was
given a PBIS schedule for the estimated days the plant worked. Then if for some reason the
establishment worked more than the PBIS scheduled days the inspector would perform those
days as unscheduled PBIS procedures. District Manager [name redacted] decided to eliminate
scheduled PBIS in these plants because he didn't like any "not performed" procedures showing
on PBIS when the plant was not operating (whether this came from higher than [name redacted] I
don’t know). This way they don't show up as not performed. This also masks when inspection
shortages cause the inspector to not go to these plants because of the inspection shortages- it
doesn't show up as "not performed" because inspectors are not to mark unscheduled procedures
as not performed procedures on PBIS. Also inspectors are increasingly being told to double or
triple cover because of inspection shortages and if necessary to just look at company records,
then get to the next plant.
Also, if you notice the "New and Improved" PBIS that is supposedly showing why
procedures are not performed--they still did not put in a place for the inspector to mark not
performed "Due to Inspection shortage". The only place an inspector has to fill out is "Other"
with no explanation why. So in reality they improved nothing when it comes to showing
procedures were not performed due to inspection shortage. So people that read PBIS (like you)
will still not be able to tell if they were not performed due to inspection shortage.
You will not see it in writing anywhere, but pressure is put on inspectors to not enter
"Not performed" in PBIS. When inspection shortages occur and inspectors are assigned double
duty or triple duty, they are told they have plenty of time to perform all the procedures in all of
the plants. The inspector feels he (or she) will suffer the consequences if not marking Performed
in all the plants on all the procedures. I talked to an inspector from Mississippi 2 weeks ago and
he said that in the poultry plant he worked at many violations were corrected but not recorded on
Noncompliance Records (NRs) because there is not enough time to fill out NR's. And inspectors
nationwide are becoming gun-shy about writing NR's unless they have plenty of time to reread
and revise the NR's because supervisors are holding them accountable to writing the NR's the
way their supervisor thinks they should be written. The funny thing about that is every supervisor
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has a different opinion of how they should be written. I was at FSRE training [time redacted]
and discussion came up about NR writing and everyone there was told by their supervisor a
different way to properly write a NR. The HACCP instructors said they realize this is a big
problem and have tried to tell upper supervision to stop this and have a set standard to write NR's
but they realize its still going on in the field. . . .The inspectors I talked to from across the nation
at FSRE training are losing any trust they had in upper FSIS management.
They are partially correct that the other shortages are caused by inspectors getting sick—but
now they don’t have any relief inspectors that are extra to fill in for people getting sick or
needing off for an emergency. All relief inspectors are now being assigned in advance to
positions to fill because of vacancies or annual leave, and because of that they do not have
anybody to put in place when an inspector gets sick, needs a medical appointment, or has an
emergency - like they did several years ago. This agency continues to cut back on field
inspectors and hire more management positions, and managers don’t work inspection duties.
Don’t know if this went on last year but sometimes upper management gives each other
incentive awards during the year and that is on top of the bonuses given during that year.
I think I had 3-4 days that were impacted because of ice & snow where I couldn't visit all the
plants. You know how bad this Agency lies about things! They've been talking for about a year
about splitting up this assignment. My boss even got on [me] a little bit because he wants us to
document at least one meeting per week with each plant. I just flat out told him it isn't going to
happen unless I have the time to do it. Now with this new plant coming up [location redacted],
that will add an additional 130-140 miles a day to my assignment. That should put me over the
300 mile/day mark.
Even the EIAO has complained that we cannot be providing much coverage to these plants
when you can only visit them 15-30 minutes a day. Even less time when the roads are [blocked]
during the winter months.
Its not just the plants Raymond admitted about that are not getting daily inspection. The
only reason he admitted to them is he was told in advance that the congress woman already had
proof it was happening. But he didn't tell her about the many other plants not getting daily
inspection because of not having enough inspectors. And he didn't tell her about inspectors being
harassed out of taking sick leave for medical purposes or family leave (doctors appointments,
funeral leave, etc.) because the agency had no one to cover for them and instead of admitting the
problem and fixing it they rather harass inspectors out of taking leave they are entitled to.
Many plants under full time inspection are not receiving daily inspection. Just last week the
plants in [location redacted] didn't receive any inspection on Monday, Wednesday, and Thursday
because that inspector was sent to [a slaughterhouse in location redacted] to cover online
shortages. The District office was notified that an inspector was needed to cover those plants but
sent no one, so no inspection of these plants were performed on those three days. This has been
going on for years. Many times other inspectors have been told to cover the [location redacted]
plants when that inspector was sent to [slaughterhouse] but the inspector was already doubling
assignments and couldn’t possibly perform inspection in [location redacted] so was instructed to
5
“Just go there and look that at the paperwork is good enough.” Even then most of the plants were
done for the day by the time the inspector was able to get there.
[From an inspector in a slaughter plant]. We are currently short three people this week and next.
We are always short at least two people. We have to rush through our tests. Last night I had the
floor all to myself for one period. I had four food safety tests, a PBIS test and a flock change,
which consists of ante-mortem and leukosis test. So far we have managed to make all our tests,
but I can assure you that we have compromised the quality of our tests.
[It] is simply untrue [that all violations are documented]. We all know that if we write all
the NRs that we should we would make life difficult for your fellow inspectors. I am sure that
we could write NRs for [sanitation performance standard] violations every day. The agency
would frown on this, even though we were taught to write all violations.
As time goes by we have less and less inspection. Let me give you just one example. We
used to do 2 [finished product quality standards tests] per day. Now we do only one, and that is
when it is scheduled, which is seldom. The agency claims that since it is not food safety it is not
as important.
I beg to differ. The reason it was not food safety, is because they will not let it be. When
we find fecal in the livers and gizzards, it is not called a food safety issue! Why? Salmonella
and E coli testing is not done on the liver and gizzards. Why? Let me tell you why. It is simple
-- fecal is there all the time! If you watch how the livers and gizzards are harvested you will see
that the gizzards are covered with fecal and the livers are not far behind.
Oh they get sprayed off in the process, but that is inadequate. Let me give you an
example. Not too long ago I found a good size piece of fecal 3/4" in the livers. This was in the
liver packing area. Had I not found it, that piece of fecal would have gone right out to
consumers. We are only able to write these up as a sanitation problem!
Later on that same week two other inspectors found the same thing. The 3rd inspector was
told that perhaps she was looking too close at the livers. As I have said before they do not
perform microbiological testing on livers and gizzards. I have a theory why -- there is no way
that they could pass such a test! Now they do not even have us checking livers on a regular
basis, when actually we should be doing more of the tests.
I just wish the congressmen and senators could see what is never reported in these plants.
I am sure that they would never eat chicken again. I am afraid that the only way to right this
matter is to have a knock down drag out fight in Congress. You need to subpoena some
inspectors in. That is the only way you can get them to talk. Most fear they will lose their jobs
if they say anything.
I talked to an inspector in the [name redacted] District and they are being disciplined if they
mark "not performed" on their PBIS. Again this is another example of covering what’s really
going on in the field. It doesn't matter if the inspector is doing double or triple duty and not able
to finish. Its pressure being put on by upper management to force inspectors to lie on PBIS to
make it look like everything is doing fine and everything is being covered. Then down the road if
something happens they can blame the inspector because PBIS is showing the inspector did all
required procedures. Combine this with inspectors not having time to write NR's and what do
you have? On paper a perfect system, in reality major problems. I wonder if congress is starting
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to see that upper agency is not being honest with them.
I work in a large swine slaughter/processing plant. We have [several] GS-7 line positions and (2)
GS -7 relief positions and (2) [processing inspection] slots. Of course the 7's positions are always
vacant and we [processing inspectors] spend 95% of the time covering for the empty and missing
7 slaughter inspectors. Things happen, I know, but why are we always short staffed in the first
place? As far as doing the processing side, that is in last place. . . We work a lot of overtime.
At the time there were many reasons as to why these were not being performed . . . BUT one
factor that the agency will fail to admit to is that their vacancy rates were so high that inspectors
were having to double/triple up so much, that PBIS tasks were impossible to complete as
scheduled. Remember Dr. Raymond made the statement that the agency didn't need any more
funds but when [consumers] put the vacancy figures out there he was made to appear that he had
no clue of what was going on in the field. I guarantee you that Bill Smith [Assistant
Administrator of the Office of Program Evaluation, Enforcement, and Review] and Ken Peterson
[Assistant Administrator of the Office of Field Operations] knew, because the National Joint
Council [union] told them and requested that they implement a means of tracking why scheduled
PBIS procedures were not being performed because field inspectors were being blamed for not
doing their jobs
After that the agency then incorporated these “management controls” where the
supervisors would have to explain why the ‘not performed’ scheduled tasks percentages were
higher in the plants they supervised than the average assigned by the Washington Bureaucrats.
When these numbers could not be controlled and the supervisor was having to explain why the
same assignment, such as mine, were well below the averages I was told to turn the PBIS task
generator off. When the ‘not performed’ codes came available I requested that I turn the
generator back on and was told to do so. This takes quite awhile for this to happen so my
assignment still is NOT generating PBIS tasks and ALL that I perform are unscheduled tasks. It
is this way right now today but may change next week, who knows when it will happen. This
and any data acquired by the agency for the agency is just like any statistical data, it can be
skewed to meet the expectations of the beholder. I'm sure these groups that collected data for the
HACCP-based Inspection Models Project as well as this RBI data have been told by the agency
up front what they wanted the data to appear like.
Almost all of the processing inspectors anymore travel to other plants unless they are in a
large slaughter plant. I for instance may cover 5 plants in 8 hours with 45 minutes travel time
between the closest and the farthest.
The problem is that when you have this many plants, one doesn't have time to write up all
deficiencies. We bring things up to their attention and follow up that they take care of it but there
is no paper trail because of a time factor. Also when we write a NR we need to write a cover
letter unless we can put their corrective actions on the NR.
Then with Management controls we need to perform food safety procedures at a
minimum of X percent. Otherwise we need to write our Front line Supervisor and tell him why.
So there are times when we do not perform a quality procedure but we mark it as performed
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because of the extra hassle. They are forcing good inspectors to falsify our records so they can
say everything is good.
No wonder NR numbers are down. It will be bad when all of us old timers that still do
some traditional inspection retire as I don't think the new inspectors have a clue what we use to
look for and some still do.
[Instructions to an inspector who was doubled up].
From: Front Line Supervisor
Sent:, [Date redacted] 2007
To: CSI
Subject: RE: Non reimbursable overtime
Good morning CSI,
When you will be covering Inspector’s assignment you are to perform only Food Safety and
Food Defense related activities and could drop other consumer protection activities. Your first
choice for 01B02 (pre-op sanitation) should be to perform this procedure for your own
assignment if the procedure is scheduled for both assignments. I did not rule out the possibility
of authorizing non-reimbursable overtime for conducting 01B02 however we need to consider
the history of plant compliance, type of product being produced by the establishment and the
available resources. Any administrative overtime worked will be justified and authorized if and
when necessary by Resource Management Staff in District Office or your supervisor.
Thanks.
Questions and Answers from the November 2006 Labor Management Relations meeting in
Denver.
Q. Please provide information on [Establishment redacted]. This position has been vacant for
some time and is very isolated. Are there plans to fill this vacancy soon?
A. The agency is looking at adding duties to this position to include inspection of processing
plants, Import duties, EIAO duties and OPEER [Office of Program Evaluation, Enforcement and
Review] duties. It is not decided at this time if all or just some of these duties would be part of
the position.
Q. I would like someone to ask about filling vacancies in the Olympia circuit or at least allowing
us to utilize our own relief inspection personnel on these vacant assignments. We have been
doubled, even tripled down here. It seems that every week our relief inspectors are either in the
Portland circuit or in the Spokane circuit. I would hope that those circuits can fill their own
8
vacancies/relief positions that evidently exist there so that the Olympia circuit can be covered
with our own relief inspectors.
A. The District Office is trying to fill vacancies. However the District Office must follow
Washington D.C. direction and not exceed the ceiling for the number of employees Washington
D.C. will allow for this District. Therefore the District office must fill positions were the greatest
need exists. Further the relief personnel in the Portland / Spokane circuits are not just for those
circuits. Relief personnel must be utilized by the agency to fill positions were the greatest need
exists. This could be any where in the District or USA to include all states and territories as
needs require.
Q. How can CSI’s in the field get better computers (newer) and ones that work so we can do our
job properly?
A. The agency renews computers & printers every 5 years. If a specific problem arises then
FAIM should be contacted.
Q. CSI’s are to use computers to do PBIS, eARDS, outlook, AGlearn. If it is difficult to do this
because your computer is too old and bogs down and CSI’s call FAIM like we are told to and
they say it is to old, call your DO and request a newer one, and you do that and it seems like you
are brushed off, how are we to do our job properly??
A. Employees should call the next level of supervision if they can not obtain needed information
or supplies.
Q. Are all inspectors responsible for all plants that the team covers?
A. The team is responsible for the assignments.
Q. If one inspector within the team is sick one day or there is a vacant assignment and the other
inspectors cover additional plant for that time (day / years) is this still considered doubling?
A. The team is responsible for the assignments there is no doubling.
Q. The Union has heard that in team inspection one inspector may train one day while the other
inspectors cover the assignments. If there is a vacancy within the assignments covered by a team
how would the remaining inspectors get time to train?
A. Vacancies could impact the assignments however the team will have to designate time for
each CSI to train.
Q. Inspectors have been doubling and covering each other’s assignments for years to cover for
sick leave and vacancies. How is team inspection different than what is already being done?
A. Yes, Team Inspection is not a new idea. However the team will determine the best utilization
of agency personnel to provided need coverage of assignments.
http://www.foodandwaterwatch.org/food/foodsafety/meat-inspection-1/FINALNoInsptFromInsp.pdf
>>>We would like to remind you that we have a pending Freedom of Information Act request
regarding inspector vacancy rates that you promised two months ago would be answered
imminently. We still have not received an official response from the agency.<<<
JOIN THE CROWD !
FOIA REQUEST FOR ATYPICAL TSE INFORMATION ON VERMONT SHEEP
Re: FOIA REQUEST FOR ATYPICAL TSE INFORMATION ON VERMONT SHEEP (4843 lines)
From: Terry S. Singeltary Sr. <[log in to unmask]>
Date: Mon, 2 Apr 2007 14:43:32 -0500
http://lists.ifas.ufl.edu/cgi-bin/wa.exe?A2=ind0704&L=sanet-mg&T=0&P=816
THAT 10,000,000 PLUS POUNDS OF TAINTED BLOOD LACED BANNED MBM THAT WENT OUT INTO COMMERCE
LAST MONTH, sadly is just the tip of the ice-burg. the 8/4/97 ruminant to ruminant feed ban was nothing more than ink
on paper. ......snip......end
TSS
Date: April 19, 2007 at 9:42 am PST
Food & Water Watch – 1400 16th Street, NW Suite 225 Washington, DC 20036
www.foodandwaterwatch.org - T: +1.202.797.6550 – F: +1.202.797.6560
April 18, 2007
Dr. Richard Raymond
Under Secretary for Food Safety
Room 227E
James L. Whitten Building
12th St. and Jefferson Drive SW
Washington, DC 20250
Transmitted via facsimile: (202) 690-0820
Dear Dr. Raymond:
We are writing about the apparent lack of transparency by the Food Safety and Inspection
Service (FSIS) regarding the extent to which the agency is meeting its statutory mandate
for daily inspection in all meat and poultry processing plants. The efficacy of FSIS
inspection is a critical issue because foodborne illness remains a significant public health
problem. The recent release by the Centers for Disease Control of its FoodNet data
indicates that the incidence of salmonellosis and illnesses associated with E. coli O157:H7,
both associated with meat and poultry products, have not declined significantly in the past
decade.1 We believe that a fully staffed inspection workforce can help achieve further
reductions in foodborne illness, but it is becoming obvious to us that FSIS has failed to
adequately address its staffing deficiencies.
The agency’s public statements about whether it is meeting the mandate of the law have
been vague and irreconcilable and the agency has failed to provide concrete information to
the public and to Congress. You and other agency officials continue to claim that the
Agency conducts daily inspection in all processing plants. For instance, in your recent
testimony before the House Subcommittee on Agriculture, Rural Development, Food and
Drug Administration, and Related Agencies Appropriations, you assured the subcommittee
that the Agency’s plan to implement risk-based inspection (RBI) is “not about saving
money or decreasing FSIS’ inspection force” and that under RBI “we’re still going to go to
each plant every day.” Similarly, at the 2007 USDA Agricultural Outlook Forum, FSIS
Deputy Assistant Administrator Daniel Engeljohn’s presentation claimed that the agency
inspects nearly 6,000 processing plants “daily.” To put it bluntly, these statements are
false, and the agency is aware they are false. Yet agency officials continue to mislead the
U.S. Congress and the public.
There is abundant evidence that the agency has not been meeting the daily inspection
mandate for quite some time. In fact, at the same congressional hearing in which you
promised continued daily inspection, you admitted to Congress, for the first time, that the
1 Preliminary FoodNet Data on the Incidence of Infection with Pathogens Transmitted Commonly Through
Food - 10 States, United States, 2006 http://www.cdc.gov/mmwr/preview/mmwrhtml/mm5614a4.htm
Food & Water Watch – 1400 16th Street, NW Suite 225 Washington, DC 20036
www.foodandwaterwatch.org - T: +1.202.797.6550 – F: +1.202.797.6560
agency had done a recent survey and determined that several hundred plants have been
officially under less than daily inspection for over 30 years. You were forced to issue
Notice 22-07 on April 2, 2007 to correct that situation. However, according to information
we have been receiving for years from FSIS inspection personnel, that is likely just the tip
of the iceberg. Significantly, there is evidence there are likely an equal or greater number
of plants that are, unofficially, not visited daily because the Agency has refused to fill longterm
inspector vacancies.
When agency officials have been willing to admit “unofficial” lack of daily inspection,
they claim it is due to rare, intermittent glitches, such as an inspector calling in sick. This is
not only misleading – it is false. Instead, there are numerous inspectors throughout the
country who have had to cover multiple-plant assignments for days or weeks at a time
because the agency does not fill vacant inspector positions, making it impossible for the
remaining inspectors to visit every plant every day. Evidence of this problem includes:
• Last summer, we alerted you that one inspector in the Albany District had been
instructed to cover multiple assignments – he was responsible for inspecting 18
plants each day. The plants spread from the lower Hudson Valley in New York to
Connecticut. It does not take a manpower specialist to figure out that daily
inspection was not being performed for those plants.
• In the Beltsville employee feedback session that the agency conducted in last year
in preparation for the unveiling of its risk-based inspection proposals, it was
revealed that an inspector in the Philadelphia District was covering 26 processing
plants in his/her assignment. Daily inspection was not being provided for all plants
in that assignment.
• Last July we informed you that there were inspector vacancy rates of between 9 and
13 percent in several FSIS districts, with a 70 percent vacancy rate for assignments
within the city of Chicago.
• In February 2007, we learned of inspector vacancy rates of between 10 and 22
percent in several FSIS districts which we have shared with FSIS management
staff;
• Last year, the agency narrowly avoided having to furlough inspectors because of
lack of funds.
We would like to remind you that we have a pending Freedom of Information Act request
regarding inspector vacancy rates that you promised two months ago would be answered
imminently. We still have not received an official response from the agency. The
information this request should provide could reveal even more inspector vacancies.
Attached to this letter, we have included new information we have collected recently from
frontline inspectors describing recent failures to provide daily inspection in specific
circuits or plants.
Unfortunately, all of this information is anecdotal because the agency has repeatedly
refused to collect data pertaining to lack of inspections. The agency has ignored
recommendations in 2000 and 2004 by USDA’s own Office of Inspector General to collect
Food & Water Watch – 1400 16th Street, NW Suite 225 Washington, DC 20036
www.foodandwaterwatch.org - T: +1.202.797.6550 – F: +1.202.797.6560
information about which inspection tasks are not performed specifically because inspectors
did not have time.2 The agency has also repeatedly ignored our recommendation that it
implement routine recordkeeping procedures that would enable the agency to accurately
determine when and where daily inspections are not occurring.
In a recent consumer meeting with FSIS administrators, Food & Water Watch staff again
asked why the agency did not keep records of whether it was able to meet the mandate for
daily inspection. Agency managers told us that this information is not relevant to the
agency’s management controls. Each time we come to you with information about
specific plants not receiving daily inspection, however, agency officials ask us to assist
them by pointing out where this is happening. As you are aware, frontline inspection
personnel are extremely reticent to go public with information critical of the agency
because of the agency’s past record of punishing whistleblowers. Therefore, we do not
have a constant flow of this information, and it should not be our job to collect it. For this
and other obvious reasons, we believe that it is unreasonable, if not altogether farcical, that
the agency refuses to use its daily information management system to collect this
fundamental staffing information.
It is also obvious to us that agency management officials have continued to mislead the
public and U.S. Congress about the agency’s ability to provide continuous inspection in all
facilities under its jurisdiction even though the agency has had policies and at least
anecdotal information to the contrary. At the House Agriculture Appropriations
Subcommittee hearing on March 29, a veteran member of the subcommittee expressed
surprise to learn that there were hundreds of plants that had not been receiving daily
inspection. Although agency officials have known this for years, we are not aware that
FSIS administrators have ever informed Congress.
There are numerous reasons we believe it is essential for you implement immediately a
reporting system to record whether and where daily inspections are occurring.
First, we disagree that this information is irrelevant to the agency’s management controls.
We believe it is essential for the agency to determine if it is meeting its mandate under the
federal inspection statutes. Your recent admission that hundreds of plants were not
receiving daily inspection and the agency was forced to conduct a “survey” to reveal that
information indicates to us that you do not have satisfactory management controls in place
now.
Second, you are pushing ahead with a radical new inspection approach that will result in
less inspection in at least some processing plants. You claim that the variation in
inspection levels will be based on agency data of previous inspections at all plants
nationwide. But it has become obvious that the agency cannot even determine what
inspection personnel are doing now. With your current data management system, you
cannot demonstrate that these plants have been receiving daily inspection, and you are not
2 “Food Safety and Inspection Service – HACCP Implementation” USDA Office of Inspector General.
Report 24001-3-At. June 2000. Pg. 60-62. And “Audit Report” USDA Office of Inspector General. Report
24001-4-At. September 2004. Pg 5.
Food & Water Watch – 1400 16th Street, NW Suite 225 Washington, DC 20036
www.foodandwaterwatch.org - T: +1.202.797.6550 – F: +1.202.797.6560
capable of demonstrating that they will receive daily inspection under a risk based
inspection system, which has been your guarantee as you have tried to convince consumer
organizations to accept your proposals.
Finally, it seems unconscionable that the agency is not collecting staffing information so
that Congress is fully apprised of the agency’s activities and needs.
For all of these reasons, we urge the agency to take all appropriate measures to collect this
basic and necessary information.
Should you have any questions regarding this matter, please feel free to contact me at
(202) 797-6550.
Sincerely,
Wenonah Hauter
Executive Director
Cc:
Senator Tom Harkin, Chairman of Senate Committee on Agriculture, Nutrition and
Forestry
Senator Saxby Chambliss, Ranking Member of Senate Committee on Agriculture,
Nutrition and Forestry
Senator Herb Kohl, Chairman of Senate Subcommittee on Agriculture, Rural
Development, Food and Drug Administration, and Related Agencies Appropriations
Senator Robert Bennett, Ranking Member of Senate Subcommittee on Agriculture, Rural
Development, Food and Drug Administration, and Related Agencies Appropriations
Representative Collin Peterson, Chairman of House Committee on Agriculture
Representative Robert Goodlatte, Ranking Member of House Committee on Agriculture
Representative Rosa DeLauro, Chairwoman of House Subcommittee on Agriculture, Rural
Development, Food and Drug Administration, and Related Agencies Appropriations
Representative Jack Kingston, Ranking Member of House Subcommittee on Agriculture,
Rural Development, Food and Drug Administration, and Related Agencies
Appropriations
http://www.foodandwaterwatch.org/food/foodsafety/meat-inspection-1/FSIS_USDA_Vacancy_Ltr.pdf
Attachment
The following are excerpts from emails that Food & Water Watch’s Senior Policy Analyst,
Felicia Nestor, received from federal meat and poultry inspectors between March 30th and April
16, 2007 concerning the impact of staff shortages on inspection.
I have one plant that has not received daily visits at times because of slaughter duties. I also
know that there are at 2 others with plants that are in the same position. If it helps we are from
Minnesota. I know of a slaughter/processing plant that has a couple vacancies (been that way for
awhile) and when someone is needed for the slaughter floor the processing side is forgotten
about. No time to do both even though they are the same plant.
Est. [Number redacted] should have two [processing inspectors] on first shift as they do on third.
But the first shift processing inspector has to cover a Hog Plant [location redacted]. The
processing inspector at [the Establishment] has to give breaks to each of 9 line inspectors during
the day plus perform all the HACCP inspection tasks. I'm sorry to say that I don't get all the tasks
done during some of the days. The IIC doesn't help with the task unless he's by himself and then
he only does half of the [critical food safety checks]. Well in a nut shell, at times it's HELL at
[the Establishment].
I am assigned to nightshift (10pm-6:30am) at [location redacted]. My supervisor wants to put
down that some procedures have not been performed because we have been short for over four
weeks now, however a couple of years ago when they were short-staffed she and the [processing
inspectors] at that time did so. My supervisor got a nasty email from the [location redacted]
District office that told her they were not to do that. The District Office made it clear to her they
didn't care if it wasn't done, it still had better be marked as performed. We've had several nights
when my supervisor is the only person on the floor. I use part of my breaks off of the line to
complete procedures to assist her in getting things completed on our procedure sheet.
At this time me and the other processing inspector on nightshift are having to alternate
filling in on the line because one of the line inspectors was moved to dayshift. . . In the
meantime, no one has been detailed to cover his position on the line so the processing inspectors
are having to swap out to cover his line position. In the meantime, we can’t perform all of our
tasks.
Regarding inspector shortages, I can start with the 3 plants to the north of me just last week.
There has been a vacancy in [location redacted] for over a year and they pull the inspector from
the [location redacted] circuit when they run short. Just last week he had all 3 of his plants go
without inspection for 3 days and in my 3 years here there are at least 100 days they have used
him there and his plants have gone without inspection.
On my plants, I usually have an all day kill on Wednesday and I have 1 or two plants that
only get covered when my supervisor is around (he does make an effort) and the first year and a
half they were not covered at all before he got here. I have been on vacations and asked to
2
change my kills. A relief person shows up to do kills only if there are any and the other plants get
no inspection for the week. In Nebraska if they were short I did the kill and the processing went
unstaffed many times.
On the days I worked over 11 hours it was because I was filling a vacancy on the day shift. That
inspector had retired and I was interested in moving to days after 6 years on the night shift. The
problem was that there was no one to do the night shift patrol, so I worked the day shift (with
one plant going overtime that means 10 hours plus the 1/2 hour pre-operational sanitation) and
then I had to cover one of the night shift plants on a call back. So after a 10 1/2 hour day I still
had an 80 mile round trip and 2 hours of the second shift to cover at the night shift plant. Twice I
was too bushed to do it, so I went home and slept a few hours then worked from 2100 to 2300
hours. It sounds bad, but it actually worked better for me.
I have been fighting for several years to get a full time [processing inspector] assigned to the
[name redacted] slaughter plant. There is one that is supposed to stop daily but is unable to
because of his other assignments. The agency is going to say that it doesn't go uninspected
because there is a vet there that is performing these duties. This vet is EIAO [Enforcement,
Investigation and Analysis Officer] trained but the [slaughterline inspectors] over there have told
me that he doesn't even perform the fecal checks that he is scheduled to perform. I also know
that this same "patrol" when the inspector is performing slaughter duties in [location redacted] or
[location redacted], not only does the [name redacted] plant not get visited but the processing
facility in [location redacted] goes without inspection. I don't have specific dates but I know it
happens weekly.
I'm a Consumer Safety Inspector in [location redacted]. I am currently on second shift on a patrol
assignment, and with the 4 establishments on my assignment, I drive 170 miles every night. In
early [month redacted], one of the second shift inspectors was on annual leave, and I was
assigned 2 additional plants to cover. Due to the amount of driving I do nightly on my own
assignment, I was not able to cover all 6 plants in one night. On Monday night, I had to skip my
headquarter plant, and on Tuesday, I skipped a different plant that was on my assignment in
order to cover the 2 additional plants that had been added to my assignment for those 2 nights. It
would have been impossible for me to make it to all 6 plants in one night. We currently have 2
vacancies in our circuit, which I realize is very common, but my concern is that as of [date
redacted], we will also have 2 inspectors on annual leave each week until the end of the year.
This creates a hardship on all of us who are doubled up and now expected to cover each plant on
our assignment, or if we don't, we will be breaking the law.
It appears that most plants are getting at least visited but as you can tell from the replies that's
ALL that's getting done. We are having to battle disciplinary actions out here in the field for our
bargaining unit employees because they have little to no time and are either making mistakes due
to lack of time or getting nothing worth while done within the plants other than meeting the
mandate that they show up. This should [allow you] to question Dr. Raymond's claim that
3
inspectors will be allowed to spend more time in problem plants. There is NO such mandate in
the regulations right now that stipulates that an inspector spend a predetermined amount of time
in a plant other than the PBIS schedule which is just a guide that can be deviated from by the
inspector when they feel the need be. How can they stand in front of Congress and claim they
will put inspectors in problem plants for more time when they can't or won't even put them into
numerous plants now to tell if there are problems or not?
[From a slaughter inspector]. Our inspection personnel are not sent to other plants. We don't
have enough as it is. We have three vacant spots waiting to be filled.
In the [location redacted] circuit we have a vacant 2nd Shift. That assignment has been handled
by the 1st Shift [processing inspector] doing call-backs and work 12 hours a day. He does what
he can and the F[ront] L[ine] S[upervisor] is okay with that. This assignment is approximately
60 miles north of [location redacted]. With that being said there are plant/shifts that are not
covered. They are 3rd shift at [location redacted] and 2nd & 3rd shift at [location redacted].
Up until about 2 years ago, in plants that worked less than 5 days a week, the inspector was
given a PBIS schedule for the estimated days the plant worked. Then if for some reason the
establishment worked more than the PBIS scheduled days the inspector would perform those
days as unscheduled PBIS procedures. District Manager [name redacted] decided to eliminate
scheduled PBIS in these plants because he didn't like any "not performed" procedures showing
on PBIS when the plant was not operating (whether this came from higher than [name redacted] I
don’t know). This way they don't show up as not performed. This also masks when inspection
shortages cause the inspector to not go to these plants because of the inspection shortages- it
doesn't show up as "not performed" because inspectors are not to mark unscheduled procedures
as not performed procedures on PBIS. Also inspectors are increasingly being told to double or
triple cover because of inspection shortages and if necessary to just look at company records,
then get to the next plant.
Also, if you notice the "New and Improved" PBIS that is supposedly showing why
procedures are not performed--they still did not put in a place for the inspector to mark not
performed "Due to Inspection shortage". The only place an inspector has to fill out is "Other"
with no explanation why. So in reality they improved nothing when it comes to showing
procedures were not performed due to inspection shortage. So people that read PBIS (like you)
will still not be able to tell if they were not performed due to inspection shortage.
You will not see it in writing anywhere, but pressure is put on inspectors to not enter
"Not performed" in PBIS. When inspection shortages occur and inspectors are assigned double
duty or triple duty, they are told they have plenty of time to perform all the procedures in all of
the plants. The inspector feels he (or she) will suffer the consequences if not marking Performed
in all the plants on all the procedures. I talked to an inspector from Mississippi 2 weeks ago and
he said that in the poultry plant he worked at many violations were corrected but not recorded on
Noncompliance Records (NRs) because there is not enough time to fill out NR's. And inspectors
nationwide are becoming gun-shy about writing NR's unless they have plenty of time to reread
and revise the NR's because supervisors are holding them accountable to writing the NR's the
way their supervisor thinks they should be written. The funny thing about that is every supervisor
4
has a different opinion of how they should be written. I was at FSRE training [time redacted]
and discussion came up about NR writing and everyone there was told by their supervisor a
different way to properly write a NR. The HACCP instructors said they realize this is a big
problem and have tried to tell upper supervision to stop this and have a set standard to write NR's
but they realize its still going on in the field. . . .The inspectors I talked to from across the nation
at FSRE training are losing any trust they had in upper FSIS management.
They are partially correct that the other shortages are caused by inspectors getting sick—but
now they don’t have any relief inspectors that are extra to fill in for people getting sick or
needing off for an emergency. All relief inspectors are now being assigned in advance to
positions to fill because of vacancies or annual leave, and because of that they do not have
anybody to put in place when an inspector gets sick, needs a medical appointment, or has an
emergency - like they did several years ago. This agency continues to cut back on field
inspectors and hire more management positions, and managers don’t work inspection duties.
Don’t know if this went on last year but sometimes upper management gives each other
incentive awards during the year and that is on top of the bonuses given during that year.
I think I had 3-4 days that were impacted because of ice & snow where I couldn't visit all the
plants. You know how bad this Agency lies about things! They've been talking for about a year
about splitting up this assignment. My boss even got on [me] a little bit because he wants us to
document at least one meeting per week with each plant. I just flat out told him it isn't going to
happen unless I have the time to do it. Now with this new plant coming up [location redacted],
that will add an additional 130-140 miles a day to my assignment. That should put me over the
300 mile/day mark.
Even the EIAO has complained that we cannot be providing much coverage to these plants
when you can only visit them 15-30 minutes a day. Even less time when the roads are [blocked]
during the winter months.
Its not just the plants Raymond admitted about that are not getting daily inspection. The
only reason he admitted to them is he was told in advance that the congress woman already had
proof it was happening. But he didn't tell her about the many other plants not getting daily
inspection because of not having enough inspectors. And he didn't tell her about inspectors being
harassed out of taking sick leave for medical purposes or family leave (doctors appointments,
funeral leave, etc.) because the agency had no one to cover for them and instead of admitting the
problem and fixing it they rather harass inspectors out of taking leave they are entitled to.
Many plants under full time inspection are not receiving daily inspection. Just last week the
plants in [location redacted] didn't receive any inspection on Monday, Wednesday, and Thursday
because that inspector was sent to [a slaughterhouse in location redacted] to cover online
shortages. The District office was notified that an inspector was needed to cover those plants but
sent no one, so no inspection of these plants were performed on those three days. This has been
going on for years. Many times other inspectors have been told to cover the [location redacted]
plants when that inspector was sent to [slaughterhouse] but the inspector was already doubling
assignments and couldn’t possibly perform inspection in [location redacted] so was instructed to
5
“Just go there and look that at the paperwork is good enough.” Even then most of the plants were
done for the day by the time the inspector was able to get there.
[From an inspector in a slaughter plant]. We are currently short three people this week and next.
We are always short at least two people. We have to rush through our tests. Last night I had the
floor all to myself for one period. I had four food safety tests, a PBIS test and a flock change,
which consists of ante-mortem and leukosis test. So far we have managed to make all our tests,
but I can assure you that we have compromised the quality of our tests.
[It] is simply untrue [that all violations are documented]. We all know that if we write all
the NRs that we should we would make life difficult for your fellow inspectors. I am sure that
we could write NRs for [sanitation performance standard] violations every day. The agency
would frown on this, even though we were taught to write all violations.
As time goes by we have less and less inspection. Let me give you just one example. We
used to do 2 [finished product quality standards tests] per day. Now we do only one, and that is
when it is scheduled, which is seldom. The agency claims that since it is not food safety it is not
as important.
I beg to differ. The reason it was not food safety, is because they will not let it be. When
we find fecal in the livers and gizzards, it is not called a food safety issue! Why? Salmonella
and E coli testing is not done on the liver and gizzards. Why? Let me tell you why. It is simple
-- fecal is there all the time! If you watch how the livers and gizzards are harvested you will see
that the gizzards are covered with fecal and the livers are not far behind.
Oh they get sprayed off in the process, but that is inadequate. Let me give you an
example. Not too long ago I found a good size piece of fecal 3/4" in the livers. This was in the
liver packing area. Had I not found it, that piece of fecal would have gone right out to
consumers. We are only able to write these up as a sanitation problem!
Later on that same week two other inspectors found the same thing. The 3rd inspector was
told that perhaps she was looking too close at the livers. As I have said before they do not
perform microbiological testing on livers and gizzards. I have a theory why -- there is no way
that they could pass such a test! Now they do not even have us checking livers on a regular
basis, when actually we should be doing more of the tests.
I just wish the congressmen and senators could see what is never reported in these plants.
I am sure that they would never eat chicken again. I am afraid that the only way to right this
matter is to have a knock down drag out fight in Congress. You need to subpoena some
inspectors in. That is the only way you can get them to talk. Most fear they will lose their jobs
if they say anything.
I talked to an inspector in the [name redacted] District and they are being disciplined if they
mark "not performed" on their PBIS. Again this is another example of covering what’s really
going on in the field. It doesn't matter if the inspector is doing double or triple duty and not able
to finish. Its pressure being put on by upper management to force inspectors to lie on PBIS to
make it look like everything is doing fine and everything is being covered. Then down the road if
something happens they can blame the inspector because PBIS is showing the inspector did all
required procedures. Combine this with inspectors not having time to write NR's and what do
you have? On paper a perfect system, in reality major problems. I wonder if congress is starting
6
to see that upper agency is not being honest with them.
I work in a large swine slaughter/processing plant. We have [several] GS-7 line positions and (2)
GS -7 relief positions and (2) [processing inspection] slots. Of course the 7's positions are always
vacant and we [processing inspectors] spend 95% of the time covering for the empty and missing
7 slaughter inspectors. Things happen, I know, but why are we always short staffed in the first
place? As far as doing the processing side, that is in last place. . . We work a lot of overtime.
At the time there were many reasons as to why these were not being performed . . . BUT one
factor that the agency will fail to admit to is that their vacancy rates were so high that inspectors
were having to double/triple up so much, that PBIS tasks were impossible to complete as
scheduled. Remember Dr. Raymond made the statement that the agency didn't need any more
funds but when [consumers] put the vacancy figures out there he was made to appear that he had
no clue of what was going on in the field. I guarantee you that Bill Smith [Assistant
Administrator of the Office of Program Evaluation, Enforcement, and Review] and Ken Peterson
[Assistant Administrator of the Office of Field Operations] knew, because the National Joint
Council [union] told them and requested that they implement a means of tracking why scheduled
PBIS procedures were not being performed because field inspectors were being blamed for not
doing their jobs
After that the agency then incorporated these “management controls” where the
supervisors would have to explain why the ‘not performed’ scheduled tasks percentages were
higher in the plants they supervised than the average assigned by the Washington Bureaucrats.
When these numbers could not be controlled and the supervisor was having to explain why the
same assignment, such as mine, were well below the averages I was told to turn the PBIS task
generator off. When the ‘not performed’ codes came available I requested that I turn the
generator back on and was told to do so. This takes quite awhile for this to happen so my
assignment still is NOT generating PBIS tasks and ALL that I perform are unscheduled tasks. It
is this way right now today but may change next week, who knows when it will happen. This
and any data acquired by the agency for the agency is just like any statistical data, it can be
skewed to meet the expectations of the beholder. I'm sure these groups that collected data for the
HACCP-based Inspection Models Project as well as this RBI data have been told by the agency
up front what they wanted the data to appear like.
Almost all of the processing inspectors anymore travel to other plants unless they are in a
large slaughter plant. I for instance may cover 5 plants in 8 hours with 45 minutes travel time
between the closest and the farthest.
The problem is that when you have this many plants, one doesn't have time to write up all
deficiencies. We bring things up to their attention and follow up that they take care of it but there
is no paper trail because of a time factor. Also when we write a NR we need to write a cover
letter unless we can put their corrective actions on the NR.
Then with Management controls we need to perform food safety procedures at a
minimum of X percent. Otherwise we need to write our Front line Supervisor and tell him why.
So there are times when we do not perform a quality procedure but we mark it as performed
7
because of the extra hassle. They are forcing good inspectors to falsify our records so they can
say everything is good.
No wonder NR numbers are down. It will be bad when all of us old timers that still do
some traditional inspection retire as I don't think the new inspectors have a clue what we use to
look for and some still do.
[Instructions to an inspector who was doubled up].
From: Front Line Supervisor
Sent:, [Date redacted] 2007
To: CSI
Subject: RE: Non reimbursable overtime
Good morning CSI,
When you will be covering Inspector’s assignment you are to perform only Food Safety and
Food Defense related activities and could drop other consumer protection activities. Your first
choice for 01B02 (pre-op sanitation) should be to perform this procedure for your own
assignment if the procedure is scheduled for both assignments. I did not rule out the possibility
of authorizing non-reimbursable overtime for conducting 01B02 however we need to consider
the history of plant compliance, type of product being produced by the establishment and the
available resources. Any administrative overtime worked will be justified and authorized if and
when necessary by Resource Management Staff in District Office or your supervisor.
Thanks.
Questions and Answers from the November 2006 Labor Management Relations meeting in
Denver.
Q. Please provide information on [Establishment redacted]. This position has been vacant for
some time and is very isolated. Are there plans to fill this vacancy soon?
A. The agency is looking at adding duties to this position to include inspection of processing
plants, Import duties, EIAO duties and OPEER [Office of Program Evaluation, Enforcement and
Review] duties. It is not decided at this time if all or just some of these duties would be part of
the position.
Q. I would like someone to ask about filling vacancies in the Olympia circuit or at least allowing
us to utilize our own relief inspection personnel on these vacant assignments. We have been
doubled, even tripled down here. It seems that every week our relief inspectors are either in the
Portland circuit or in the Spokane circuit. I would hope that those circuits can fill their own
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vacancies/relief positions that evidently exist there so that the Olympia circuit can be covered
with our own relief inspectors.
A. The District Office is trying to fill vacancies. However the District Office must follow
Washington D.C. direction and not exceed the ceiling for the number of employees Washington
D.C. will allow for this District. Therefore the District office must fill positions were the greatest
need exists. Further the relief personnel in the Portland / Spokane circuits are not just for those
circuits. Relief personnel must be utilized by the agency to fill positions were the greatest need
exists. This could be any where in the District or USA to include all states and territories as
needs require.
Q. How can CSI’s in the field get better computers (newer) and ones that work so we can do our
job properly?
A. The agency renews computers & printers every 5 years. If a specific problem arises then
FAIM should be contacted.
Q. CSI’s are to use computers to do PBIS, eARDS, outlook, AGlearn. If it is difficult to do this
because your computer is too old and bogs down and CSI’s call FAIM like we are told to and
they say it is to old, call your DO and request a newer one, and you do that and it seems like you
are brushed off, how are we to do our job properly??
A. Employees should call the next level of supervision if they can not obtain needed information
or supplies.
Q. Are all inspectors responsible for all plants that the team covers?
A. The team is responsible for the assignments.
Q. If one inspector within the team is sick one day or there is a vacant assignment and the other
inspectors cover additional plant for that time (day / years) is this still considered doubling?
A. The team is responsible for the assignments there is no doubling.
Q. The Union has heard that in team inspection one inspector may train one day while the other
inspectors cover the assignments. If there is a vacancy within the assignments covered by a team
how would the remaining inspectors get time to train?
A. Vacancies could impact the assignments however the team will have to designate time for
each CSI to train.
Q. Inspectors have been doubling and covering each other’s assignments for years to cover for
sick leave and vacancies. How is team inspection different than what is already being done?
A. Yes, Team Inspection is not a new idea. However the team will determine the best utilization
of agency personnel to provided need coverage of assignments.
http://www.foodandwaterwatch.org/food/foodsafety/meat-inspection-1/FINALNoInsptFromInsp.pdf
>>>We would like to remind you that we have a pending Freedom of Information Act request
regarding inspector vacancy rates that you promised two months ago would be answered
imminently. We still have not received an official response from the agency.<<<
JOIN THE CROWD !
FOIA REQUEST FOR ATYPICAL TSE INFORMATION ON VERMONT SHEEP
Re: FOIA REQUEST FOR ATYPICAL TSE INFORMATION ON VERMONT SHEEP (4843 lines)
From: Terry S. Singeltary Sr. <[log in to unmask]>
Date: Mon, 2 Apr 2007 14:43:32 -0500
http://lists.ifas.ufl.edu/cgi-bin/wa.exe?A2=ind0704&L=sanet-mg&T=0&P=816
THAT 10,000,000 PLUS POUNDS OF TAINTED BLOOD LACED BANNED MBM THAT WENT OUT INTO COMMERCE
LAST MONTH, sadly is just the tip of the ice-burg. the 8/4/97 ruminant to ruminant feed ban was nothing more than ink
on paper. ......snip......end
TSS