Earlier this year, National Meat Association held its 50th Annual Convention in San Francisco. There’s something about anniversary events that brings out special efforts to look at where we’ve come from over the earlier decades, and to look forward into the future. My congratulations to your staff who have worked hard to put in place all the appropriate activities that you will enjoy these next few days.

The Livestock Conservation Institute has a proud and long history since it was formed in 1916 when an outbreak of bovine tuberculosis threatened the livestock industry and the health of millions of Americans. It seems like something of a coincidence, certainly not part of the staff planning for the 80th anniversary for your organization, that unconfirmed scientific linkage from what some call an epidemic in the United Kingdom of bovine spongiform encephalopathy and the human illnesses and death from Creudstfeldt-Jacob Disease was made in the city of my birth, Edinburgh, Scotland last month. This unconfirmed linkage has turned off the European appetite for beef faster than we could have believed. We in the United States are watching, knowing all too well the short step from spectator sport to victim.

The current wave of concern about possible animal linkage to a very ugly human disease provides LCI with new opportunities to continue its efforts to eradicate animal disease. National Meat Association is pleased to be here today to thank you for the many past efforts and to assure you that we will partner with you for the future.

You have asked me today to speak to the issue of Meat Inspection - Moving Toward the year 2000. It’ll be hard to tell you everything I know in twenty minutes or less, but we’ll try!

We’ve been talking about HACCP since the mid-1980s when the National Academy of Sciences recommended it and it was subsequently defined for application to the meat and poultry industry by the Inter-Agency Microbiological Criteria Committee. Events were moving swiftly, too swiftly for some, so it got sidetracked into a public "round table" forum held in the summer of 1993 in Washington. Public advocates at these events expressed their distrust of science without good watchdog protection by government regulators. We need to remember that all of the food safety events held after February 1993 reflect the long shadows of the Jack-in-the-Box cluster crisis, and are attended by strident calls for absolute safety of raw meat by consumer advocacy groups.

While this was going on, the industry was not sleeping on the sidelines! In 1994, the International Meat & Poultry HACCP Alliance was formed under the leadership of Dr. Russell Cross at the Center for Food Safety at Texas A&M University. National Meat Association is proud to be a charter member. Through the Alliance, the industry began to organize its effort to provide classes to train operating people in the industry in HACCP. The Alliance developed curriculum, provided appropriate course outlines, and maintains a registry of people who have attended training. It also provides accreditation for the educator component for classes. Each association that sponsors training has some options. National Meat Association holds a course in cooperation with an accredited educator organization, about once every 4 to 6 weeks, in different locations that are accessible to members. We choose to limit size so that attendees can receive some individualized attention as needed, and we ask our educator sponsor to set up a final examination.

In February 1995, we all watched as Acting Under Secretary Mike Taylor unveiled his "mega reg" which was followed by a series of briefing meetings. I attended the first one in Oakland, California and was dismayed to not have an opportunity to have interactive Q&A discussion with the panel of FSIS experts who described various aspects of the proposed rule. Yes - we could ask questions, so long as they were written on 3X5 cards and sent up to the moderator to be read and then answered. No follow-ups were allowed. The same pattern was used in the other five briefings. There were then some "technical/scientific conferences" to which there were invited spokespeople. There were two public hearings, the first in Kansas City, Kansas which was specifically designed to receive comments from small businesses. The place was jammed, and I attended presenting both our views and those of our sister organization in Hawaii. The second public hearing was in Washington in June 1995, and each speaker was limited to 7 minutes with 3 minutes for questions by the panel led by Mr. Taylor. Again, I attended and presented our views. National Meat Association also submitted written comments for the record.

We were very dissatisfied with the fact that there was no opportunity for meaningful discussion about the broadest and most sweeping changes to the meat and poultry inspection program since its inception. Specifically, Mr. Taylor promised our officers, in a meeting in his office the previous October, that he would provide a forum more like negotiated rulemaking than the traditional notice and comment rulemaking. What we observed and participated in 1995 simply did not allow the needed discussion and dialogue on major issues. So we led a group of organizations to petition the Secretary of Agriculture to institute formal negotiated rulemaking. The Secretary was still pretty new to the job; he consulted with Mr. Taylor; and he turned us down. With no other alternative at the Executive level, we turned to the Congress and Congressman Jim Walsh of New York introduced an amendment to the Appropriations Bill to provide for negotiated rulemaking.

After this passed the Appropriations Committee, it came to the attention of Secretary Glickman and he met with the Congressional leaders and worked out a compromise. The compromise was meaningful discussion in a series of meetings in September 1995, all of which I attended.

Mr. Taylor attended throughout the six days; the Secretary himself attended as his schedule permitted; one of his senior staffers was always there. They were unique meetings, and a great deal of expertise was assembled and provided input. One of the curious artifacts was the new information provided to attendees each day and described as the agency’s "current thinking" on each issue as it came before the group for discussion. We hope that some of the "current thinking" was modified, given the eloquence of input that the agency received over the six long days. We still don’t really know because we still have not seen the final rule. It’s promised every day.

However, a document this huge has many cooks stirring the broth. Also, as most of you know there are certain requirements that must be met in rulemaking. One of the newer ones is that such a rule must be reviewed by the Office of Risk Assessment and Cost Benefit Analysis. This is a new entity set up within the Department, with USDA’s Chief Economist in charge. This office was set up by a provision in the 1990 Farm Bill, but USDA dragged its feet and it was not in place to review the proposed rule of February 1995; it has reviewed the final draft, it complained of the shortness of time for its review, and it criticized two very specific aspects of the final rule. It told FSIS, in a March 19 report, that the Use of Baseline Surveys to Recalibrate Process Control Standards is flawed; and that Measurement Error Induced by Carcass Sampling Undermines Process Control Methodology is unacceptable. There were two lesser issues: Requirement for E.coli testing and the inadequacy of the risk analysis strategy. FSIS was reported in this week’s Food Chemical News as having fixed the problems. It’ll be interesting to see how they have fixed them. The problem with the baseline surveys is that they took large tissue samples off each carcass that was sampled, and in the final regulation, FSIS would use a sponge technique. Obviously, from a microbiological viewpoint, this is comparing apples with oranges, and it is surprising to me that FSIS failed to understand this.

The Congress has come to recognize that something is not working right at FSIS with respect to the sciences. The Farm Bill that the President has just signed includes a provision that establishes a Meat & Poultry Safety Panel comprised of scientists to assist FSIS in developing science to support the program. Their help is not warmly received at the agency.

It seems to us at National Meat Association that there is abundant support from all parties of interest to go forward with HACCP in a final regulation. The problem is that consumer advocates neither understand nor trust HACCP. They have a sympathetic ear at the court in the form of a political lawyer who is not only the Administrator of Food Safety & Inspection Service (the very first purely political appointment in the agency’s history) but also the Acting Under Secretary for Food Safety. They say they want HACCP, but they really want microbiological performance standards. These have become almost a standard of clean versus not clean! They prefer to argue the "why not’s" rather than get to understanding HACCP, and the fact that some kind of microbiological testing can be part of confirming that a critical control point is being met, but is not a "pass" "don’t pass" finished product test.

We have asked Mr. Taylor to go ahead with a HACCP final rule and divorce it from the other questionable and still debatable parts of the mega reg. We’ve heard through the hall talk that he must honor the demand of consumer activists for performance standards. We and others who have also asked him to move ahead quickly on HACCP are still waiting for his response.

Just yesterday, our Washington Counsel visited the Office of Management and Budget along with other organizations to inform these officials who will shortly be reviewing the final rule to separate HACCP and move it ahead separately from the other microbiological standards. I am not terribly encouraged that this will happen.

The bottom line is: There will be changes to the meat and poultry inspection system by the year 2000. I believe that we will have substantial use of HACCP systems; I am somewhat fearful that system failures will be misinterpreted, at least by consumer activists. I expect that the meat and poultry system will more resemble the FDA inspection system as we know it today, but there will still be a strong presence of field inspectors. There needs to be huge improvement in the field management, especially of the command and control type inspection behavior that exists in many plants in this country. To this end, National Meat Association is engaged in efforts with FSIS to improve the working relationships. It’s going to be an interesting time!