How Food Safety for Meat Does and Does Not work in the US

No, you can't just fire bureaucrats and have it all be fine

DOGE is gonna start firing people! On Day 1! People are ON NOTICE.

Leaving aside that the efficiency department has two heads, let’s talk about how animal based protein food is regulated in the US.

1- At the local level

• Retail establishments like your local butcher shop (if you have one) or your local restaurant. These are regulated by something called The Food Code. The Food Code is published ever 2 years by a group of institutions and people generally called the Codex. The FDA will write the Food Code and then urge adoption across localities. However, every health department can have it’s own food code. Most large cities have their own. Many counties have their own. Some are just copied from the Federal Food Code, some bear no resemblance at all. Some require very detailed HACCP (Hazard Analysis for Critical Control Points) plans for almost anything that isn’t heat and eat, some don’t require it for almost anything.

• Wholesale establishment- There are 27 states with their own meat inspection programs. This means that there are state employees who inspect establishments. These tend to be small companies and with a couple of exceptions, they can only sell in the state they produce in. However, there’s a giant grey zone about whether those products can go across state lines. FSIS (The Food Safety Inspection Service) of the USDA AKA the meat inspectors…say no. But in practicality, how on earth are they going to police that?

• There’s one weird program with 7 states, essentially in the SEC where the state inspectors are deputized as federal inspectors, and the plants they inspect can sell across state lines.

2- The Federal level

• If you want to sell meat across state lines, by and large you need to be inspected by a federal inspector. FSIS does this inspection. They authorize the USDA stamp that you are used to seeing.

Some other things about inspections:

All slaughter for sale into the commercial food stream must conform to the Animal Welfare Act and the AVMA Guidelines for the Humane Slaughter of Animals. There’s all sorts of rules here about what gets passed and what does not. There are rules about Kosher and Halal slaughter. There are rules about what gets slaughtered first and last. Rules about cleanliness. Slaughter is INCREDIBLY messy and keeping all the dirty parts of an animal (of which there are many) off the parts you want to sell for food takes a high level of training, attention to detail and skill.

All ground beef has an extra set of rules because of Shiga Toxin E. coli problems, and recently salmonella problems.

All ready to eat meat has an extra set of rules around the control of listeria and salmonella.

As I write this, another 72,000 pounds of ready to eat meat is being recalled. And Thanksgiving is in 48 hours. It’s because of Listeria.

Just some of the stuff I’ve seen. Photo by Michele Pfannenstiel

Why is this all happening?

There are a LOT of answers to this question. The number of things that need to go wrong for contaminated meat to get into the food stream is truly staggering.

That said, I’ve done a LOT of recalls with companies and here’s what I think characterizes most of these giant recalls.

• The people in the factories are not safe. Safety at work is a matter of physical safety, financial safety and emotional safety. I have never been in a company in the middle of a recall where people feel safe at work. Never. People are afraid to speak up. They are afraid that what needs doing costs too much money. They are afraid of getting their heads based in.

• The people in the factories are not trained to effectiveness. Sure, everyone says TRAIN MORE. It’s the USDA’s favorite corrective action tool. However, unless your training is aimed at doing this better, it doesn’t help. There is a staggering amount of bad training for meat employees out there. And don’t get me started on the extremely variable level of training of the inspectors. State inspectors are simply not trained to the level Federal inspectors are. The difference? The Federal inspectors are unionized. Very few state inspectors are. Also…there are not nearly enough inspectors.

• Management does not respect the process. Food safety in meat production is done through an engineering concept called Failure Mode Effect Analysis. The simple explanation is…how does the process work, where does it break, and how do measure in the best spots to know it is not broken? This process for food safety is the HACCP process. I’ve trained thousands of people HACCP by now and most people are doing it to get it done. Not because doing it well might keep people alive.

• Management fails to invest their time, talent and treasure in doing the right things. Frankly, a listeria recall like we are in is a failure of basic sanitation. I have never been in a facility that is letting their soap sit on their production equipment for 7 to 10 minutes that has a listeria problem. Never. I have been in plenty of meat processing plants where I’m helping them fix a listeria problem and I’ve timed how long that soap stays on there…longest I’ve ever clocked someone is 3 minutes, shortest is 90 seconds. Keeping your plant listeria free is a matter of letting the clock run out and soap contact time.

• I’ve been in plants where management clearly does not value the work of keeping things clean, doing the process right, and creating a culture where the animals and the people have dignity and respect. Does it take more work? Sure, but it also sucks a lot less.

• Finally, I’ve never been in a plant in a recall situation where the management got there because they tackled problems head on. They get there because they avoid problems, don’t talk about anything, fake records and try and skirt the regulations. These folks don’t remain my clients for long.

No matter what the incoming administration does about food safety regulations (and yes, some of them are truly staggering in their stupidity) it will remain illegal to sell contaminated food.

The only question is how much authority the state or feds are going to have to do anything about it. I mean, look at the current recalls. The system failed, people have died. And that is in inspected plants. Imagine what happens if we take the inspectors out all together?