ADVANCEMENT OF THE SCIENCE
2022). PHVs are directed by PHIS to ran- domly select a carcass and excise choice tissues such as kidneys, livers, or muscles. When FSIS collects a sample, the slaughter company provides the address of where the animal originated. Pending the results of testing, the company is to hold the carcass and o al. The choice tissues are sent to an FSIS laboratory for testing of potential illegal injections or feeding of the livestock with antibiotics or hormones by the farm ani- mal producers. The illegal chemicals could have detrimental e ects on the consumers of meat and poultry products. If the labora- tory results are negative for illegal chemi- cals, the carcass and o al are released, and there is no violation against the farm ani- mal producer. If the choice tissues show a laboratory result of an illegal chemical or drug, the carcass and o al are condemned, the producer is warned and placed on a list of residue violators, and the livestock from that producer is closely monitored by slaughter companies and FSIS. Food inspectors on the slaughter line can segregate for veterinary disposition a carcass that appears diseased and possibly unfit for human consumption. If a PHV is suspicious that this pathology is due to illegal residues of hormones or antibiotics, the PHV will collect a kidney and run a kidney inhibition swab (KIS) test, which is a screening test for antibiotics and hormones. If the KIS test is negative, then there is no potential violation, and the carcass and o al are released. If the KIS test shows a positive result, then the kidney, liver, and mus- cle tissues are excised from that carcass. These tissues are sent to an FSIS laboratory to deter- mine if the positive KIS test is the result of an illegal use of antibiotics or hormones. Rules of Practice A regulatory control action is when CSIs retain product, reject equipment or areas, or stop production. A withholding action is when FSIS refuses the mark of inspection (e.g., branding, packaging materials with inspection legends) to be applied to products. Whenever FSIS inspectors or EIAOs determine that an enforcement action is required against a com- pany, it is completed in accordance with FSIS regulations (Rules of Practice, 2023). Parts 500.2 through 500.7 of the Rules of Practice give more detail about the reasons
for FSIS to take such enforcement actions, how companies can appeal the actions, how establishments might come into abeyance (i.e., suspension), conditions for withdrawal of inspection rights, and refusals of grant of inspection to establishments that are found unacceptable. Part 500.8 describes condi- tions for rescinding product labels. Whenever enforcement actions leading to a suspension are taken, case files are created. If companies have committed a potential crime, the case files are provided to the Oce of Program Evaluation Enforcement and Review within FSIS, where the matters are investigated for possible criminal prosecution. Technical Support FSIS inspection is a team e ort. Whenever FSIS inspectors have urgent issues and need assistance or guidance, there are knowledge- able supervisors to contact for advice and support. Those supervisors can contact upper management for further assistance. For ques- tions about technical concerns, FSIS inspec- tors can contact askFSIS (www.fsis.usda.gov/ contact-us/askfsis) online or call 1-800-233- 3935. Sometimes the technical questions can lead to changes in national policy. Part 4 Summary Companies are encouraged to have written procedures on food defense against threats of potential contamination. CSIs check for vul- nerabilities and, if vulnerabilities are found, CSIs meet with the companies and document the meeting using a memorandum of inter- view. Zero tolerance is monitored by FSIS and is mandated to prevent fecal, ingesta, and milk contamination of carcasses and o al in slaughter companies. In addition, FSIS requires companies that slaughter livestock to conduct testing for generic E. coli to determine if their processes are under control. The Pathogen Reduction Performance Standards require companies to test for acceptable levels of Salmonella and Campylobacter . At a frequency determined by OPHS, FSIS is directed to collect ground beef samples to test for pathogenic E. coli as well as fully cooked products for Salmonella and/ or L. monocytogenes . When directed, FSIS collects aseptic products or sponge samples of carcasses for national baseline studies and/or to verify food safety e ectiveness. Antimicrobial enteric
samples are taken as part of the NARMS program to better understand antimicrobial resistance. The National Residue Program requires FSIS to select carcasses and remove choice tissues to test for potential illegal injections of antibiotics or hormones into the livestock. The Rules of Practice given in the regulations describe actions to be taken to bring noncompliant companies either into compliance or complete closing. Series Summary and Conclusion FSIS inspects regulated companies from the time livestock first enter the slaughter com- panies to the point where the derived food products are shipped to consignees. Nonfed- erally inspected warehouses, stores, and even consumers are contacted by FSIS regarding FSIS-regulated products, indicating a large range of inspection responsibilities. FSIS uses utensils and organoleptic measures to determine food safety of carcasses and car- cass parts in slaughter companies. Observa- tions are made, data are reviewed, records are checked, microbiological and chemical samples are taken and analyzed, and prod- uct labels and written food safety systems are scrutinized. Actions are taken accordingly, and documentation is created to protect pub- lic health in regulated companies that pro- duce meat and poultry products. Of note, this series is not all-inclusive or com- prehensive. For example, it does not include egg inspection, pet food, canning, cooking/ cooling times, and temperature controls. Professionals in a food safety career in another government agency will note that there can be considerable di erences between their agency policies and the policies imple- mented by FSIS. For example, the author is not aware of any government food inspec- tion agency—other than state agriculture agencies—where government regulators have permanent oces inside the companies they regulate. The FSIS education requirements might also be a surprise to food safety inspec- tors in other government agencies. The author has noticed little mention of federal meat and poultry inspection in the Journal of Environmental Health . The aim of this 4-part series, therefore, is to inform environmental health specialists of the duties and requirements of federal meat and poultry inspectors. This series fills an infor- mation gap about public health protection—
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Volume 86 • Number 2
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