oversight

Consumer and Marketing Service's Enforcement of Federal Sanitation Standards at Poultry Plants Continues To Be Weak

Published by the Government Accountability Office on 1971-11-16.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

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        REPORT TO THE CONGRESS

                                    lllllIlllllllllllllllllllllIIIIIllIllIIllIIIlII
                                            LM095479
                                                                        Q.
                                                                   c-

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        Consumer And Marketing Service’s
        Enforcement Of
        Federal Sanitation Standards
        At Poultry Plants
        Continues To Be Weak            S-163450




        Department of Agriculture




        BY THE COMPTROLLER   GENERAL
        OF THE UNITED STATES
                       COMPTROLLER        GENERAL       OF   THE      UNITED    STATES
                                        WASHINGTON,      D.C.      20548




      B-163450

      To the     President      of the Senate and the
‘-i   Speaker      of the    House    of Representatives

               This is our report          pointing   out that the Consumer      and
      Marketing     Service’s       enforcement        of Federal   sanitation  stan-
      dards    at poultry    plants      continues    to be weak.    The Consumer
      and Marketing       Service       is a constituent     agency   of the Depart-                        _A
      ment of Agriculture.

               Our review    was made                 pursuant  to the Budget                   and Ac-
      counting    Act,  1921 (31 U.S.C.                53), and the Accounting                    and Au-
      diting   Act of 1950 (31 U.S.C.                  67).

               Copies of this         report  are         being  sent to the Director,      Of-
      fice of Management              and Budget,          and to the Secretary     of Agri-
      culture.




                                                         Comptroller                  General
                                                         of the United                States




                               50TH     ANNIVERSARY                  1921-     197t
                   .
        'COMPTROLLERGEUERAL'S                                     CONSUMER AND MARKETING SERVICE'S ENFORCEMENT
         REPORTTO THE CONGRESS                                    OF FEDERAL SANITATION STANDARDS AT POULTRY
                                                                  PLANTS CONTINUES TO BE WEAK
    I                                                             Department of Agriculture  B-163450


        DTGEST
        -5----


         WHYTHE R23VIEMWASMADE
    I
                   The General      Accounting         Office      (GAO) made this       follow-up       review b.A...-_-~.
                                                                                                                    at poultry
                                                                                                                            ..L . I.
                   plants     to determine       whether        the Consumer and Marketing             Service      had improved
                   twenforcement          of.san.itation           standards      after  GAO's earlier         reviews.        This
                   reviewmed             68 federally           inspected      plants,   including       17 of the 40 plants
                   GAO covered      in its prior          review       and 51 plants     selected      at random from five
                   of the leading        poultry       slaughtering         and processing       States.       The 68 plants
                   accounted     for about 19 percent                of the 13 billion        pounds of poultry          slaugh-
                   tered    in the United        States       in calendar       year 1970.


        FINDINGS AND CONCLUSIONS

                  Enforcement of sanitation                    standards
                  still  weak

                   Following   GAO's earlier     reviews,     the agency took                    some actions      to   improve
                   the enforcement   of sanitation        standards,   including:

                       --Sending     letters       to its inspection         program      employees,       including       plant
                          and supervisory          inspectors,    clearly       outlining       inspection        objectives
                          and sanitation          procedures    and assuring          each employee        full    support
                          for his efforts          in enforcing     sanitation         standards.

                       --Issuing     revised proceduress      forms,     and instructions,                  including      criteria
                           for withholding   or suspending       inspection,      to assist               inspectors       in carry-
                           ing out the agency's     policies.        (See p. 12.)

                   The actions     taken by the agency have not been successful                   in achieving      ade-
                   quate enforcement        at the plants       GAO visited.        For each of the 68 plants,
                   supervisory     inspectors,       who accompanied       GAO and evaluated        each plant    for
                   compliance    with the agency's        standards,       reported    some deficiencies.         The
                   types and extent       of the deficiencies,          classified      as either    minor variations
                   or unacceptable       conditions,     varied    from plant       to plant.

                   The evaluations             showed   that     unacceptable      conditions:

                       --Continued       to exist at most            of the 17 plants          covered     in GAO's prior
                          review.      In many cases the             conditions were         similar     to those pre-
                          viously     noted.




I       Tear   Sheet
                                                                                             I
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                                                                                            I


      --Existed  at most of the 51 randomly selected plants.      At many of these
         plants, the conditions   appeared to be of a long-standing   nature and
        were similar  to conditions   noted at most of the 17 plants.

    Four case studies    illustrating  the types of sanitation  problems at the
    plants GAO visited     are included on pages 19 through 39.

    After most of GAO's fieldwork had been completed, the agency implemented a
    revised regulation   providing criteria  on the amount of moisture which may
    be absorbed and retained in poultry during processing.      When the amount
    of moisture absorbed is determined to be above the specified       limits,    the
    inspector is to require that all poultry processed be held and drained
    to acceptable levels.     Because of the timing of the regulation's      imple-
    mentation, GAO did not determine how well it was being implemented.
    (See p. 48.)

    Conclusions
    Many of   the sanitation    deficiencies  appeared to have existed over a long
    period.    In GAO's opinion, this situation is indicative      of a lack of
    strong,   day-to-day enforcement by the agency's plant inspectors and of a
    lack of   effective   supervisory review.    Weaknesses in the agency's enforce-
    ment of   sanitation   standards may be widespread.

    Adequate criteria    and policies now exist for enforcing sanitation standards.
    Such criteria    and policies,   however, provide only a basis for improving en-
    forcement.    In the final analysis the effectiveness    with which sanitation
    standards are enforced depends on the resolve of the agency's employees
    at every level--from     plant inspectors to Washington officials.

    Ways must be found to demonstrate convincingly   to the agency's inspection
    employees that consumer protection is the main objective of enforcing sanita-
    tion standards and that strict   enforcement of such standards
                                                             f      is essential.
    (See p. 41.)


RECOMMEIVDATIOiVS
            OR SUGGESTIOflS
    In August 1970 two consultants hired by the Department of Agriculture   com-
    pleted a study of the agency's consumer protection   programs. The consul-
    tants recommended a number of changes for reorganizing    the programs. Most
    of the recommendations were adopted; however, one recommendation--that   a
    separate agency be established within the Department for consumer protec-
    tion programs--was not. The consultants stated that the recommendation was
    predicated on their belief that:

      --There is an inherent difference       between the nature of the agency's
         marketing activities and that of its consumer protection      activities
        which creates an internal   conflict.
      --Consumer protection     is so large an area and has such complex problems
         that it needs a full-time    administrator.



                                         2
i         GAO recommends      that  the Secretary        of Agriculture         reevaluate    the consul-
I         tants'   recommendation      because GAO believes           that    implementation      of the
I         recommendation      would demonstrate       convincingly         that    the Department    was
I         placing    emphasis    on consumer    protection.
I
I
I         GAO recognizes     that,    should     the Department       adopt the consultants’ recom-
I
I         mendation,     its full    implementation      would take some time.          Also,  if a
I         separate    agency were established         within    the Department,       many of the em-
I
I         ployees    now responsible      for enforcing      sanitation     standards    would continue
I         to be responsible.
I
I
          For these reasons     GAO recommends   also that    the Secretary       explore     other  and
I         more immediate    avenues to improve     and emphasize      the enforcement       of sanita-
I
I         tion standards.      Such avenues might     include an intensification          of efforts
I
I
          already    under way to strengthen    supervision     and to improve       the training
          of inspection    employees   as well  as increased      use of disciplinary         action
          when inspection    employees    do not meet their     responsibilities.         (See p. 42.j


    AGENCYACTIONS AND LWRESOLVED
                               ISSUES

          The Department        (see    app.   I)   said:

             --That      it initially       decided       not to adopt       the consultants'        recommendation
                to establish          a separate      agency because         the consultants        had stated     that
                the meat and poultry             inspection      program       also could function        within     the
                existing      agency and because             one advantage        of keeping     it there    would
                be that separate           administrative        support       functions    would not have to be
                developed.

             --That     the agency was attempting       to respond   in specific    ways to deficien-
                cies    in its supervisory   structure     which had been totally       inadequate
                  and was taking or planning      other   actions  to improve    the enforcement
                  of sanitation   standards.

             --That     the merits    of establishing        a separate   agency should   be considered
                but that,     in its judgment,        it would be a grave error       to consider   the
                creation    of a new agency until          the actions    already  under way and others
                being planned      had been given        a reasonable   time test.


    MATTERSFOR CONSIDERATIONBY THE CONGRESS

          The Congress     may wish to consider       the matters          discussed     in this   and earlier
          reports  in connection      with a number of measures               now before     the Congress.
          These measures     include    bills  to establish          a separate      Department    of Consumer
          Affairs  and the President's        Reorganization           Plan which would transfer           the
          agency's   poultry    and meat inspection         activities        to a proposed      Department
          of Human Resources.        (See p. 43.)




     Tear Sheet                                                3
                         Contents
                                                              Page

DIGEST                                                          1

CHAPTER

   1       INTRODUCTION AND SCOPE                               4
               Federally   inspected plants                     5
               Program administration                           8
               Program costs                                    8
               Other activities     of the Consumer
                 and Marketing     Service                      9

   2       ENFORCEMENTOF FEDERAL SANITATION STANDARDS
           AT POULTRY PLANTS CONTINUES TO BE WEAK             10
               Actions taken to enforce sanitation
                 standards at poultry    plants since
                 our prior review                             12
               Conditions    in poultry plants visited
                 during this review                           16
                    Plant A                                   19
                    Plant B                                   27
                    Plant C                                   33
                    Plant D                                   36
               Conclusions                                    40
               Recommendations to the Secretary
                 of Agriculture                                42
               Matter for consideration     by the Congress    43
               Agency comments and our evaluation              44

   3       REGULATION FOR INSPECTION OF POULTRY FOR
           EXCESSIVE MOISTURE STRENGTHENED                     48

APPENDIX

       I   Letter dated November 2, 1971, from the
             Consumer and Marketing   Service to the
             General Accounting Office                         49

  II       Digest of report to the Congress entitled
              "Enforcement   of Sanitary,  Facility,  and
             Moisture Requirements at Federally      In-
              spected Poultry   Plants,"  September 10,
             1969                                              54
APPENDIX                                                            Page

 III       Digest of report to the Congress entitled
              "Weak Enforcement of Federal Sanitation
              Standards at Meat Plants,"  June 24, 1970              57

   IV      Principal      officials      of the Department of
              Agriculture        responsible   for administration
              of activities         discussed in this report         62

                             ABBREVIATIONS

C&MS       Consumer and Marketing        Service

FDA        Food and Drug Administration

GAO        General   Accounting     Office
COMPTROLLERGENERAL'S                  CONSUMER AND MARKETINGSERVICE'S ENFORCEMENT
REPORTTO THE CONGRESS                 OF FEDERALSANITATION STANDARDSAT POULTRY
                                      PLANTS CONTINUESTO BE WEAK
                                      Department of Agriculture B-163450


DIGEST
_-----

WHYTHE REVIEW WASMADE
    The General Accounting Office (GAO} made this follow-up review at poultry
    plants to determine whether the Consumer and Marketing Service had improved
    the enforcement of sanitation    standards after GAO's earlier   reviews.   This
    review covered 68 federally   inspected plants, including 17 of the 40 plants
    GAO covered in its prior review and 51 plants selected at random from five
    of the leading poultry slaughtering     and processing States.   The 68 plants
    accounted for about 19 percent of the 13 billion      pounds of poultry slaugh-
    tered in the United States in calendar year 1970.


FINDINGS AND CONCLUSIONS

    Enforcement of sanitation     standards
    stiZZ weak

    Following GAO's earlier reviews, the agency took some actions          to improve
    the enforcement of sanitation  standards, including:

         --Sending letters   to its inspection program employees, including plant
            and supervisory inspectors,   clearly outlining    inspection objectives
            and sanitation  procedures and assuring each employee full support
            for his efforts in enforcing sanitation     standards.

         --Issuing   revised procedures, forms, and instructions,     including   criteria
            for withholding  or suspending inspection,  to assist   inspectors    in carry-
            ing out the agency's policies.    (See p. 12.)

    The actions taken by the agency have not been successful in achieving ade-
    quate enforcement at the plants GAO visited.        For each of the 68 plants,
    supervisory inspectors,   who accompanied GAO and evaluated each plant for
    compliance with the agency's standards, reported scmie deficiencies.        The
    types and extent of the deficiencies,    classified    as either minor variations
    or unacceptable conditions,   varied from plant to plant.

    The evaluations     showed that unacceptable   conditions:

         --Continued to exist at most of the 17 plants covered in GAO's prior
            review.  In many cases the conditions were similar to those pre-
            viously noted.




                                              1
       --Existed    at most of the 51 randomly    selected  plants.     At many of'these'
          plants,   the conditions appeared    to be of a long-standing     nature    and
          were similar   to conditions  noted at most of the 17 plants.

    Four case studies         illustrating        the types       of sanitation             problems    at   the
    plants  GAO visited          are included       on pages      19 through          39.

    After    most of GAO's fieldwork             had been completed,            the agency implemented           a
    revised    regulation        providing     criteria       on the amount of moisture            which may
    be absorbed      and retained          in poultry      during    processing.        When the amount
    of moisture absorbed            is determined        to be above the specified            limits,        the
    inspector     is to require          that all poultry         processed       be held and drained
    to acceptable        levels.       Because of the timing            of the regulation's           imple-
    mentation,      GAO did not determine              how well    it was being       implemented,
     (See p. 48.)

    ConcZusions
    Many of     the sanitation        deficiencies          appeared,   to have        existed    over a long
    period.       In GAO's    opinion,       this    situation       is indicative          of a lack of
    strong,     day-to-day     enforcement          by the agency's        plant       inspectors     and of a
    lack of     effective     supervisory         review.       Weaknesses       in    the agency's      enforce-
    ment of     sanitation     standards        may be widespread.

    Adequate     criteria     and policies        now exist    for enforcing       sanitation      standards.
    Such criteria         and policies,      however,    provide     only a basis       for improving       en-
    forcement.         In the final      analysis     the effectiveness      with which sanitation
    standards      are enforced       depends     on the resolve       of the agency's        employees
    at every level --from          plant   inspectors       to Washington    officials.

    Ways must be found to demonstrate         convincingly      to the agency's     inspection
    employees   that consumer protection       is the main objective        of enforcing       sanita-
    tion standards   and that strict     enforcement       of such standards    is essential.
    (See p. 41.)


RECOi'@BNDATIONS
               OR SUGGESTIONS
     In August 1970 two consultants             hired  by the Department           of Agriculture       com-
    pleted     a study of the agency's          consumer    protection       programs.      The consul-
    tants    recommended      a number of changes for reorganizing                 the programs.        Most
    of the recommendations           were adopted;     however,       one recommendation--that            a
    separate      agency be established         within   the Department         for consumer      protec-
    tion    programs--was      not.    The consultants       stated     that    the recommendation          was
    predicated       on their   belief    that:

      --There     is an inherent        difference         between the nature      of the agency's
         marketing    activities        and that of its consumer          protection      activities
         which creates        an internal        conflict.

      --Consumer      protection     is    so large    an area         and has such           complex    problems
         that  it    needs a full-time        administrator.
      .
I




    GAO recommends     that  the Secretary        of Agriculture        reevaluate    the consul-
    tants'  recommendation      because   GAO believes         that implementation        of the
    recommendation     would demonstrate       convincingly        that    the Department    was
    placing   emphasis    on consumer    protection.

    GAO recognizes     that,    should     the Department       adopt the consultants'      recom-
    mendation,     its full    implementation      would take some time.          Also,  if a
    separate    agency were established         within    the Department,       many of the em-
    ployees    now responsible      for enforcing      sanitation     standards    would continue
    to be responsible.

    For these reasons     GAO recommends    also that the Secretary       explore     other  and
    more immediate    avenues to improve and emphasize        the enforcement       of sanita-
    tion standards.      Such avenues might include an intensification            of efforts
    already    under way to strengthen     supervision  and to improve       the training
    of inspection    employees   as well   as increased   use of disciplinary         action
    when inspection    employees    do not meet their   responsibilities.         (See p. 42.)


AGENCYACTIONS AND UNRESOLVED
                           ISSUES

    The Department          (see   app.   I)   said:

          --That      it initially       decided not to adopt        the consultants'       recommendation
             to establish          a separate      agency because    the consultants       had stated    that
             the meat and poultry             inspection   program     also could function       within    the
             existing      agency and because one advantage               of keeping    it there would
             be that separate           administrative     support     functions    would not have to be
             developed.

          --That   the agency was attempting          to respond   in specific    ways to deficien-
             cies in its supervisory       structure     which had been totally       inadequate
             and was taking    or planning      other   actions  to improve    the enforcement
             of sanitation   standards.

          --That     the merits    of establishing       a separate   agency should   be considered
             but that,     in its judgment,        it would be a grave error      to consider   the
             creation    of a new agency until         the actions    already  under way and others
             being planned      had been given a reasonable         time test.


MATTERSFOR CONSIDERdTIONBY THE CONGRESS
    The Congress     may wish to consider      the matters         discussed     in this   and earlier
    reports  in connection      with a number of measures             now before     the Congress.
    These measures     include   bills   to establish        a separate      Department    of Consumer
    Affairs  and the President's       Reorganization          Plan which would transfer           the
    agency's   poultry     and meat inspection      activities        to a proposed      Department
    of Human Resources.        (See p. 43.)
                                                                       .




                                CHAPTER1

                       INTRODUCTION AND SCOPE

       The General Accounting Office,    in the past few years,
issued two reports    relating  to the enforcement   of Federal
sanitation   standards at poultry    and meat plants by the Con-
sumer and Marketing Service (C&MS), Department of Agricul-
ture.

        In September 1969 we reported    to the Congress on the
need for C&MS to strengthen      its enforcement of sanitation
standards and moisture requirements        at federally     inspected
poultry    plants (B-163450, Sept. 10, 1969).        In that review
we identified     40 plants that c&MS supervisory       inspectors
had reported for repeated violations        of minimum standards
over periods ranging from 6 months to over 5 years.

      In June 1970 we reported        to the Congress that C&MS
needed to strengthen      its enforcement of sanitation           standards
at meat plants (B-163450, June 24, 1970).              During that re-
view we visited    40 federally     inspected meat plants and
eight nonfederally     inspected plants receiving          Federal grad-
ing service.    The plants we visited        generally     were ones
which C&MS records indicated       had sanitation       problems.      Of
the 48 plants visited,       44 were slaughtering       animals or proc-
essing meat food products under unsanitary             conditions     for
sale to consumers.      We observed instances of product con-
tamination   at 35 of the plants.

     Copies of digests       of the two reports      are included     as
appendixes II and III.

        This report covers our review of the adequacy of C&MS'
enforcement of sanitation    standards at 68 poultry    plants re-
ceiving Federal inspection.      We plan to make a follow-up
review of the enforcement of sanitation     standards at meat
plants.

      Of the 68 federally  inspected poultry    plants covered
in this review,   17 were selected from the 40 plants in-
cluded in our prior review and 51 were selected at random
from a listing  of poultry  plants receiving    Federal inspec-
tion in five of the leading poultry    slaughtering    and

                                     4
   .


processing   States.    Thus we followed up on the adequacy of
actions taken at plants included in our prior review and
also visited   a number of randomly selected plants to form a
broad basis for evaluating      the adequacy of C&MSs enforce-
ment of sanitation     standards at Federally  inspected poultry
plants throughout    the United States.

        We visited   the plants during the period October 1970
to March 1971. We were accompanied by C&MS supervisory                  in-
spectors who reviewed the plants'         compliance with C&MS sani-
tation    standards.    In addition   to visiting    the plants,      we
reviewed records and interviewed        officials    at C&MS head-
quarters     in Washington,    D.C., at five of C&MS" regional          of-
fices,    and at selected C&MS circuit       offices   in those re-
gions.     We reviewed also C&MS' revised procedures for iden-
tifying    and preventing    shipments of poultry      containing     ex-
cessive moisture --a matter discussed in our earlier              report.

FEDERALLY INSPECTED PLANTS

       The Poultry Products Inspection         Act, as amended by the
Wholesome Poultry Products Act (21 U.S.C. 4511, provides
for Federal inspection      of poultry     and poultry   products to
prevent the movement in interstate          or foreign    commerce of
poultry    products which are unwholesome, adulterated,1            or
otherwise unfit     for human consumption.         The act provides
also that each plant that slaughters           or processes poultry
for sale in interstate      or foreign     commerce be operated in
accordance with such sanitary        practices     as are required     by
regulations     promulgated by the Secretary        of Agriculture.


Iwith   respect to sanitation,      the act defines a product as
 adulterated    if (1) the product has been prepared,       packed,
 or held under unsanitary      conditions    whereby it may have
 become contaminated     with filth     or may have been rendered
 injurious    to health or (2) the product consists,       in whole
 or in part, of any filthy,       putrid,   or decomposed substance
 or is for any reason unsound, unhealthful,         unwholesome, or
 otherwise unfit     for human food.
      The Secretary has delegated to the Administrator        of
C&MS authority   under the act, including     the authority   to
suspend inspection    at any plant failing    to maintain   sani-
tary conditions.    If suspended, a plant cannot slaughter        or
process poultry.    Federal inspection     may be resumed when
the plant complies with Federal standards.

        C&MS inspectors     assigned to individual     plants have been
delegated authority       to suspend inspection      temporarily     from
an entire    plant or from individual      operations     within   a
plant where unsanitary        conditions  which cause product con-
tamination     are found.     Where the inspectors     observe unsani-
tary conditions     which do not immediately       threaten     the whole-
someness of the product,         they are to identify     them for cor-
rection    by management.

        If plant facilities  or methods of operation    are not
brought into compliance within      a reasonable period,   the
eligibility     of the plant to receive Federal inspection     ser-
vices can be terminated.

        As required by the act, C&MS has published regulations
setting    forth standards for sanitation         in the Federal Reg-
ister    (7 CFR 81).    The regulations     provide that inspection
personnel may reject       for use any unclean equipment., utensil,
room, or compartment.         C&MS has also published a handbook
to assist     its inspectors    in carrying    out their responsibili-
ties.     As of December 31, 1970, 1,180 poultry         plants were
under Federal inspection.

        The Wholesome Poultry     Products Act, approved August 18,
1968, expanded the Department's           responsibilities        by autho-
rizing    the Secretary   to cooperate with the States in devel-
oping and administering       effective      State poultry      inspection
laws and programs.      The act also provided for expanding the
Federal program to include the inspection                of poultry   and
poultry     products moving in intrastate         commerce if a State
does not have an inspection         program at least equal to the
Federal program within      2 years after enactment of the act.
The 2-year limit     was later    extended to 3 years by adminis-
trative     action.  The poultry      inspection    programs of 33
States had progressed to "equal to" status through Octo-
ber 31, 1971.


                                    6
        Meat plants that ship meat and meat food products in
interstate    or foreign    commerce must comply with require-
ments of the Federal Meat Inspection        Act, as amended by the
Wholesome Meat Act of 1967 (21 U.S.C. 601).         These req-uire-
ments are similar      to those for poultry   and poultry products
plants.     As of the end of 1970, about 2,800 meat plants
were under Federal inspection.




                                 7
PROGRAMADMINISTRATION

       The Federal poultry        and meat inspection      programs are
under the overall        administration      of C&MSheadquarters         in
Washington,      D.C. The programs are carried           out by eight
regional    offices,     each headed by a regional         director.      The
territory     of each regional       office    is divided into circuits.
Circuit    officers    in charge are responsible         for supervising
the inspectors       assigned to provide day-to-day           inspection
at plants in their        circuits.       As of December 31, 1970,
about 8,700 C&E inspection             employees were located through-
out the United States; about 7,300 of them were assigned to
meat and poultry       plants.

     Major activities       for which poultry      plant   inspectors      are
responsible   include:

     --Inspection     for sanitary condition        of facilities        and
        equipment used in the production           and handling     of
        poultry   products.

     --inspection     for   wholesomeness and adulteration   of
        poultry   before    and during slaughter  and during proc-
         essing.

     --Supervisionofdispositionofadulterated               poultry prod-
        ucts so that they are not used for            human food purposes.

PROGRAMCOSTS

      The Federal Government pays the cost of the Federal
poultry    inspection     program, except for the costs of over-
time and holiday inspection          services which are charged to
the plants receiving         such services.   The Government also
makes matching grants to those States that have developed
intrastate     inspection     systems that measure up to the Fed-
eral system and to those States that are working toward
that goal.
       C&MS received appropriations      of about $34 million    for
fiscal   year 1971 and about $44 million         for fiscal year 1972
to carry out its poultry      inspection    activities.




                                      8
OTHER ACTIVITIES OF THE CONSUMER
AND MARKETING SERVICE

   In addition    to meat and poultry      inspection,     C&MS:

   --Inspects    egg products pursuant to the Egg Products
      Inspection   Act of 1970 (21 U.S.C. 1031).

   --Provides     inspection , grading and classing,     and stan-
      dardization     services   for other products,  such as cot-
      ton, grain, fruits       and vegetables,  naval stores,
      dairy products,      and tobacco.

   --Carries    out marketing    activities   under the Agriculture
      Marketing Act of 1946 (7 U.S.C. 1621) to aid in pro-
     moting the orderly      and efficient   marketing  and effec-
      tive distribution     of fasm products.

   --Administers      regulatory     laws aimed at protecting      farm-
      ers and others from financial           loss from deceptive,
      careless,     and fraudulent     marketing   practices  and from
      unfair    transportation     rates and services on farm sup-
      plies and products.

   --Purchases  surplus agricultural         commodities for     dis-
      tribution to schools,  families,        and institutions      and
      for emergency relief  use.
                                 CHAPTER
                                     .-- 2

            ENFORCEMENTOF FEDERAL SANITATION STANDARDS

               AT POULTRY PLANTS CONTINUES TO BE WEAK

      C&MS has taken some actions       to strengthen     the enforce-
ment of sanitation     standards since our earlier        reviews.
These actions,    however, have not been successful          in achiev-
ing adequate enforcement      of sanitation    standards.      Our most
recent review at 68 poultry      plants revealed varying degrees
of conditions    that were unacceptable      under C&MS sanitation
standards.     The unacceptable   conditions:

         --Continued     to exist at most of the 17 plants included
            in our prior review.     In many cases the conditions
            were similar    to those previously noted.

         --Existed   at most of the 51 randomly selected plants.
            At most of the plants,   the conditions appeared to be
            of a long-standing  nature and were similar   to condi-
            tions noted at the 17 plants.

       In many cases the unsanitary       conditions    caused visible
product contamination.        In other cases, contamination       was
not visible      but the conditions   were such that bacteriological
contamination      might have resulted.     The importance of good
sanitation     was emphasized by an official       of the Food and
Drug Administration      (FDA) who, in an article      on food sanita-
tion,l    stated:

         "The complete cleanliness        of equipment is of ex-
         treme importance     in the   prevention   of bacterio-
         logical  contamination.       Unless cleaned at fre-
         quent intervals,     trays,   pans, belts,   and other
         surfaces with which the       food comes in contact


LRobert     L. Shelton,   Jr.,  The C'nanaing Concept    of Food Sanita-
 tion,     (FDA Papers,   October 1967.)




                                       10
       ”
.




             accumulate enough organic matter to support the
             growth of micro-organisms  which may then be
             transferred  to the food product.**tt
               *           *          *           *          *


           "While there is much discussion        of eventual mi-
           crobiological    standards for foods, there can
           never be a satisfactory     substitute    for control-
           at-source.    This may be readily      accomplished by
           implementing   a sanitation   and quality     control
           program as a basic element in food production."

           Because our review included a number of plants selected
    at random, we believe    that weaknesses in the enforcement of
    sanitation   standards by C&MS may be widespread.      Indications
    are that the weaknesses have persisted      over a long period,
    and we believe that they will continue to persist        until   C&MS
    inspection   employees at all levels strictly    enforce sanita-
    tion standards.

          The following   sections of this chapter discuss (1) cer-
    tain actions taken by C&MS to enforce sanitation        standards
    at poultry   plants since our prior review, (2) the conditions
    in poultry   plants visited    during this review, (3) our con-
    clusions and recommendations,       and (4) the Department's    com-
    ments and our evaluation      of them.




                                      11
                                                                      .   .


ACTIONS TAKEN TO ENFORCESANITATION
STANDARDSAT POULTRY PLANTS SINCE OUR
PRIOR REVIEW

     Our prior reports   to the Congress on C&MS' enforcement
of sanitation  standards in federally   inspected poultry and
meat plants included recommendations to the Administrator     of
C&MS dealing with

      --the establishment    of effective   criteria   for the sus-
         pension and termination    of inspection    services at
         plants in violation    of minimum standards and

     --the need for reemphasis         to employees at all levels
         of their responsibilities        for the enforcement of reg-
        ulations     to ensure that    products are wholesome and
         unadulterated.

      In commenting on a draft of the September 1969 report
on poultry  plants,  the then-Administrator        of C&MS told us
that C&MS had activated     a rigorous    national   effort  to ensure
adequate sanitation    in federally    inspected poultry     plants.
He stated that

     --inspection     would be suspended at plants     which were
        unwilling   to provide acceptable  sanitary     conditions,

     --instructions    to field personnel had been amended to
         provide a better understanding   of sanitation require-
        ments, and

     --regional    directors    had been asked to make in-depth
        reviews of the 40 plants covered in our review and
        to take appropriate       actions, including the suspension
        of inspection     services where warranted.

     Subsequently C&MS provided us with the following sum-
mary of actions taken with respect to the 40 plants covered
in our prior review:




                                      12
                                                     Number of
              Action   taken                          Dlants

     Federal inspection   withdrawn
       either by C&MS or at the request
       of plant management                              11
     Federal inspection   temporarily
       suspended while action was taken
       to bring plant sanitation      in line
       with C6rMSstandards                                8
     Corrective  actions taken or
       scheduled which did not require
       cessation  of operations                         21

            Total                                       -40
     In commenting on a draft of our June 1970 report deal-
ing with meat plants, the then-Administrator told us that

     --the emphasis and objectives      of the major inspection
         improvement program, which was already under way,
        were being intensified    and were completely   in line
        with and responsive    to the recommendations   in the re-
         port;

     --a  letter  had been directed   to all meat and poultry
       inspection   program personnel clearly       outlining in-
       spection objectives    and sanitation     procedures and as-
       suring each employee full     support for his efforts      in
       enforcing   sanitation  standards;    and

     --revised     procedures,   forms, and instructions,    includ-
        ing criteria     for withholding    or suspending inspec-
        tion,   had been issued to assist      inspectors in carry-
        ing out C&MS' policies       at plants where unsanitary
        conditions     were found.

      He stated that, although the record demonstrated         some
progress,    still     further action was needed. He indicated
that further       actions would be determined by a study then be-
ing made on improvements needed in C&MS' administration.

      In August 1970 two consultants hired by the Department
completed a study of C&MS' consumer protection   programs.

                                 13
Their report contained a number of recommendations to the
Assistant   Secretary of Agriculture    for Marketing and Con-
sumer Services for reorganizing      the programs.

       In October 1970 a new Administrator     was appointed,  and
in November 1970 the Secretary announced that, largely        on
the basis of the consultants'     report,  C@J.S' meat and poul-
try inspection     programs had been reorganized   to provide
more direct    lines of communication and to improve consumer
protection.

      Among the consultants'        recommendations     that   were
adopted were ones to:

      --Establish     a separate division      for sanitation     and
         plant facilities      and a sanitation     officer   position
         in the Field Operations      office     in Washington and in
         each regional    office.    These changes were intended
         to provide continuous and uniform attention            to sani-
         tation problems.

      --Combine all of C&MS' Washington inspection           and review
         staffs    into a single unit reporting      to the Adminis-
         trator    to give him better  intelligence     regarding   the
         effectiveness    of the inspection     programs.

In August 1971 C&MS officials       told us that other recomrnenda-
tions of the consultants     directed    at improving the unifor-
mity of inspections,    strengthening     supervision,  and increas-
ing training  were to be implemented.

        One of the consultants'        reconnnendations--to     separate
C&MS' marketing       functions     and its consumer protection       func-
tions by establishing          a separate agency for consumer protec-
tion programs --has not been adopted by the Department.                  The
consultants      stated that this recommendation was made because
they believed that there was an inherent difference                 in the
nature of C&MS' marketing and consumer protection                programs
which created an internal           administrative   conflict.      The con-
sultants    stated further       that consumer protection      was so
large an area and had such complex problems that               it needed
a full-time     administrator.




                                     14
        In July and August 1970, shortly           after we told C&MS
that we were initiating      a follow-up       review of the enforce-
ment of sanitation     standards in poultry           plants,   a C&MS re-
view team visited     43 poultry    plants,      including    the 40 plants
we covered in our prior review.          Of the 43 plants,         34 were
eligible    for Federal inspection,      nine had Federal inspection
withdrawn either voluntarily        or involuntarily,         and 28 were
in operation    at the time of the team's visit.              The team re-
ported that operations      had to be suspended so that sanita-
tion deficiencies     could be corrected         at 13 of the 28 plants
and that it observed contaminated           products at nine plants.




                                      15
CONDITIONS IN POULTRY PLANTS VISITED
DURING THIS REVIEW

       C&MS records showed that,       in calendar year 1970, the
68 plants we visited      accounted for about 19 percent of the
13 billion     pounds of poultry    slaughtered   and about 13 per-
cent of the 3 billion      pounds of poultry     processed in fed-
erally    inspected poultry    plants in the United States.

       C&MS supervisory    inspectors,   who accompanied us on our
plant visits,     reviewed the plants'     compliance with C&MS
sanitation    standards.     In their review the inspectors    used
a form which provided that an item being reviewed be classi-
fied as (1) acceptable,        (2) in minor variation,   or (3) un-
acceptable.

       The inspectors  reported    some deficiencies     in sanitary
conditions    in each of the 68 plants,        The types and the ex-
tent of the deficiencies,      classified     either  as minor varia-
tions or unacceptable     conditions,     varied from plant to plant.
Many of the deficiencies      appeared to have existed over a
long period.

       Because judgment is involved,   uniform and consistent
application   of sanitation  standards is difficult.      During
plant visits   we observed, on occasion,     that similar  condi-
tions were rated as violations     of C&MS standards by one in-
spector but not by another inspector.

      At 4.0 plants,   including 13 of the plants covered in
our prior review, the inspectors     who accompanied us suspended
normal operations    for periods ranging from 10 minutes to
several days because the plants did not meet certain     C&MS
standards.     In 15 plants the suspensions were for 4 hours
or longer.

      Contaminated products were observed in 35 of the plants.
Contaminants observed included fecal matter,           ingesta (con-
tents of digestive    tract),   bile,   and feathers.      Potential
contamination    from dirty   equipment; generally       poor sanita-
tion;  inadequate pest control;       and dirty  floors,    walls,   and
overhead structures     was also evidenced in most plants.



                                   16
      The following    table summarizes, for various sanitation
categories   under slaughter   and processing  operations,   the
percentages    of times that the C&MS inspectors     who accom-
panied us rated the items on the C&MS review form as unac-
ceptable or in minor variation     at the 68 plants.     Under
each category one or more items may have been reviewed.
Not all items were reviewed at each plant.

                                                   Percent    of times rated    less than acceptable
                                                                                       Randomly se-
                                                      Follow-up plants                 lected plants
                                                 Minor                          Minor
                                                 vari-       Unac-              vari-       Unac-
              Item reviewed                      ations     ceptable   -Total   ations
                                                                                ___        ceptable  Total

Slaughter operations:
     Preoperative        sanitation
        (floors,     walls, overhead
          structures,       and equip-
         ment)                                     58          27         85      50         22         72
     Operative sanitation
        (slaughter,        scalding,
       picking,       eviscerating,       and
        carcass cooler facilities
        and equipment)                             21          15         36      33         11        44
     General sanitation           (dry stor-
        age, outside premises, em-
        ployee welfare facilities,
        and pest control)                          37          17         54      35         14         49
     Maintenance and/or facilities
        and equipment (carcass cool-
        ers and slaughter,           scalding,
        picking,      chilling,      and evis-
        cerating      areas)                       33           5         38      38         10         48
     Giblet preparation           (handling,
        cleaning,      and trimming)               38          15          53     30          6         36
     Condensation prevention             in
        chilling      area                         46           8          54     33          6         39
     Ice source and handling                       38          15          53     53         19         72
Processing operations:
     Facilities       and maintenance
        (floors,     walls, ceilings,
        doors, equipment, and stor-
        age areas)"                                44           0          44     34         10         44
     Sanitation       of equipment                 56          33          89     33         44         77
     General sanitation           (general
        housekeeping,         pest control,
        and outside premises)                       11          0          11     41         20         61


        The above table shows that, generally,      unacceptable
 conditions   and minor variations     were as often found in the
 17 plants we had visited       during our prior   review as in the
 51 randomly selected plants.




                                                         17
      The four following    case studies discuss the conditions
encountered during this review at two of the plants covered
in our prior review and at two of the plants selected at
random.    These cases illustrate    the types of sanitation
problems that we and the C&M!3 supervisory     inspectors    ob-
served during this review.




                               18
Flant   A

         This poultry-slaughtering     plant was one of those           in-
cluded in our prior review because it had been identified
by C&MS inspectors      for repeated violations  of sanitation
standards.

        Subsequent to our prior review, C&MS supervisory  in-
spectors made several reviews of this plant during the pe-
riod July 1969 through July 1970 and reported numerous san-
itation  deficiencies.  Following are some of the items re-
ported by a supervisory  inspector  after his plant visit on
August 5, 1969,

        --Antemortem  area:         manure and mold on the wall and
           adequate drainage        not provided on outside premises.

        --Carcass  coolers:      walls and ceilings  were moldy and
           broken and there     was heav condensation,

        --Floors,    walls,  overhead:  some mold on walls in
           picking   room, rust on overhead supports,  and house-
           keeping   unacceptable,,

        --Equipment:   pickers and scalder in poor state of
           repair and construction of some equipment not ac-
           ceptable.

        --Employee welfare facilities:           crowded and insuffi-
           cient toilet facilities     for     women.

        --Slaughter,    scalding,      and picking   rooms:   sanitation
           not acceptable,
        --   Dry storage:  box storage not acceptable.          Should
             be stacked to prevent vermin and allow for         cleaning,,

        --Shipping   and receiving area: not properly  drained,
           deep pits in loading docks, and fly problems.

        --Outside  premises and maintenance and service areas:
           old junk and paper, improperly  drained, and no at-
           tempt to keep clean.



                                      19
            After another review 3 weeks later,    the supervisory
inspector        in a memorandum to the C&MS Regional Director
stated:

            "Finally, _ after ante-mortem inspection,    I in-
            structed    inspectors   to let the company start
            since degree of noncompliance was so extensive
            that a short delay for some corrections      was un-
            realistic."      (underscoring  supplied)

          A supervisory        review    made in July    1970 showed the
following    conditions.

            --Floors,     walls,     and ceilings:  rusty overstructure,
               leaks    in roof,     and cracks in blood tunnel trough.

            --Carcass     coolers:      condensation    from drip   pans.

         --Slaughter,   scalding,      and picking areas:   some equip-
            ment not clean; leaky roof in picking area: some
            rust and flaking    paint on overhead structures;     and
            cracks in walls,    floor,    and  door facing.

         --EMscerating      department maintenance:    holes in
            wall, grease on cable of one eviscerating       line and
            one cut-up line,     and peeling paint  on one  line above
            giblet   table.

         --Ice source         and handling:      ice bin and conveyor       need
             renovation,

        In commenting on the July 1970 review, the C&MS Re-
gional Director    stated in a letter   to C&MS headquarters   that
these deficiencies     had either  been corrected or were sched-
uled for correction.      He concluded with the following    com-
ment.

        "Response on the part of plant management appears
        to have been good; however, we will push for
        prompt correction    of the few remaining unsatis-
        factory  items and keep a close watch on the plant
        in an effort    to assure that corrections are main-
        tained."



                                           20
         On January 13, 1971, we visited   the plant accompanied
by a supervisory     inspector. This inspector  had assumed the
responsibility    for the plant about 3 months prior to our
visit.

         He inspected the live-bird      holding area; the receiv-
ing dock; and the killing,     scalding,     and picking areas and
informed plant management that the general housekeeping of
these areas was so poor that additional         clean-up would be
necessary.     In his report the supervisory       inspector included
the following    comments on these and other areas he inspected.

        Antemortem     area

        --Sanitation    in this area was nonexistent.      Floors
           were filthy    and corners were piled with debris.
           Motors moving the conveyors were encased in black
           tarry dirt and grease mixed with feathers.         This
           condition   had existed   for a long time.    Rollers
           were so congested with fecal material,      feathers,
           and dirt that they were difficult      to move.

        --Ceiling    areas gave the appearance of a cheap horror
           movie scene with numerous cobwebs and heavy dust
           accumulations.    The area surrounding the docks was
           muddy and strewn with debris.

        Preoperative     sanitation

        --Scalder    was unacceptable    due to dirty   water covered
           with bloody foam.     This evidenced that equipment
           had not been properly      washed. Rust was thick and
           caked at entrance of scalder.       There was a heavy
           blood accumulation    from previous slaughter.       The
           scalder needed complete renovation        and a thorough
           cleaning.

        --Pickers   had been improperly        cleaned and the top
           covering showed much dirt,        feathers,    and old fat in
           one corner.     When this area was again inspected,the
           blood was still     present in the corner area of the
           scalder,   feathers    were still    in pickers,   and the
           above-mentioned     covering had not been touched,



                                      21
--The exhaust fan in the window had not been cleaned
   for months.    Walls were splattered  and corners
   were cluttered  with dirt and feathers.

General   sanitation

--The dry-storage      area was unacceptable.      Dirt was
   underneath boxes, cartons were piled and jammed in
   corners,    and there was filthy     debris between car-
   tons and walls at the top of stairs.          There was no
   protective    covering,    such as screens or air cur-
   tains,    to prevent flies    from entering   building    dur-
   ing the time when boxes were received.          A plastic
   covering was used in one area to cover the operation
   area.     The opening was torn and the covering was in
   poor condition,     allowing    dust and dirt from this
   area to blow in on the product.          This area should
   be enclosed to prevent dust contamination           of the
   product.

--Restrooms   were in such a condition   as to be unfit
   for use.   Commodes were plugged and wet papers were
   on the seats of commodes, floors,    and all adjacent
   areas.   No soap was in the dispensers.

--The outer premises were unacceptable.     Debris was
   strewn over the area, corners next to building   were
   filled  with papers and filth.   There was an accu-
   mulation of dead birds all over the outer premises.
   Some had been crushed by trucks and had been there
   quite some time.   Others were in hidden areas and
   were decomposing.

--The live-bird  holding area was devoid of any ap-
   pearance of housekeeping.    Weeds were high enough
   to make an excellent  harborage for rats.   Coops in
   the storage area had dead and decomposing birds be-
   tween them.

--Pest control   was not in accordance with regional
   instructions,   No effort had been made to avoid
   harborages for pests.



                            22
.


    --Hygienic      practices    were poor.   Towels and soap were
       not kept     in supply    at appointed areas.

    -Carcass     coolers

    --Coolers      evidenced green algae on walls.      Holes in
       plaster     and wall had not been satisfactorily      re-
       paired.

    --Condensation    unacceptable              and its   prevention    was
       not evidenced.

    Offal   building

    --The offal   building   was unacceptable,               the east wall
       cracked and deteriorating.      The roof              apparently had
       been wrecked by truck.

    --Drainage   and care of building  were improper.     Drain-
       age created a nuisance of foul,   greenish,   brackish
       material  covering a swampy area.

    Eviscerating       department

    --Rusty     shackles contaminated     birds by rusty drips.
       Chillers    needed recaulking     and seams needed thor-
       ough cleaning.     The pipe overhead allowed condensa-
       tion to drip in chiller.         A rubber floor mat was
       lying in the giblet     chiller.      Welding was not
       smooth and caught product fat.          Drip pan (past fi-
       nal wash before prechiller)        needed to be replaced;
       it had pit marks and rust.

    --Vacuum hoses for lung removal needed to be replaced
       and the system needed to be cleaned to get rid of
       fetid   odor. Nozzles needed thorough cleaning to
       remove dirt buildup and bacterial   harborage. S-
       shaped hangers were rustye   Shackles needed to be
       replaced.

    --On the giblet        trough,        all   welding   should    be smooth.

    --Shields      and covers on evisceration              line    needed at-
       tention     to be acceptable.


                                     23
                                                                              ,


        --Covered drain area at end of eviscerationline                was
           rusted out and must be replaced.,

        --All     lights    over line must have tubes      enclosed in
           plastic      or other covering to prevent       broken tubes'
           falling      onto exposed product.

        --Flaking      rust on angle irons (braces) which were
           over evisceration     trough must be replaced with
           rust-resistant     material.   Drip pans needed to be
           replaced.

        Ready-to-cook      product

        --Giblet   preparation  was unacceptable          due to contam-
           ination  and improper preparation.            Giblets had to
           be recleaned.

        --Much better      washing     and preparation    of the product
           was needed.

        --Inspection      of product by plant       personnel   was not
            adequate    to detect deficiencies.

        Ice source      and handling

        --Ice     source and handling were totally           unacceptable.
            Top part of ice-making machine was rusty.               An ac-
            cumulation     of rust and silt was on beams and equip-
            ment.     Sanitation     and housekeeping were very poor
            in the entire      area housing the machine.         Water from
            this area dripped directly         on ice.     Conveyor and
            auger troughs were not covered.            Welds and patches
            of these augers were dirty         and difficult     to clean
            properly.      The   chute  to dispensing     area  was  rusty.

        --Condensation   needed more attention.            Necessary   pre-
           ventive action must be taken.

        One item determined by the supervisory       inspector   to
be unacceptable    but not included in his report was the
plant's  freezer.     The inspector   told plant management that
the freezer was totally      unacceptable,    He said that the
product could not be stored in the freezer until         the freezer
was thoroughly    defrosted   and cleaned.

                                       24
         In summary,      the supervisory      inspector     stated:

         "In general,  it must be said that            this is the
         poorest example of an eviscerating              plant in the
         *Jr* Circuit.

         The overall   picture of the plant and premises is
         certainly  not one of a food processing establish-
         ment."

          During his review the supervisory            inspector      stated
that plant operations         should be suspended until          sanitation
at the plant was at an acceptable           level.       Because there were
about 60,000 live birds at the plant awaiting                slaughter,
however,    the  inspector     contacted  C&MS     regional    officials      for
advice on how to handle the situation.               Regional officials
told the inspector       that,   if possible,     he should allow the
slaughter     of those birds on hand, after the critical                 areas
were cleaned.

         The supervisory     inspector    allowed slaughtering       of the
birds on hand to begin after         a 5-l/4-hour    suspension,     but
operations   were suspended thereafter         until  certain    items
were corrected.      He told plant management that the decision
to allow the slaughter       of the birds on hand was predicated           on
the assumption that the birds would probably die before they
could be slaughtered      if there was a plant shutdown.            He
stated that this decision        in no way condoned the condition
of the plant or the general attitude           of plant management
toward sanitation.

           Plant management objected strongly          to the corrections
required      for the ice facilities,       offal house, and freezer
since these required major repairs.              Plant officials   said,
in relation       to the freezer,     that no other freezer storage
facilities       were then available      in the area and asked that
they be allowed to use the freezer until              January 25, 1971,
at which time freezer storage space would be available                 at
another plant.

        On January 15, a regional    official,     on the advice of
a C&MS Washington official,   instructed       the plant inspector
to allow the plant to resume operations.          Operations were
resumed on January 16. On January 18 a regional            official

                                        25
granted the plant     permission    to use the freezer     until   Jan-
uary 25.

          Regional officials    told us that the decision to allow
operations     to resume was based on the plant inspector's     as-
sessment of the plant's       corrective  action. The supervisory
inspector    visited   the plant on January 22 and found that
corrective     action had not been completed on four items--the
outside premises,      the ice machine, the sizing bins, and the
ice auger covers.

          The supervisory      inspector   told us that he was dis-
turbed by the decision to allow operations            to resume without
his approval and without his knowledge that the specific
items listed     in his report had been corrected.,           He told us
that, because operations          had been allowed to resume prior to
correction     of the discrepancies      to his satisfaction,       con-
flicts    would continue to exist between plant management and
the C&MS inspection       staff.     He said that the only thing ac-
complished by the suspension was that the plant was cleaned
enough to meet minimum standards.             He said that the C&MS in-
spection staff would have to continue struggling,               as before,
to force the plant to operate under acceptable             conditions.

         In March 1971 the plant%s inspector       in charge reported
to his supervis'or    that one of his inspectors      had been
threatened    by the plant manager.     The plant manager was sub-
sequently    replaced by the company.     The Office of the In-
spector General, Department of Agriculture,          investigated     the
incident    and found that the inspector    had been verbally        as-
saulted and harassed.      As a result   of the investigations,
C&MS sent a warning letter      to plant management citing        the
seriousness    of the incident.




                                   26
Plant    B

      This plant slaughters and eviscerates  ducks.  It was
one of the 40 plants covered in our prior review because it
had been reported by C&MS as not being in compliance with
C&MS sanitation  standards on several occasions during the
period September 1963 to June 1968.

        During 1969 and 1970, a C&MS regional            official  and a
supervisory       inspector      visited  this plant on numerous occa-
sions.      Their     reports    showed  different  opinions of the san-
itation     conditions.         Between June 1969 and May 1970, the
regional     official       reviewed the plant on four occasions.         Al-
though noting some problems, his reports generally                indicated
continued     improvement in plant sanitation.            During about
the same period, June 1969 to July 1970, however, the super-
visory    inspector       reviewed the plant five times and continued
to find numerous deficiencies.

      On June 20 and October        13, 1969, the supervisory        in-
spector's  reports described        many unacceptable    conditions.
The October report  included        the following   statement:

        "In view of the fact that sanitation       at this plant
        has been lagging,    always at a low level,      I rec-
        ommend that inspection     be withheld  or withdrawn
        until   the plant management indicates     to the Con-
        sumer Protection    Program that they will      operate
        their plant in accordance with the Federal Poultry
        Regulations    and meet satisfactory   sanitation     re-
        quirements."

       On October 17, 1969, the regional    official   visited    the
plant.    He reported that some improvement had been made since
his last visit    but that many corrections    were still    to be
made especially     in the area of equipment and facility      re-
pairs.    He reported also that sanitation      in some departments
continued   to be a problem.

     On January 19, 1970, the regional  official  again visited
the plant and reported that a great deal of improvement had
been made in the plant since his visit  in October 1969.




                                      27
       On May 28, July       1, and July 14, 1970, the supervisory
inspector   visited  the      plant and found many unsanitary   con-
ditions.    As a result       of the July 14 review, the Regional
Director   wrote to the       plant owners on July 21:

     "On July 14, 1970, Dr. *** visited              your plant
     and found the following  conditions             existing   be-
     fore the beginning of operations:

           "1.   Offal     room was unclean.

           "2.   Restrooms were filthy--toilets   and sinks
                 were unclean.   Cobwebs were present and
                 the floors  needed to be swept.

           "3.   Employees' aprons were badly           worn and
                 encrusted with dried blood.
           "4.   All     floors   in the plant     needed sweeping.

           "5.   Overhead structures    were either         dusty,
                 rusty 9 or grease   encrusted.

           "6.   Eviscerating  shackles were dragging
                 across a window ledge on return to the
                 picking room.

           "7.   The scalder and picker were both encrusted
                 with feathers from previous operations.

           "8.   The wax handling          area was unacceptable.

           "9.   Eviscerating       shackles were contaminated
                 with blood,      tissue,   wax, and rust.

     "Memorandums from here dated October 13, 1969 and
     May 28, June 20, July 1, 1970, included similar
     conditions which were unacceptable.

     "If these unsanitary     conditions   continue to be
     found in your establishment       on supervisory re-
     view, we will  interpret    this to mean that you do
     not intend to cooperate with the inspection        in
     your plant and we will have no alternative       other


                                      28
    ,

        than to suspend inspection      at Plant ***.    If you
        have any questions    about sanitation   requirements
        in your plant,   please contact Dr. *** who will
        advise you of our minimum standards,        We hope
        that suspension of inspection      will not be neces-
        sary, however, this is your notice that we in-
        tend to do this the next time a supervisory         re-
        view indicates   you are not complying with our
        very basic sanitation    requirements."

       On July 23, 1970, a c&MS review group surveyed the
plant and concluded that, although general housekeeping
remained a problem, the plant was producing a wholesome un-
adulterated     product.     They noted evidence of substantial
improvement in both the equipment and the facilities             of the
plant.     They  attributed     the  cause for the continued   problem
of improper cleanup to a lack of communication between plant
management and the C&MS plant inspector.           A supervisory    in-
spector who accompanied the review group noted some defi-
ciencies    including     the following.

        --No rodents or mice noted in plant.    One particle of
           what appeared to be a rat feces noted on packing
           table.  No evidence of traps or other means to control
           vermin.

        --Toilet     area could be cleaner.

        --Floor   and walls need a better cleaning.             Feathers   in
           buckets from previous operations.

        --General     floor   sweeping needed in all      departments,

        --Some overhead pipes with           dust.   Shackles   dragging
           over window ledge.

        --Scalder:       feathers   and filth.

        --All   shackles:     rusty chains.    Live-hang shackles
           have been painted;       starting to flake off,        Eviscerat-
           ing room shackles worn and starting           to rust.     Picker:
           feathers   caught under fingers.        Entire wax handling
           operations    unsatisfactory.     Settling      tank unclean
           before start    of operations.     Wax picker unclean;         old

                                        29
        wax encrusted between fingers.     Pinning               tables:
        grease accumulation  on undersurface.

      --Packing     area:      table   unclean.

      --Lung    gun and cryovac        nozzles    had a putrid     oder.

      --New York     Dress tanks       unclean;    grease    and debris    in
        bottom.

      --Floor     drain     in cooler too small to accommodate drain-
         age.     Large     puddle of water in center of floor.

      Subsequent     to the review group's visit,             the supervisory
inspector  wrote     the C&MS plant inspector:

      "It  is apparent that your conception   of the Sani-
      tary Requirements within   and outside premises is
      not in line with C&MS *** standards.     It appears
      as if you are not reading or do not understand     the
      regulations,   memos, and etc., that are issued to
      you **.

     "It  appears that your control   of the plant sanita-
     tion is very lax and definitely    unacceptable.     You
     must improve your control    of sanitation  at *-k-k [the
     plant]."

     We were unable to find            any subsequent       supervisory    re-
ports for this plant.

       On February 1, 1971, the Q5M.Splant inspector          in charge
accompanied us on our review of the plant because the super-
visory     inspector   and his assistant    were both unable to visit
the plant on this date.          The day we visited   the plant was the
first    day the plant inspector      in charge had been assigned
to the plant.        The previously   assigned plant inspector    had
been replaced because he had not adequately          enforced C&MS
sanitation      standards,

      Numeroussanitationdeficiencies     were observed during
the review,   and plant operations   were delayed 4-l/2 hours
while certain    of the deficiences  were corrected.   The fol-
lowing deficiencies     are some of those noted by the inspector.


                                        30
     --Floors,  walls,  and ceilings:     cobwebs on ceiling;
        flaking paint on ceilings     and wall; floor cleaning
        needs improvement.

     --Ventilation:     ventilation    fan inadequate;                   too much
        of an accumulation     of steam.

     --Equipment:     rusty product holding tanks (rejected);
        de-waxer machine very filthy     (rejected   for use until
        cleaned);  de-picking   machine tanks, knives,     tables,
        etc., unsatisfactorily    cleaned (corrected    before use).

     Eviscerating     department

     --Ceilings:    scaling       paint;        hanging     insulation     on over-
        head pipes.

     --Lavatories:       need more cleaning.

     --Equipment:      rusty - - product holding
             -                              _ _ tanks (rejected);
        pails,   tanks, tables,       etc., had specks of paint and
        some buildup of dirt and organic matter (thoroughly
        cleaned before use); some shackles were rusty;                 ac-
        cumulation    of grease and graphite         on rails;     lung-
        removing equipment was filthy          (corrected      before use).

     Other

     --Freezer:      unsatisfactorily            cleaned.

     --Personnel     dress:      dirty        aprons and clothes.

     --Storage  room:         area cluttered;         some boxes for shipping
        product stored        under working        tables;  plastic wrappers
        not adequately        covered.

      During the visit   we observed noncompliance with certain
C&MS standards relating     to processing    operations  which the
inspector   did not include in his report but which he ac-
knowledged in our discussions      with him.    These included
(1) poultry    not being washed prior to being placed in hold-
ing tanks for evisceration,      (2) water in the holding tanks

                                         31
exceeding the allowable  temperature, and (3) poultry      not
being chilled to 40 degrees or lower within  4 hours      after
slaughter.

       The C&MS plant inspector required  that   most of the
deficiencies  he reported be corrected   prior   to the start
of the day's operations.




                               32
Plant    C

      This randomly selected plant processes a variety             of
food products,   including     poultry    and meat products.      Corre-
spondence and reports      for January 1968 through November
1970 indicated   only minor sanitation         problems at this plant.
A report on a visit     to the plant by a supervisory         inspector
in November 1970 indicated       that sanitation      may have begun
to deteriorate.     Deficiencies      noted during the November
visit  included rust and flaking        paint.

         On December 10, 1970, we were accompained by the super-
visory     inspector     on a review of this plant,    The review con-
centrated       on the part of the plant in which meat and poultry
was processed and stored, because C&MShad primary respon-
sibility      for sanitation      in these areas,   C&MS sanitation
responsibility        in the remainder of the plant was limited     to
controlling       conditions    that could affect  the meat and poul-
try areas.

       On the basis of his review, the supervisory     inspector
rated 17 of 24 items as not meeting C&MS standards.         Conse-
quently plant management suspended operations      at this plant
for the entire     day.  Some of the conditions reported    by the
inspector    and the results  of his inspection were:

        --Walls,     in general,   were acceptable.    In cooking areas
          walls were tiled       and kept in good condition.     The
           junctures    of the walls and floors     had some cracks
           that required     sealing.    There were some holes in
           painted block walls that needed sealing,          Also some
          holes for pipes had not been sealed properly.

          These items   are to be corrected     by January   15, 1971.

        --Ceilings     were generally     in good repair.  There were
           instances    of flaking    paint from a disconnected  air-
           conditioner    unit and rust on some overhead pipes and
           a few metal supports.

          Paint was removed from the air conditioner     on Decem-
          ber 10. A continual    maintenance program was to be
          carried out to control   flaking  paint and/or rust.



                                   33
--Sanitation       of equipment was poor.      Stainless-steel
   vats had a thin film of grease in corners,               on some
   side panels, and on outside surfaces,             Steam kettle
   cookers had film on inner surfaces,           a thick accumu-
   lation    ,under lids,    and buildup on the bottom and on
   the steam line to it.         Valve outlets    and stainless-
   steel piping that carry broth were not satisfactorily
   clean.      A broth funnel,    plastic  outlet    lines,    and
   stainless-steel       elbows showed buildup.        A stainless-
   steel can conveyor was dark from a film of grease.

  A stainless-steel     shovel and a fork showed some meat
  tissue and grease films and were speckled with paint
  from spray painting      the walls.   A rusty table had
  been painted with aluminum paint which had not ad-
  hered properly.      A rusty scale had been refinished
  with aluminum paint,       and the scale platform  was still
  flaking    where its surface had been cracked from rust
  deterioration.      A stainless-steel    table and meat
  grinder had not been cleaned thoroughly,

  Also there was an excess of grease around grease fit-
  tings of closing machine.  An ingredient    scoop and
  mixer had not been cleaned properly.     A can sterili-
  zer tunnel had accumulated rust on its inner surface.
  A can opener and a table drawer were dirty.

  Rustytablesused     to handle salt pork were rejected
  and discarded.     The slicing   machine was rejected       until
  cleaned.    All the equipment (except that discarded)
  was cleaned and cooker lids were dismantled           and
  cleaned.    The painted scale, table,      and can opener
  were rejected   for use,     The table,   additional    rusty
  tables in the equipment washroom, and some pipe stands
  were removed from the operation        for galvanizing.       The
  can opener was discarded to be replaced with a new
  one,

--An employee rest room and break room had not been
   cleaned properly.   A ,urinal bowl, toilet   bowls, and
   white enamel trash receptacles    were soiled and dusty.
   The men's rest room had a broken glass, and the
   screen was down. The employees ' break room did not
   receive effective  attention   and had a &utter    of

                             34
        dispenser package over-wraps             and infrequently
        cleaned tables and floor.

        The urinals,     toilets,     basin,      and trash receptacle
        later were cleaned.          Repair     of window and lockers
        and screen replacement were             to be accomplished the
        following    day.     Effective,       continuous   if need be,
        attention    is to be given to          the break room immedi-
        ately,

     --In the raw meat use and storage area, the cooler
         badly needed cleaning.    In a holding freezer, some
         stacked packages had fallen   and some frozen chicken
         had fallen from broken packages onto the floor.

        Some ground beef not properly protected  in a plastic
        bag was condemned.  Chicken exposed to contamination
        was condemned, and stacks were put in order.   The
        cooler was cleaned,

The supervisory    inspector    concluded that preoperational
sanitation   inspections     had not been adequately  effective
for a period of time.

        Subsequent to the review,    the supervisory   inspector
sent a letter     to the plant manager which established       com-
pletion    dates for those deficiencies    not corrected    at the
time of his review.




                                     35
PlantD

        Smoked turkeys and chickens are processed on a seasonal
basis in this randomly selected plant.        Records in the C&M!S
circuit    and plant offices  showed a continual    history  of
sanitation    problems since Federal inspection     was granted to
the plant in September 1968.

       In April 1969 the plant inspector     provided plant man-
agement with a list     of 30 deficiencies   related     to unsanitary
conditions    that had to be corrected.     In October 1969 the
plant inspector    discussed persistent    sanitation      problems
with plant management.      The plant inspector      stated in a
memorandum that he had been assured by plant management that
steps would be taken to preclude recurrent         problems.

       In November 1969 a supervisory      inspector   visited    this
plant.    The supervisory    inspector  rated sanitation       as ac-
ceptable and commented that the plant was in better             condi-
tion than he had ever found it on previous visits.              On the
same day,however,     the plant inspector     made the following
comment in a memorandum to the file.

      "Dr. **   [supervisory  inspector] visited    in the
      plant and discussed with management their prob-
      lems on sanitation.    Management was told if no
      improvement by end of the week, plant would be
      declared a problem plant and reported      to the
      Regional office."

      Subsequent daily sanitation        reports prepared by C&MS
plant inspectors  continued to      show recurring    deficiencies.
In January and February 1970,       the supervisory    inspector
again reviewed the plant and,       on both occasions,      rated
many facilities  and sanitation       items below C&MS standards.

       On April 13, 1970, the C&MS plant inspector     wrote a
detailed   memorandum to plant management about sanitation
problems which he said had to be solved.       The problems and/
or his suggested corrective    actions included:

     --Carcass   cooler   and smokehouse:     rusty conveyor;
        rusty overhead    pipes, hangers, and rails;       storage
        racks not kept    clean; no protector     on fluorescent

                                  36
        lights;     rusty equipment throughout;        frayed insula-
        tion;    dirty   cooling units;    floor not maintained       in
        sanitary      manner; paint flaking      in frank pack room;
        maintenance of sanitary         conditions    not practiced.

     --Processing     room and area:      dirty  cooling units;
        frayed pipe insulation;       rusty doors, equipment, and
        containers;     dirty walls;    corners and holes in walls
        need repair;     all unpainted wood should be treated;
        dirty   overhead structures;      unclean lavatory;     spice
        room should be kept clean and rust free.

     --Dry storage area (rat problems):        repair all possible
        entries for vermin (floors,     walls,  ceilings,   under
        locked doors);  clean regularly     and thoroughly;   get
        rid of all unusable items; do not stack anything on
        top of boxes.

In the memorandum the plant        inspector    stated:

     "These problems *** are for the most part chronic,
     and are to not only be solved, but (sanitary
     conditions)    are to be maintained         on a regular
     basis.     These responsibilities        are the plant man-
     agement's,    and therefore,      inspection     service will
     not *** accept responsibility          for seeing that
     they are done. However, we definitely              will  see
     that no operation     **    is carried      on if these
     problems are not solved ***.V'

       In September 1970 operations       were suspended for about
l-l/Z   hours by the plant inspector        because of unsanitary
conditions.      The plant inspector,     in a memorandum to the
supervisory    inspector,  stated:

     'I*** While performing      the first     of my twice a
     week preoperative      Sanitation     surveillance      I found
     the management of this establishment             to be in
     violation    of the Manual Section ***.            They are not
     performing    preoperative     sanitation      and are allow-
     ing operations     to begin when unsanitary          conditions
     exist.     They, by their own admission,          have not
     performed preoperative        Sanitation     inspection     in
     over two weeks.      Items too numerous to mention
     were found to be in an unsanitary            condition    ***.
                                    37
                                                                               .




     "Please advise me of any further      action you deem
     necessary to insure that the management of this
     establishment    accepts the responsibility   of pre-
     operative   sanitation   inspection."

The supervisory inspector           made the following      notation      on
the memorandum.

     "Visited    with Management on this & corrections
     were made - Management will conduct sanitation
     supervision."

      On October 27, 1970, we were accompanied by the C&M!S
supervisory   inspector  on a review of this plant.    The super-
visory inspector    rated 35 percent of the items he reviewed
as not meeting G&E standards.        The deficiencies he found
and his suggested corrective     actions follow.

     Facilities      and maintenance

     --Floor      in sales   cooler    needs patching      in two areas.

     --Small holes in walls           of processing      room and sales
        cooler need patching.

     --Patches      on cooler      doors need caulking.

     --Unused rusty rails          were over products        in cooler;
        area was restricted         until corrected.

     --Freezer   needs better housekeeping;              freezer    was tagged
        and condition  was corrected.

     Sanitation

     --Some areas of the floors     around walls             in processing
        areas need better cleaning.

     --Walls in the processing              room near the grinder      need
       better  cleaning.

     --Condensation      control      needs attention      in the stuffer
        room.


                                       38
     --Unused stuffer  was rusty      and should be tagged   for
        cleaning or removal.

     --General   housekeeping   in all   areas needs improving.

       During the review the supervisory   inspector  rejected
a few pieces of equipment and areas for use until       cleaned.
The supervisory   inspector   also told the plant foreman that
the plant inspector    in charge had been instructed    to reject
the freezer in the future if it ever reached the same con-
dition   in which he had found it.




                                 39
CONCLUSIONS

        The extent and types of conditions         reported    by C&MS
supervisory      inspectors    and observed by us at the 68 poultry
plants included in this review demonstrated             that C&MS still
was not adequately        enforcing  its sanitation      standards at
poultry    plants.     In view of the large number of randomly
selected plants included in this review, we believe that
conditions     observed during our plant visits         may be wide-
spread.

      Many of the conditions       observed appeared to have ex-
isted for long periods of time--a         situation  which we be-
lieve is indicative     of a lack of strong, day-to-day       enforce-
ment by C&MS plant inspectors        and of a lack of effective
supervisory   review.     In such circumstances     consumers are
not provided with adequate assurance that they are receiv-
ing the unadulterated      products   intended by the Poultry Prod-
ucts Inspection    Act.

        This is the third report that we have issued on C&MS'
enforcement of sanitation           standards in domestic meat and
poultry     plants.      It is the second report dealing with poul-
try plants.         In the earlier     reports   we recommended that
C&MS issue improved criteria             for enforcing    sanitation stan-
dards and reemphasize to its employees at all levels their
responsibilities         for enforcing      such standards.

       Following     our earlier     reports  C&MS issued revised pro-
cedures, sanitation         standards,    and forms and stressed the
need for strict        enforcement of standards to employees and
industry    through letters       and meetings.     It was apparent
from this review, however, that C&MS' actions had not sub-
stantially     improved the enforcement of sanitation          standards
at poultry     plants.

       We believe that adequate criteria      and policies   now ex-
ist for enforcing    sanitation    standards.   In our opinion,
however, C&MS inspection       employees at every level need to
intensify   their enforcement of sanitation       standards.    As we
stated in our June 1970 report on meat inspection:
      "Clear and firm criteria --setting         forth the ac-
      tions to be taken when unsanitary          conditions are

                                    40
    .


        found--and   improved reporting   policies   can pro-
        vide a basis for improving C&MS enforcement of
        sanitation   standards at meat plants.     In the
        final analysis,    we believe that the effective-
        ness with which such standards are enforced will
        be dependent on the resolve of C&MS personnel at
        each and every level-- from the plant inspectors
        to the Washington officials.11

        Given adequate criteria      and policies,     the essential
keys to strict       enforcement of sanitation      standards will
continue to be the actions         taken by C&MS' 8,700 inspection
employees and the support that they receive from their
superiors      at all management levels.       Ways must be found to
demonstrate      convincingly    to C&MS inspection      employees that
consumer protection        is the main objective     of enforcing    san-
itation     standards at federally      inspected plants and that
strict    enforcement of such standards is essential.

      We believe that one way in which improved enforcement
might be accomplished would be to establish     a separate
agency in the Department for consumer protection     programs.
This action was recommended in August 1970 by Department
consultants,   but the recommendation was rejected   by the De-
partment.    We believe that the Department should reevaluate
the recommendation.

      As the consultants   stated in their report, their rec-
ommendation that a separate agency be established    was pred-
icated on their belief   that

        --there    is an inherent     difference     between the nature
           of C&MS' marketing activities          and that of its con-
            sumer protection   activities       which creates an internal
           administrative    conflict      and

        --consumer    protection is so large and has such complex
           problems   that it needs a full-time administrator.
      Establishing    a separate agency       for consumer protection
seems even more appropriate      in view      of the increased re-
sponsibilities     for consumer protection        activities  that the
Congress placed on the Department in            the Wholesome Poultry
Products Act of 1968, the Wholesome           Meat Act of 1967, and
other legislation.

                                     41
       We recognize that,      should the Department adopt the
consultants'      recommendation,    its full   implementation     would
take some time.       We recognize also that, if a separate
agency for consumer protection          were established    within   the
Department,     many of the employees now responsible          for en-
forcing    sanitation   standards would continue to be respon-
sible.

       Therefore we believe that the Department should con-
sider other and more immediate avenues to improve and em-
phasize enforcement of sanitation        standards.    Such avenues
might include an intensification       of efforts   already under
way to strengthen      supervision  and to improve the training
of inspection      employees as well as increased use of appro-
priate   disciplinary     action when C&MS inspection    employees
at any level do not meet their responsibilities.

RECOMMENDATIONSTO THE
SECRETARYOF AGRICULTURE

     We recommend that the Secretary     of Agriculture          reevalu-
ate the consultants'    recommendation that a separate           agency
for consumer protection     programs be established.

        We recommend also that the Secretary      explore other and
more immediate avenues to improve and emphasize the enforce-
ment of sanitation     standards,   including  the intensification
of efforts     already under way to strengthen     supervision     and
to improve training     as well as increased use of disciplinary
action when inspection      employees do not meet their responsi-
bilities.




                                   42
MATTER FOR CONSIDERATION BY THE CONGRESS

      Because of the importance to the cons'umer of proper en-
forcement of sanitary    standards,   we believe that the Con-
gress may wish to consider the matters discussed in this re-
port and in our earlier     reports  in connection with a number
of measures before the Congress which bear either         on the is-
sue of consumer protection      or on the food inspection    pro-
grams of C&MS.

     These measures    include:

     --Bills    to establish    a separate Department of Consumer
        Affairs   in the executive     branch (H.R, 254 and 1015,
        92d Cong. >. These bills,       which have been referred
        to the House Committee on Government Operations,           call
        for the transfer     of certain    C&MS functions,    with the
        apparent exception       of meat and poultry    inspection   and
        grading,   to the new department.,

     --The President's      Reorganization    Plan (reprinted      as
        H. Dot. 92-75) which calls for the transfer            of C&MS
        meat and poultry     inspection    and grading activities
        to a proposed Department of Human Resources,              The
        programs of FDA also would be transferred           to the new
        department,    which would offer an opportunity         to log-
        ically   coordinate    the consumer protection      programs
        of C&MS and FDA. A bill         to create the Department of
        Human Resources has been introduced         in the Congress
        (H.R. 6961, 92d Gong,) and has been referred            to the
        House Committee on Government Operations          for consid-
        eration.

     --A bill     (H.R. 11298, 92d Gong.) which would establish
        the Federal Food Safety Administration           to ensure the
        safety of food, its nutritional         quality,   and confor-
        mity to accepted standards and to control           its pack-
        aging and labeling.         Among other fPlnctions the bill
        would transfer     to the new agency the functions        of the
        Secretary     of Agriculture    under the Federal Meat In-
        spection Act, the Poultry Products Inspection           Act,
        and the Egg Products Inspection         Act.



                                  43
       Although we are recommending that the Secretary              of
Agriculture-reevaluate      the earlier   consultants'      recommenda-
tion that a separate agency for consumer protection               be es-
tablished     in the Department of Agriculture,        we believe it
desirable     that the Congress consider the possibility            of
transferring      the meat and poultry  inspection      functions      of
C&MS to a new or existing      department or agency where they
could be combined with other consumer protection              f,unctions
of the Government.

AGENCYCOMMENTSAND OUR EVALUATION

       In his November 2, 1971, letter    (see app. I>, the Ad-
ministrator     of C&MS commented for the Department on our rec-
ommendations and on the matter for consideration       by the Con-
gress.      The Administrator's comments and our evaluation   of
them are presented below.

Avenues to improve and emphasize
enforcement of sanitation standards

      The Administrator    said that he believed that our rec-
ommendation that the Secretary         explore immediate avenues to
improve and emphasize the enforcement of sanitation            stan-
dards, including    the intensification        of efforts already un-
der wayto strengthen    supervision,       was:

      "**   the key recommendation of your report,  and
      by far the most significant   action that can be
      taken toward the improvement of meat and poultry
      inspection  in this country."

       The Administrator      said also that,     immediately   after
receiving    our September 1969 report,        the Department began
to move in a deliberate        way to solve the basic structural
and functional     deficiencies    that we had pointed out.         He
said further    that minor changes had been made promptly but
that major changes had been deferred until             they could be
studied carefully.        He stated that a full       solution to the
deficiencies    demanded drastic      reorganization.

      The Administrator  said that the supervisory    structure
in effect  during our previous review and essentially       still
in effect  during this review was totally   inadequate.      He

                                    44
.


said also that the supervisory          structure   was grossly    lacking
at all levels in that

      --no centralization   of authority      and responsibility
         existed in the individual    plants,

      --circuit-level     supervisory   visits  to plants were too
         infrequent    to ensure either    adequacy or uniformity
         of inspection,

      --supervision  at the regional level was inadequate be-
         cause the geographic span of control was too great,
         and

      --supervision     at the national   level failed   because at
         least three    Washington divisions    were communicating
         instructions    to the field   and because too often the
         instructions    had not been coordinated     and were not
         consistent.

       The Administrator      said further that C&MS was attempting
to respond in a specific        way to each of these supervisory
deficiencies.       He stated that there were other elements in
the organization      and other aspects of the reorganization,
such as consolidation       of supportive  functions and increased
supervisory    training,    that had been or would be ,undertaken,

       In addition,     the Administrator   said that, as soon as
the new field     structure    was in place, both he and his Deputy
Administrator     for the Meat and Poultry      Inspection   Program
planned to make visits       to the regions to personally      meet with
all supervisors      through the circuit    level.    He said also
that they intended to make clear to the supervisors            that
they were fully      and firmly   committed to the objectives       of
the Wholesome Meat Act and of the Wholesome Poultry Products
Act and that the supervisors         would be fully   supported when-
ever tougher regulatory        measures became essential     to the
realization     of those objectives,

      GAO evaluation

     We believe that the actions that have been or will be
taken to strengthen  the supervisory   structure and to correct
other organizational   weaknesses should help to improve the

                                   45
inspection    program.    Unless these actions result     in more
adequate enforcement of sanitation         standards by the individ-
ual  inspectors,     however, they will not correct    the basic
weakness in the inspection       program--inadequate   enforcement
of sanitation     standards at the plants.

Reevaluation   of consultants'
recommendation

       Concerning our recommendation that the Secretary     re-
evaluate the consultants'     recommendation that a separate
agency be established     for consumer protection  programs, the
Administrator    said that a major factor   in the Department's
decision not to create a new agency was that the consultants:

       "**Jc also noted that meat and poultry         inspection
       could function     within     C&MS without a change of
       organizational     structure,    and that 'there would
       be one advantage of initially          keeping Consumer
       Protection     in C&M!5in that new logistic       support
       would not have to be developed -Mc*s."

        The Administrator       said also that meat and poultry       in-
spection was not in 1970, and was not now, a viable admin-
istrative    unit.     He said further     that,    if a new agency had
been created late in 1970 at the same time the reorganiza-
tion was begun, it would have been necessary to devote a
great deal of time, effort,           and manpower toward the develop-
ment of administrative          support activities,     such as personnel,
budgeting,      accounting,     equipment,   supplies,   data processing,
and statistical       services,     which are now provided by C&IS.

       He stated that this inevitably       would have slowed down
program reorganization      and that, since program changes were
and are of a much higher priority,        C&MS had decided to con-
centrate    on them and to defer a possible administrative         re-
organization     to a later  date,   The Administrator      stated also
that,    in his j,udgment, it would be a grave error to consider
creation    of a new agency until    the field    reorganization   was
complete and until      the new supervisory    structure    had had a
reasonable time test.

       The Administrator     stated,    however, that he fully    agreed
that   the Secretary     of Agriculture    should, in the future,

                                   46
.




    consider the merits of establishing    a separate agency for
    meat and poultry   inspection but that timing was critical   in
    a step of such great importance.

          He said that the field       reorganization      was to be com-
    pleted in December 1971 and that, allowing             ample time for
    smoothing out rough spots in the structure             and for imple-
    menting additional     supervisory     training    programs, any fur-
    ther reorganization     probably should not be considered          for
    several months.     Further he said that to do otherwise would
    merely complicate    the actions that were being taken and
    would, in his judgment, be detrimental            rather than benefi-
    cial.




                                      47
                                                                          ,



                              CHAPTER 3'

                  REGULATION FOR INSPECTION OF

         POULTRY FOR EXCESSIVE MOISTURE STRENGTHENED

      In January 1971 C&&S strengthened       its regulation   to
prevent the shipment of poultry        that had absorbed excessive
moisture   during processing.     If adequately   implemented,    the
new regulation    should be effective.

       The need for strengthening     and enforcing      regulations
to prevent the sale of poultry       containing    excessive water
was discussed in our prior report on poultry           inspection.
(See app. II for report digest.)          In that report we pointed
out that the previous regulations,         which required     daily
tests to determine moisture      content,    did not provide C&MS
inspection    employees at the plants with the authority            to
require    the plants to hold and drain poultry       when moisture
content was excessive.

        c&MS' new regulation     provides criteria       to be used by
the inspectors     for determining       whether the amount of mois-
ture absorbed or retained        in poultry     is within maximum
limits.     When the amount of moisture         absorbed is determined
to be above the specified        limits,    the inspector    is to re-
quire that all poultry       processed be held and drained to ac-
ceptable levels.

       Because this regulation      became effective     after most of
our fieldwork     was completed, we did not determine how well
it was being applied.       If properly     implemented,    it should
provide an incentive     for poultry     plants to keep moisture
absorption    within allowable    limits    because the plants'     op-
erations   will be disrupted    to drain poultry      that has exces-
sive moisture.




                                  48
                                                                       APPENDIXI

             UNITED STATES DEPARTMENT OF AGRICULTURE
                       CONSUMER    AND   MARKETING    SERVICE



                                                                 WASHINGTON.            D.C.   20250

Mr. Max Hirschhorn                                               November 2, 1971
Associate Director
Civil Division
United States General Accounting         Office
Washington, D. C. 20548

Dear Mr. Hirschhorn:

I appreciate the opportunity   to comment on your draft           audit        report
relative  to our poultry inspection program.

The Department began to move, in a deliberate   way, immediately after
receiving your report of September 1969. Minor changes were made
promptly (some of which are discussed in your present audit).      Major
changes were deferred until they could be carefully    studied.   A re-
organization affecting   thousands of employees should not be undertaken
in haste and without a careful evaluation of alternatives.      Yet a full
solution demanded drastic reorganization.

In mid-1970, the Secretary of Agriculture   commissioned a team of con-
sultants   to make a comprehensive study of the organization     of meat and
poultry inspection.    This study was completed in October 1970. The
report (generally referred to as the May-Barnard Report) was excellent,
and has formed the basis for most of our organizational      actions since
that time.    A few of its recommendations were rejected,    some were altered,
but most were accepted as written.

The May-Barnard Report called for a major reorganization               of the meat and
poultry inspection program. Perhaps its principal               conclusion was that
the program had a totally        inadequate supervisory structure.           This is es-
sentially     the finding of your 1969 audit , and is undisputably             accurate.
The supervisory structure was grossly lacking at all levels.                   In the
plant, there was no centralization           of authority    and responsibility.        At
the circuit     level, supervisors spent too much time behind their desks, in-
stead of circulating       from plant to plant.       This was not entirely       their
fault,    for the paper work load which kept them behind desks was imposed
upon them from above; they did not create it.              But this meant that super-
visory visits      to plants were too infrequent        to insure either adequacy or
uniformity     of inspection.      Supervision at the regional level was inade-
quate because geographic span of control was too great.                Eight regional
offices were attempting to establish and implement policy through hundreds
of circuit     and subcircuit    supervisors.     It is no wonder that inspection
policy lost something in the transmittal;            there was little     direct trans-
mittal.      And finally,    supervision at the national level failed because of


                                          49
   APPENDIX I

Mr.    Max Hirschhorn

nebulous    lines   of authority.       At least   three   Washington     divisions     were
communicating     instructions       to the field,    and too often     the instructions
had not been coordinated          and were not consistent.         This understandably
led to confusion       and uncertainty     in the field     force.

The structure            just  described            was essentially      still           in being       during       your
recent   audit.            We should    not         therefore     expect   your          1970-early        1971      find-
ings     to   be   significantly            different        from     those     of   September         1969.

You have recommended          that      "the Secretary         explore...immediate              avenues     to
improve    and to emphasize           the importance         of enforcing         sanitation        standards.
Such avenues    might include             an intensification           of efforts        already      underway
to strengthen      supervision..."             I believe       this    to be the key recommenda-
tion of your report,          and by far the most significant                     action      that can be
taken toward     the improvement            of meat and poultry            inspection         in this country.
It is the basic       intent       of the reorganization,              as recommended           by Drs. May and
Barnard.

we are attempting                to respond         in a specific             way to each of the supervisory
deficiencies            outlined        earlier.           (At the Washington               level,       the reorganiza-
tion has now been completed;                        in the field             we expect        full     implementation
by December 1971.)                   For example,           at the plant           level,       responsibility             will
be pinpointed            through        the use of "Inspectors                   in Charge."             One man will           be
in charge         at each of the 4,000 federally                          inspected         plants       in the U. S.
Just above plant               level,       subcircuit          supervisors          will     be eliminated             in order
to simplify           the supervisory             structure,           and circuit          supervisors            will    operate
without       offices         so that       they may concentrate                 in the field            on plant         super-
vision.         With the help of the staff                       of the National              Archives,          our reports
system has been redesigned,                       at an expected              saving      of more than one million
dollars       per year.           Even more important,                  will     be the benefits               that will        ac-
crue in permitting                field       inspectors         to concentrate             on inspection             rather
than on paper work.                   The geographic             span of control              between        the circuit
supervisors          and the regional               offices        has been shortened                by the establish-
ment of 34 area offices.                        These offices           will     not only improve                supervision
of the Federal             circuits,          but will        also provide           continual         surveillance            over
State     inspection           programs.          Finally,         regional-national               coordination            has been
enhanced       by the establishment                   of a Field         Operations           Division         in Washington,
D. C. Thus a single                   division,         rather       than three,          has authority             and responsi-
bility      to issue directives                  or instructions              to the regional              offices.

In Washington,           all supportive        functions        have been consolidated                into    two
divisions.          One, a Standards          and Services         Division,       prepares      proposed
regulations,         develops      standards,       monitors       labels,       approves     facility        draw-
ings,      etc.     The other,       a Laboratory        Division,        provides      laboratory         support
of all kinds for the Field                Operations        Division.          We departed       from the May-
Barnard       Report     in granting      divisional‘status             to the laboratories,               but this
has turned        out to be one of the most important                      changes      of all.         Residue
surveillance         has become of tremendous               importance         in assuring        the whole-
someness of food products               , and this       has placed        a heavy demand on all
government        laboratories.

                                                              50
                                                                   APPENDIX I


Mr. Max Hirschhorn

There are other    elements in the organization    and other aspects to the
reorganization,    but the major points have been delineated.     We have
high hopes for    this reorganization.   We believe that we are well on the
way to improved    performance throughout the system.

The gist of your case reports and other portions of the audit is that
poultry inspectors have often been too lenient.        This is supported by
the fact that deficiencies    found in 1969 were still     uncorrected a year
or more later, that plant managers have agreed to corrections         but failed
to carry them out, and that inspectors and their supervisors have per-
mitted operations to continue in spite of this action or inaction.           In
other words, inspectors ought to be tougher, and they ought to have
stronger backing from above. Dr. McEnroe and I fully concur.           Without
defending any laxity    on the part of our inspectors or their supervisors,
it must, nevertheless,    be recognized that stopping a plant, either tem-
porarily  or permanently, is a serious step for anyone to take.          The in-
spectors must be accurate in evaluating a hazard to the consumer and
fair in application    of our standards.   Their obligations     extend to the
consumer, to the government, and to the plant; and their total task is
not easy. That is why supervision is so important,         why the reorganiza-
 tion is so important and so relevant , and why followup to the reorganiza-
tion is even more important.

As soon as the new field structure        is in place, both Dr. McEnroe and I
plan to make visits    to the regions in order to personally meet with all
supervisors   (through the circuit     level) in the program.         This is un-
precedented, but we believe it will pay dividends in morale and under-
standing throughout the organization.            Among other things, we intend to
make clear to the field supervisors          that we are fully and firmly       com-
mitted to the objectives      of the Wholesome Meat Act and the Wholesome
Poultry Products Act and that they will be fully supported whenever
tougher regulatory measures are essential           to the realization    of those
objectives.    Though these plans were developed several months ago, they
respond to your conclusion that "in the final analysis,              the effectiveness
with which sanitation     standards are enforced depends on the resolve of
C&MS personnel at every level --from         the plant inspectors to the Washington
officials."    In addition,    they respond to your statement that ways must be
found "to demonstrate convincingly         to C&MS inspection personnel that con-
sumer protection    is the main responsibility        inherent in enforcing sanita-
tion standards at federally      inspected plants and that strict          enforcement
of such standards is wanted."

A great  deal also needs to be done in the way of supervisory       training    among
food inspectors who are in supervisory positions , as well as among super-
visory veterinarians.        This is to be done in a systematic manner through
Staff Development Plans that will be prepared on a calendar year basis.
This requirement will extend throughout all divisions        of C&MS, but is of
special importance in meat and poultry inspection        because of its critical
inadequacies.     Instructions    for preparation of the Calendar Year 1972
Staff Development Plan will be issued shortly.

                                         51
 APPENDIX I

Mr.   Max Hirschhorn

 YOUI- audit   suggests      that one way to improve              meat and poultry         inspection
might be through        the establishment              of a separate      agency within        USDA. In
support     of this   suggestion,           you cite      the May-Barnard      conclusions       that     (1)
there    is an inherent         difference        in the nature      of C&MS' marketing          and con-
sumer protection        activities          which creates       an internal     administrative          con-
flict,     and (2) consumer           protection       is so large     and has such complex prob-
lems that it needs a full-time                   administrator.        You then question         the De-
partment's     1970 decision            to maintain       meat and poultry      inspection       within
the Consumer and Marketing                 Service.

Drs. May and Barnard              also noted       that meat and poultry              inspection          could
function        within     C&MS without       a change of organizational                  structure,          and
that     "there      would be one advantage            of initially          keeping      Consumer Protec-
tion     in C&MS in that new logistic                 support       would not have to be developed..."
This was a major factor                in the decision          not to create         a new agency.             Meat
and poultry          inspection      was not,     in 1970, and is not now a viable                        administra-
tive     unit.       All administrative          support      activities        such as personnel              services.
budgeting,         accounting,       equipment,       supplies,        data processing,           statistical
services,         etc.,    are provided       for it by the parent              agency       (C&MS).       If a new
agency had been created                in late    1970 at the same time the reorganization
was begun,         it would have been necessary                 to devote       a great       deal of time,
effort,        and manpower       toward    the development            of these capabilities.                  This
would inevitably             have slowed the program              reorganization.             Since program
changes were and are of a much higher                       priority,        we decided        to concentrate
on them, and defer              a decision      on administrative            reorganization          to a later
date.

In my judgment,        it would be a grave error                    to consider         creation      of a new
agency until       our field      reorganization             is complete         and the new supervisory
structure     has had a reasonable               time test.           However,      I fully       agree that the
Secretary     of Agriculture          should       in the future           consider       the merits       of es-
tablishing      a separate      agency for meat and poultry                      inspection.          As noted
in the May-Barnard          Report,       this     program       is certainly         large     enough to merit
agency status.         But timing         is critical          in a step of such great                importance.
The field     reorganization          is to be completed               in December 1971.              Allowing
ample time for smoothing              out rough spots in the structure,                         implementation
of additional       supervisory         training       programs,         etc.,     any further        reorganiza-
tion probably       should    not be considered                for several         months.        To do otherwise
would merely       complicate       the actions           that are now being              taken and would,        in
my judgment,       be detrimental           rather      than beneficial.

Parenthetically,            it should      be added that     the presumed       internal     administra-
tive   conflict         between    marketing     and regulatory       programs,      or marketing       and
consumer       protection       programs,     is a myth.       Each of these programs            operates
under a different             Deputy Administrator,        so they are already           separated      with-
in C&MS.         Any    supposed    conflict     must,  therefore,       occur    in  my  decisions       as
Administrator           of the Agency.        But this has never been a problem                during     my
first    11 months in USDA, and I do not expect                    it ever to be a problem.



                                                     52
    4

                                                              APPENDIXI

Mr. Max Hirschhorn

The principal   issue is not so much where the meat and poultry inspection
function is organizationally    located but rather how it is operated.
While the audit pints     up sanitation problems , we believe inspection has
improved considerably since 1969. The audit conclusions and recommenda-
tions do not seem to recognize either the recent progress made or the
significant   potential for improvement which the new supervisory structure
promises.

We do, however, fully share your concern for consumer protection.     One
cannot be nonchalant about a program of this magnitude, and of such
great importance to the American public.   We intend to have an efficient,
effective program, and will be pleased to have your suggestions at any
time.

Sincerely,



2*/pw
 Consumer and Marketing   Service




                                    53
 APPENDIX II

COMPTROLLER
          GENERAL'S                                ENFORCEMENT OF SANITARY, FACILITY, AND
REPORT
     TO THECONGRESS                                MOISTURE REQUIREMENTS AT FEDERALLY IN-
                                                   SPECTED POULTRY PLANTS
                                                   Consumer and Marketing    Service
                                                   Department of Agriculture     B-163450


DIGEST
-_----

WHYTHEREVIEWWASMADE
    The Poultry    Products     Inspection             Act of 1957, as amended,        provides    for
    the inspection     of poultry       and         poultry    products     which are processed      in
    plants  engaged    in interstate               or foreign     commerce to ensure      that  the
    poultry   and poultry     products             are wholesome,       free from adulteration,
    and processed     under sanitary               conditions.

    Because of the widespread                 production       and consumption             of poultry        and
    poultry      products       and the fact that           about 86 percent             of all poultry          is
    processed        in about 900 plants            under Federal          inspection,          the General        Ac-
     counting      Office      (GAO) has examined          into     the Federal          inspection        program
    to ascertain          whether   the Department           of Agriculture's              Consumer      and Mar-
    keting      Service      (C&MS) was adequately             enforcing        the minimum standards               es-
    tablished        in accordance       with requirements              of the Poultry            Products      In-
    spection       Act.     GAO's review         was directed         primarily        to the adequacy           of
    actions      taken by C&MS at those federally                     inspected        plants      which had been
    reported       for repeated       violations         of minimum standards                for sanitation,
    facilities,         and moisture       absorption.


FINDINGSANDCONCLUSIONS
    GAO found that    there    was a need for C&MS to strengthen         its enforcement
    procedures   to ensure     that minimum standards    for sanitation,          facilities,
    and moisture    absorption     were met by federally    inspected      poultry        plants.

    GAO identified        40 plants       that were reported        by C&MS supervisory            person-
    nel for repeated        violations         of minimum standards       over periods         ranging
    from 6 months to over 5 years.                 Most of the violations           involved       sanita-
    tion     requirements    which were intended             to ensure  the wholesomeness             of the
    product.        The 40 plants        accounted     for about 6 percent        of the 11.2 bil-
    lion    pounds of poultry          slaughtered       under Federal    inspection        during      cal-
    endar year 1967.          (See pp. 7 to 19.)

    GAO believes      that the lack of timely          action    by C&MS to suspend or termi-
    nate inspection       services      at plants   which were in repeated       violation      of
    minimum standards        did not adequately        protect    the consuming    public    from
    poultry    or poultry      products    that   could have become adulterated           or other-
    wise unfit     for human consumption.           During     a period  of suspension,      plants


                                                                                        SEPT.lOJ.965
                                                        54
          .                                                                           APPENDIX         II


     cannot    process  poultry     or poultry   products     for   sale   in     interstate    or
     foreign     commerce.

     GAO believes      also   that the failure     of C&MS to suspend    or terminate      in-
     spection    services     at such plants    could imply   to the management       of other
     federally    inspected      plants that   violations   would be treated    with mini-
     mum consequence.

     GAO identified   also 44 federally      inspected plants which were permitted
     to ship poultry    in interstate     commerce for sale to the consuming public
     that,  on the basis   of daily tests,      contained water in excess of that
     permitted by regulations.        These plants    exceeded moisture requirements
     at least   20 percent  of the time during 4 to 11 months of calendar                       year
     1967.    The 44 plants accounted for over 13 percent of the poultry
     slaughtered under Federal inspection            during     calendar year 1967.
     (See pp. 22 to 26.)
     GAO believes  that the consuming public was not adequately protected
     against increased costs resulting  from excessive water in poultry be-
     cause C&MS inspection personnel were not authorized to retain poultry
     containing water found to be excessive on the basis of the results of
     daily moisture absorption tests.


FLEXO~NDATIONS      OR SUGGESTIONS

     The Administrator        of C&MSshould
        --strengthen     enforcement procedures by establishing                  effective criteria
           for the suspension and termination      of inspection                services at those
           plants  in'violation    of minimum standards.

        --determine whether the poultry plants identified    dwring GAO's review
           as having operated in viol ation of minimum standards over extended
           periods of time are currently   operating in compliance with minimum
           standards.

        --establish       a daily-testing  procedure that can be used as a basis for
           retaining      for additional  processing any product that is in excess of
           moisttie      absorption tolerances.

        --authorize  the C&MS inspector in charge at the plant                      to retain    poul-
           try for additional processing on the basis of daily                      tests.


AGENCY ACTIOIG     AND VNRESOLVED ISSUES

     C&MS informed GAO that a rigorous national effort    had recently been ac-
     tivated to ensure adequate sanitation   in inspected plants.     C&MS stated
     that inspection had been suspended at several plants, that numerous
     plants had been required to make iiranediate improvements, and that major
APPENDIX   II                                                                         I

    long-ier,m improvements were being called    for and rigid   deadlines   estab-
    lished therefor.

    C&MSstated also that suspension action was being and would be taken on
    plants unwilling      to provide acceptable sanitary conditions    and that in-
    structions    to field personnel were being amended to ensure proper under-
    standing of their authority       to take action to ensure proper plant sani-
    tation.     GAO agrees with the actions taken by C&MS and believes that the
    intensified    C&MSefforts     to ensure adequate sanitation  in federally  in-
    spected plants should be continued as a permanent part of the enforce-
    ment program.

    C&MS advised GAO that the regional directors having responsibility     for
    the plants identified    in GAO's review had been advised of the need for
    immediate in-depth reviews of such plants and for taking appropriate ac-
    tion, including    suspension of inspection, should the nature of current
    findings warrant such action.

    With respect to moisture control,    C&MSinformed GAO that there was in
    the final stages of design a statistical    control system of daily tests
    to be performed by C&MS inspectors assigned to the plants.     C&MS stated
    that full authority  for retaining   birds out of compliance on the basis
    of the results of daily tests would be placed in the hands of the
    plant inspector in charge and the retained birds would not be distrib-
    uted to consumers until excessive moisture had been removed. C&MS
    stated also that it planned to put this system into use, nationally,      in
    the near future.


i%W!l'ERS
        JQR CONSIDERATION
                       BP THECONGRESS
    Because poultry and poultry products are an important source of the Na-
    tion's supply of food and are consumed throughout the Nation, the Con-
    gress may wish to consider the matters discussed in this report in its
    continuing evaluation of consumer protection  programs.
                                                                      APPENDIX III

COMPTROLLER
          GENmAL8S                        WEAKENFORCEMENTOF FEDERALSANITATION
REPORT
     TO THECONGRESS                       STANDARDSAT MEAT PLANTS BY THE
                                          CONSUMER AND MARKETINGSERVICE
                                          Department of Agriculture B-163450


DIGEST
-se-__

WHYTHEi?EVIEWWASMADE

    The Congress has determined that it is essential  for the health and wel-
    fare of consumers to be protected by ensuring that meat and meat food
    products distributed  to them are wholesome and processed under sanitary
    conditions.

    Under the Federal Meat Inspection Act, the Consumerand Marketing Ser-
    vice, Department of Agriculture,      has the responsibility      for establish-
    ing and enforcing sanitation     standards in federally      inspected meat
    plants. Inspectors assigned to the plants are responsible for enforcing
    the sanitation   standards.   (See p. 6.)

    The Consumer and Marketing Service also is responsible for ensuring that
    sanitation  standards are maintained by nonfederally  inspected plants
    that receive Federal gradin    service--a marketing service provided to
    meat plants upon request.   9See p. 7.)
    As of December 31, 1969, there were about 3,200 federally   inspected
    plants and about 140 nonfederally  inspected plants which had been ap-
    proved by the Consumer and Marketing Service as eligible  to receive Fed-
    eral grading service.

    The General Accounting Office (GAO) in a report to the Congress
    (B-163450, September 10, 1969) pointed out the need for the Consumer and
    Marketing Service to strengthen its enforcement procedures to ensure
    that standards for sanitation,   facilities,       and equipment were met by
    federally  inspected poultry plants.        Also, the Office of the Inspector
    General, Department of Agriculture,       in 1965 and 1969 pointed out weak-
    nesses in the enforcement of sanitation         standards at federally in-
    spected meat plants.

    In view of previously indicated weaknesses in the enforcement of sani-
    tation standards, GAOwanted to ascertain the adequacy of the Consumer
    and Marketing Service's enforcement of sanitation   standards at meat
    plants provided Federal inspection  or grading service.

    GAO's review was directed primarily to certain of the plants         which Con-
    sumer and Marketing Service records indicated had sanitation         problems.




                                         57                 JUNE24,197G
APPENDIXIII                                                                   c

    Conditions found in the plants and reported in this review therefore may
    not be typical  of conditions in all plants receiving Federal inspection
    or grading service.


FMDINGS AND CONCLUSIONS

    The Consumer and Marketing Service needs to strengthen its enforcement
    procedures to ensure that standards for sanitation   are met by plants re-
    ceiving Federal inspection or grading service.

    Accompanied by Consumer and Marketing Service supervisory personnel, GAO
    visited   40 federally   inspected plants and eight nonfederally  inspected
    plants receiving     Federal grading service.  Evaluations  of the plants
    were made in accordance with Consumer and Marketing Service sanitation
    standards.     (See pp. 14 and 34.)

    In calendar year 1969, the 40 federally inspected plants accounted for
    about 7.7 percent of the cattle and swine slaughtered and about 4.9 per-
    cent of meat products processed in all federally   inspected plants.

    Consumer and Marketing Service inspection        personnel were not uniform in
    their enforcement of sanitation standards        and generally were lenient
    with respect to many unsanitary conditions        unless product contamination
    was obvious.

    At 36 of the 40 federally      inspected plants and at the eight nonfederally
    inspected plants, animals were being slaughtered or meat food products
    were being processed for sale to the consuming public under unsanitary
    conditions.    GAO observed instances of product contamination      at 30 of
    the federally    inspected plants and at five of the nonfederally      inspected
    plants.     Some of  the major  unsanitary  conditions observed during    GAO's
    plant visits   included:

      --Lack of adequate pest control       as evidenced by flies,    cockroaches,
         and rodents.

      --Improper slaughter operations resulting        in contamination    of car-
         casses with fecal material and hair.

      --Use of dirty   equipment and processing     of product    in unsanitary
         areas.
      --Contamination  of product by rust, condensation,         and other foreign
         material from deteriorated or poorly maintained         overhead structures.
         (See pp. 15 and 34.)

    Examples illustrating     sanitation  problems at federally   inspected and
    nonfederally    inspected plants visited    by GAO are located on pages 16
    to 30 and pages 34 to 40, respectively.



                                       58
                                                                                               APPENDIX        III




   --rejected       for    wise squicxent      and plant               areas or suspended        inspection
       jn f&ej-al‘Dy       iqs-)~ted      @art&   xhen         LT-I:     arsitary conditions       were found
       and

   --rewxended           the withcira~tiz.1       of Federal            grading     services    at nonfeder-
       a'! sy i nsper,-&ij   p-j i;r!t= that      ~ei-e fowd            operating      under   unsanitary
       conditions     o

If Federal      inspection         service    is suspended,       a plant        cannot     slaughter
animals     or process       meat for mwement           in interstate          commerce.        The with-
drawal     of grading       serifice     from a nunfederal      ly inspected           plant     precludes
the plant"s       usjng any official            mar i: OY other     identification            of the Fed-
eral    grading    service.          (See pp- 6 and 8.)

GAO was unable       to ascr<b?       to any one cause the failure                of inspectiori
personnel      to reqliire      plsnt   managements     to promptly         and effectively      cor-
rect    unsanitary      conditions.       GAO believes,         however,     that     a primary  cause
of the lack of uniformity             a?d leniency      in enforcement          of sanitation
standards      was a lack of clear          and firm    criteria      setting       forth   the ac-
tions    to be taken when unsanitary            conditions        were found.

GAO believes         that weaknesses        in the Consumer           ar?d Marketing      Service's
system for repor*< L,ng on plant              revields     also contributed         to the inadequate
enforcement        of sanitation       standards        at federally       inspected      plants.   Be-
cause reports          generally    did not shs$ what action,                if any3 was taken to
correct     reported       unsanj tary     conditions,        information       was not readily
available      to Consumer       and Marketing          Service     management       as to whether
appropriate        and timely     corrective         actions      were required       by inspection
personnel.         (See p. 41.)

Clear     and firm        criteria--setting              forth     the actions        to be taken when un-
sanitary       conditions          are found--       and improved         reporting         policies      can pro-
vide a basis          for improving            the enforcement          of sanitation            standards      at
meat plants.            In the final           analysis,       GAO believes         that      the effective-
ness with which such standards                       are enforced         will    be dependent           on the
resolve      of Consumer and Marketing                     Service     personnel        at each and every
level--from.       the plant           inspectors        to the Washington            officials.




The Administrator    of the Consumer       and Marketing     Service     should reempha-
size to individual     employ~1es at all levels        their  responsibilities      for
the enforcement    of regulations       to ensure  that meat and meat food prod-
ucts are wholesome     and unadulterated.
APPENDIX III

    To assist employees at all levels in carrying          out their   responsibilitier
    the Administrator  should establish

      --criteria    setting  forth specific   conditions under which inspection
         and grading services should be suspended at plants in violation         of
         sanitation   standards and under which equipment and specific     plant
         areas in federally     inspected plants should be rejected for use unti
         made acceptable and

      --a uniform reporting policy whereby action taken and to be taken wil
         be a required part of all reports pertaining to observed sanitation
         deficiencies.   (See p. 42.)


AGENCY
     ACTIONSAND UNRESOLVED
                        ISSUES
    The Administrator    of the Consumer and Marketing       Service   (see app. I)
    stated that:
      --The conditions    described in GAO's report are of deep concern to the
         Department of Agriculture,    and the Department is and has been deter
         mined to eliminate   such threats to the wholesomeness of the Nation'
         meat and poultry products.

      --The emphasis and objectives  of the major inspection    improvement pro
         gram already under way and now being intensified    in the Consumer :-
         Marketing Service are completely in line with and responsive to
         GAO's reconnnendations.

      --Much has been accomplished         but much remains to be done.

    With respect   to specific   actions     taken and planned,   the Administrator
    stated that:

      --A letter had been directed to a17 Consumer Protection     Program per-
         sonnel clearly outlining    inspection objectives and procedures re-
         garding sanitation    and assuring each employee of full support for
         his efforts   in enforcing sanitation  standards.

      --Meetings would be held with committees from major meat packer orga-
        nizations  for the purpose of reemphasizing meat inspection objec-
         tives and developing an educational program for their membership o-
         the whole spectrum of meat inspection,  particularly sanitation.

      --Revised procedures, forms, and instructions"had      been issued to as-
         sist inspectors in carrying out the Consumer and Marketing Service'
         policy at plants where unsanitary conditions     are found, 'including
         criteria  for withholding  or suspending inspection   for cause.

    The Administrator  also provided detailed        information   on enforcement ac-
    tions taken as a result of the inspection          improvement program. He


                                     60
                                                                              APPENDIX III        ,   ,
   stated     that, although   the record    demonstrates     progress      during   the   past
   year,    the need for still    further    action    is acknowledged.

   The action   needed will be determined by a management study now under
   way to determine   improvements  needed in administration.  This study is
   expected to have strong impact on carrying out GAO's recommendation re-
   lating to improved reporting systems to demonstrate actions taken.

    The Administrator    provided the following report on the status of the 48
    plants visited    by GAO as determined by recent Consumer and Marketing
    Service plant visits.

      --Federal inspection      has been discontinued        at five      of the 40 federally
         inspected plants.
      --Conditions  of sanitation in 27 of the federally inspected plants
         have been so improved as to meet Consumer and Marketing Service
         sanitary requirements.

      --Two of the eight nonfederally   inspected plants ceased operations
         following withdrawal of recognition   for Federal grading service.

      --Four nonfederally      inspected    plants'   operating    conditions        are now
         acceptable.

      --In the remaining eight federally   inspected plants and the two non-
         federally inspected plants, action has been taken to protect the
         product while the remaining needed plant improvements are being com-
         pleted.

    GAO believes that the actions already taken and the further actions out-
    lined by the Administrator,    if fully  implemented, substantially    comply
    with its recommendations and will Provide greater assurance to the con-
    suming public that meat Droducts are processed under sanitary conditions.
    GAO believes,   however, that, even with the intensified     enforcement ac-
    tions planned by the Consumer and Marketing Service, continuing efforts
    of all inspection   personnel to require compliance with sanitation       stan-
    dards are vital to maintaining    the integrity   of the inspection   program
    and ensuring the consuming public of a wholesome product.


M4TTERS
      FORCONSIDERATION
                    BY THE CONGRESS
    This report discusses matters of such importance              to the consuming public
    that the Congress may wish to consider the facts              revealed and the steps
    being taken to correct the situation.
        APPENDIX IV
4   *

                           PRINCIPAL OFFICIALS OF

                      THE DEPARTMENTOF AGRICULTURE

               RESPONSIBLE FOR ADMINISThlATION OF ACTIVITIES

                          DISCUSSED IN THIS REPORT


                                                Tenure of office
                                                From             To
                                                                 -
                         DEPARTMENTOF AGRICULTURE

        SECRETARYOF AGRICTjLTURE:
           Clifford M. Hardin                Jan.    1969      Present

        ASSISTANT SECRETARY, MARKETING
          AND CONSUMERSERVICES:
            Richard E. Lyng                  Mar.    1969      Present


                      CONSUMERAND MARKETING SERVICE

        ADMINISTRATOR:
            Clayton Yeutter                  Oct.    1970      Present
            George R. Grange (acting>        July    1970      Oct.    1970
           Roy W. Lennartson                 Feb.    1969      July    1970

        DEPUTY ADMINISTRATOR, MEAT AND
          POULTRY INSPECTION:
            Kenneth M. McEnroe               Sept.   1970      Present
            Lester H. Burkert (acting>       July    1970      Sept. 1970
            Gilbert H. Wise                  Aug.    1969      June 1970




                                                            U.S.   GAO.   U’ash..   D-C.
                                        62
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