The key to understanding the complexities in the debate over the line speed issue for poultry production is to recognize that there is a distinct difference between the line speed for slaughter and the line speed for processing in a facility. While slaughter line speed is currently limited to 140 birds per minute (bpm), except for certain facilities, there are no regulations that limit the line speed for processing itself where birds are cut up and turned into various products.
More intuitively, another key point is that the work performed by poultry processing line personnel is incredibly difficult and ensuring the safety of these workers is of paramount importance. It is the intersection of these elements that is vexing the debate over line speed.
When chickens arrive at a typical high volume slaughter facility, numerous workers are present to suspend each bird by their feet on a moving line and, within seconds, the chickens are calmed by rub bars that are intended to provide a comforting sensation on the chest. This procedure usually is accompanied by the use of dim lighting which helps keep birds calm. They are then electrically stunned to render them unconscious before a machine administers a quick, single cut to the throat.
After slaughter, the birds enter the cleaning and evisceration segment, which is a highly automated process where machines remove feathers and internal organs to prepare the birds for processing. The birds are placed in a bath of hot water to loosen feathers and then a machine removes the feathers. The carcasses then go through a quality control part of the slaughter line to ensure that any visual defects – bruises or fecal material – are removed before being washed and then sent to the chiller. After being chilled, microbiological tests are conducted by the company and by the USDA for microorganisms such as Salmonella.
The slaughter practices described above is the subject of the current debate over slaughter line speed, which is limited by regulation to 140 birds per minute (bpm), except in so-called HIMP facilities, which are allowed to operate their slaughter lines up to 175 bpm. The petition submitted to FSIS by the National Chicken Council (NCC) last year requests that the slaughter line speed limit to be set at 175 bpm.
If the petition is approved by FSIS, not every poultry plant would immediately increase the slaughter line speed. Because this part of the process is highly automated, the plants would have to ensure that they have the appropriate technology to allow for the accurate operation of the machines at the higher speed while still being able to maintain process control, or address potential food safety threats. The average slaughter line speed at the so-called HIMP facilities is actually lower than the allowable 175 bpm, and that likely would be the case if the NCC petition is approved.
New poultry inspection system
The quality control segment of the line is the focus of FSIS’ effort to modernize the poultry inspection system. Science informs us that the visual defects on poultry carcasses have very little impact, if any, on food safety and that removing them is essentially a quality control task.
The primary food safety threat in this part of the process is removing visible fecal material. While feces can be removed through proper cooking, not every poultry product is cooked properly, which increases the risk of cross contamination on surfaces and other foods being prepared if fecal material with live pathogens is present. Because the presence of feces on carcasses is gross, a facility has every incentive to ensure it is removed as no one would purchase the product. Similarly, since feces can presents a food safety threat, continued visual inspection by FSIS is necessary.
With this in mind, the question becomes whether it makes sense for a government agency (FSIS) to provide a company with subsidized labor by performing its quality control tasks for them, or could agency resources be allocated toward activities directly related to food safety, such as microbiological testing for Salmonella.
More generally, another critical question becomes whether the existing law that has been in effect since the mid-1950s that mandates visual carcass-by-carcass inspection has become antiquated and incapable of addressing current food safety threats that continue to evolve. The fact is poultry slaughter line speeds could be reduced to one bird per minute and it would have no impact on food safety because you cannot see Salmonella.
Under NPIS, the quality control tasks are performed by plant employees, while FSIS inspectors still are present to conduct visual carcass-by-carcass inspections to ensure carcasses are free of visual defects before entering the chiller. Additional FSIS inspection personnel are available to perform tasks that are more directly related to food safety, including sample collection for microbiological testing, ensuring the plant is sanitary, and following its HACCP procedures.
There are no regulations that limit the line speed for processing where carcasses are typically cut and deboned, and turned into products sold in stores or used in restaurants. While plants can theoretically set the processing line speed as fast as they would like, they still are subject to HACCP principles to ensure that their product is not adulterated and food safety risks are being addressed, regardless of the processing line speed. Failure to adequately address food safety risks can result in the facility being shut down.
Also, because the process of cutting and deboning is strenuous work, poultry plants must find the right balance between worker safety and delivering a quality product.
A significant concern of increasing line speed is the potential for further endangering the poultry industry’s labor force. Carpal tunnel syndrome is a common injury for poultry workers who perform these grueling and dangerous tasks. First-time visitors to any slaughter facility often are struck by two images – the slaughter process itself, and the demanding work required over a sustained period of time to transform poultry carcasses into products presentable for sale.
Having to perform these tasks at a higher line speed would exacerbate an already tough work environment. That notwithstanding, it should be noted that the petition to increase line speed for slaughter would not impact the line speed for processing; it is an important component of the debate that should be clarified and that the line speed for both should not be conflated.
However, this does not invalidate the concern about worker safety. If the line speed for slaughter is increased, it is a fair assumption that companies will need to increase the processing line speed or to accommodate the extra inventory in the chiller. While the industry has countered that it instead would add workers to the line or install additional processing lines, it is not clear whether there is enough space in most plants to accommodate additional employees or equipment.
The intersection of food safety and worker safety will continue to vex the debate over line speed issues in poultry slaughter plants. The resolution of this issue will require a level of trust among all stakeholder groups.
Labor groups have to trust that poultry industry companies will not increase processing line speed if the plants are permitted to operate at a higher slaughter line speed. Consumers have to trust that the poultry industry will be as effective as FSIS in ensuring visual defects are removed from carcasses, and that industry would not advocate for policies that intentionally harm workers or facilitate the production of unsafe foods. Poultry companies have to trust that workers care to make quality products efficiently, and trust that consumers recognize that industry would not intentionally produce unsafe foods that harm their brands.
However, there has been long-standing and extensive levels of distrust between and among all of these groups that has been exacerbated by the current political climate. Given this, consensus on this issue, regardless of FSIS’ decision, seems highly unlikely.
About the author: Brian Ronholm is currently senior director of regulatory programs at Arent Fox LLP. He previously served as USDA Deputy Undersecretary for Food Safety in the Obama Administration and, prior to that, on the staff of Rep. Rosa DeLauro.
(To sign up for a free subscription to Food Safety News, click here.)