The industry is committed to ensuring a safe, wholesome, and abundant supply of poultry products for both domestic and international markets, and the poultry slaughter inspection system plays an important role in this process. The chicken industry supports a science-based, statistically validated, establishment-oriented approach to food safety and poultry slaughter inspection.

Dr Ashley B. Peterson, vice president of Science and Technology for the National Chicken Council

In 1997, the Food Safety and Inspection Service (FSIS) reported that studies by the National Academy of Sciences, the General Accounting Office (now, Government Accountability Office), and US Department of Agriculture (USDA) "have established the need for fundamental change in the meat and poultry inspection program".

Perhaps one of the most fundamental and most criticised components of the proposed rule is the new responsibilities of the online FSIS inspector. The proposed rule is not 'privatisation of inspection' although that phrase has been used frequently by the proposal's critics.

Under the proposal, a USDA inspector will be stationed farther down the evisceration line and just before the chiller to ensure that birds have been properly processed. The facility will now be in charge of its own quality assurance programme by training sorters to remove any quality defects from carcasses, thereby allowing FSIS inspectors to focus more on food safety-related parameters and not visible defects.

This is a significant change from the current inspection system. This change, coupled with the various other components of the proposed rule, will require significant investments on behalf of the chicken industry.

Once finalised, implementing USDA’s proposed rule will not be a simple process. In fact, the implementation process will require extensive time, effort and investment on behalf of chicken companies. Substantial capital will be required to make the necessary changes - from equipment to personnel - within each chicken processing facility that chooses to implement the new system and production adjustments would only be made when the market dictates such.

Specifically, equipment in many chicken processing facilities is already at capacity. If a facility wants to keep its existing equipment, it still will have to retrofit the existing layout by moving lines and installing new inspector stands. All of these changes cost money.

If a processing facility wants to increase line speeds, it may have to invest millions of dollars to install a faster evisceration line depending on the capability of its existing equipment. If a poultry company decides to increase line speeds, it may also need to add additional lines in second processing. Since this investment would be substantial, not all chicken processing facilities will elect to participate in the new inspection system.

The second topic is personnel. With the increase in record-keeping, microbiological testing and carcass sorting, more employees may be necessary. New employees may also be necessary on the evisceration line and in second processing if a facility elects to increase line speeds. All employees require extensive training and must be kept current on all practices and procedures within the plant.

Third, and most important, is the question regarding market conditions and the basic economic principle of supply and demand. Market conditions and consumer demand for chicken will dictate whether to increase chicken production - not the industry’s ability to increase line speeds.

Coming off of the worst financial year in the chicken industry’s history, USDA forecasts about a two-per cent decline in production for 2012. A company cannot simply flip on a switch to increase production, and as stated above, even if it could, market conditions would have to be such that increased production makes sense for that company.

February 2013