USDA-FSIS Quarterly Enforcement Report: Downloadable Raw Data and 10 Year Trends

data-graphicIn my mass of emails from the government each day, every quarter I get one from FSIS letting me know what they’ve released their quarterly enforcement report. These reports detail actions taken against specific establishments, as well as details on how many enforcement-type actions are taking place ongoing.

I have a problem with this report however. It’s presented as a pdf with no metrics or historical data to put the information in context. FDA has done a good job in the past few years at releasing metadata in formats that allow analysis (CFSAN adverse event reports, inspection database, etc.), but USDA takes the time to kick out this report without showing what the trends are.

Alright raw data nerds, here at FF&F we’ve got your back. For all your analysis needs, we’ve collected a few of the more “top level” reporting numbers from reports going back to 2007, and put them all in excel for you to strip apart and analyze to your hearts content. We’ll even keep updating this spreadsheet and re-uploading every quarter ongoing.

fsis enforcement reports data (.xlsx)

Because some of us like bringing home a growler on a Friday night and entering data to do basic trending on government statistics, here are some of the trends I found interesting that aren’t visible by looking at any one of the individual reports.

verification-procedures-performed

These are the number of individual verification procedures performed by FSIS inspectors each quarter. We can’t speak as to why there was such a change in 2010-2011, as these numbers could simply have started being calculated differently in the system. But NPR had some data to suggest that overall meat consumption started declining in 2010, which could lead to fewer establishments or approved inspection hours, and thus fewer verification events.

compliance-rate

Compliance rates have always remained above 98% (meaning that 98% of all verification activities end with an inspector going “okay, you’re doing the right thing here”). But like overall verification, compliance seems to have a slight downward trend as well. It’s hard to say this decline is significant since the standard deviation of these percentage data is only 0.0016, but the whole point of getting this data organized to demonstrate the trend is to keep tabs on things like this. It’s hard to never have a downward trend when you hover near 100%, but it will be interesting to see if there is any FSMA effect in the next few years on this trend in either direction.

percent-of-nr-appeals-that-were-granted

That 2% noncompliance rate is a count of Noncompliance Records (NR’s) that are issued. Per FSIS:

An NR is a written record that documents noncompliance with FSIS regulations. An NR notifies the establishment of the noncompliance and that it should take action to remedy the situation and prevent its recurrence. Noncompliance reported on NRs varies from non-food safety issues to serious breakdowns in food safety controls.

When an establishment fails a verification activity, it is issued an NR and has the option to appeal if they think an observation was out of context, the inspector was incorrect in his/her interpretation of the regulation, or some other circumstance led them to believe the finding was incorrect. The graph above shows that historically about 1/3 appeals are granted by regional offices/DC when establishments challenge an NR. But in recent years that number has dropped from around 35% to 30%. This could have also contributed to the increased number of noncompliances observed earlier, now that fewer appeals are being granted.

percent-livestock-carcasses-condemned-of-those-inspected

The poultry carcass inspection/condemn data didn’t have any interesting trends, it swung up and down without a lot of overall variation. The livestock carcass data was more interesting in that it seems to have a sustained downward trend.  This could be to better herd health in the last decade or more efficient slaughter practices that result in fewer condemned carcasses from injury or contamination. While the cause is uncertain, as long as it isn’t the result of poor or inconsistent enforcement, this is a great trend! Fewer condemned animals is better for the animals and the environment.percent-meat-and-poultry-refused-on-inspection

I’m not sure this paints a completely accurate picture, but the data points were real, they actually wrote zeroes in the older reports. While the number of products imported has increased overall, this % refused trend shows that even though imports are increasing, we’re also rejecting more meat at the border than ever before. You can check out this FSIS directive to learn more about inspection of imported meat and poultry and what refusal criteria might be.

If you’re more intense than I am and want to do advanced statistics that excel can’t handle, you can see what’s out there in terms of software and let me know if you discover any new insights from this data! The spreadsheet and all graphs were created from source data in the FSIS quarterly enforcement reports.

 

 
ResearchBlogging.org

USDA/FSIS (2017). Quarterly Enforcement Report for Quarter 1, Fiscal Year 2017 United States Department of Agriculture
 

Why isn’t the USDA declaring the invisible feces in our meat?

No, that wasn’t a typo. Today I came across this petition for rulemaking to FSIS from the Physicians Committee for Responsible Medicine.

First off: PCRM has some great programs that promote research, animal welfare, and better medicine. The overall merit of their organization cannot be judged by a single program or campaign they have in place.

Now let’s tear this petition apart, because I actually had to check their website to make sure it was real, and not an over-the-top satire from The Onion.

The concern the committee wishes to correct via this petition is thus:

“Inconsistent with its statutory mandate, USDA regularly passes at inspection meat and poultry that is  contaminated with feces. Although USDA implements a “zero tolerance” policy for fecal contamination, this policy applies to visible fecal contamination only. The result is that fecally contaminated meat and poultry products pass inspection as long as the feces on them are not “visible” to the naked eye.

This inspection policy conveys a misleading promise of “wholesomeness.” Feces may contain round worms, hair worms, tape worms, and leftover bits of whatever the animal excreting the feces may have eaten, not to mention the usual fecal components of digestive juices and various chemicals that the animal was in the process of excreting. Americans deserve fair notice that food products deemed “wholesome” by USDA would be deemed disgusting by the average consumer and adulterated under any reasonable reading of federal law.”

Not to quote without context, the petition goes on to list the ways in which non-obvious feces may be introduced to meat product, the most valid being shared scald/chill tanks in processing operations.

Ultimately, the corrections the committee is seeking are removal of the “wholesome” description from USDA inspected meats, begin treating feces as an adulterant, and:

“USDA should amend sections 317.2(l)(2) and 381.125(b)(2)(i) of the Code of Federal Regulations to exclude from the current mandatory label the sentence that reads, “This product was prepared from inspected and passed meat
and/or poultry.” USDA should amend sections 317.2(l)(2), 381.125(b)(2)(i), and 381.125(b)(2)(ii) of Title 9 to include in the mandatory label the following as the second-to-last sentence: “This product may be permeated with feces, which cooking does not remove.”

That’s some pretty heavy language, perfectly stated to play on the fears and squeamishness of your average consumer. However, I see nothing written there about food safety, so the intention of the change is obvious: prevent people from eating meat.

While the about page for PCRM mentions nothing about being proponents of animal rights, the amount of articles devoted to encouraging a purely vegan diet clearly shows that they have an anti-meat agenda. While they correctly advertize the health benefits of vegan foods, a quick search of their website saturates any visitor with the message “meat is bad, and animal agriculture is always cruel”.

The petition shines a light on a group that is ready to intentionally scare and mislead consumers into changing their lifestyle. As part of their justification that feces is everywhere, they cite one of their own studies, “Fecal Contamination in Retail Chicken Products“. In this study, the committee proved that invisible fecal contamination is everywhere by “testing for the presence of feces.”

No such test exists.

What they actually did was test for generic E. coli, which can act as an indicator organism for fecal contamination.  HACCP programs in slaughter facilities use on-line enumeration of E. coli and other coliforms to validate critical control points for just that purpose. But in this case, rather than setting limits and using a statistical rationale to make a conclusion about the level of contamination, it appears that any evidence of the presence of E. coli  led to the determination that the sample was contaminated with feces. Because there are no methods declared, this evidence could be as mundane as RNA fragments from a non-pathogenic strain recovered in an enriched sample.

The study is absolutely meaningless. There is no available data to review in terms of the levels of contamination, no methods listed for how the E. coli was enumerated, and finally no legitimate publication, suggesting that the construction of the study and its conclusions would not have passed peer review.

As part of the rule change, PCRM would like feces to be declared as an adulterant. Generally, USDA inspectors cannot allow adulterated products to enter commerce, adding to the ludicrosity of this proposal. By the PCRM’s definition, all meat products are covered in invisible feces, and the presence of invisible feces should prevent any product from entering commerce. In one swift move, PCRM will ensure that only clean, wholesome meats will be sold, i.e. none.

But have things changed over the years to make eating meat less safe? The PCRM thinks so. I have no data to argue whether or not Americans are cooking less (PCRM also neglected to provide data), and eating more RTE products, but I did think it was funny that when I read this:

“Americans today consume far more meat and poultry than ever before, thereby increasing their potential exposure to fecal contamination in these products”

When the first link I read on their website contained this graph…
http://www.pcrm.org/media/blog/nov2013/youre-in-good-company-with-a-vegan-thanksgiving
http://www.pcrm.org/media/blog/nov2013/youre-in-good-company-with-a-vegan-thanksgiving
Which is it PCRM? Whichever is more convenient for the ad campaign at the time?
(side note: if people indeed are eating out more in restaurants, that would mean they are eating at inspected restaurants where county health inspectors ensure adequate cooking temperatures, rather than at home where people rarely if ever have proper process control)

Finally, the idea that the USDA needs to declare the presence of invisible feces on every product that passes inspection makes no logical sense,  and does nothing but mislead the consumer, not only by implying that the product isn’t safe in general, but that fully cooking the product makes no difference. If it wasn’t obvious by now that this proposed rule change isn’t solely to earn points with vegans, look closely the wording. In order to turn consumers off meat, PCRM would risk undoing years of public education and trust in proper cooking temperatures.

Clearly I took this proposal too literally, but because FSIS will actually have to review the proposal, and PCRM wants to brag about how these changes might occur, I offer one last piece of evidence to support my view that this proposal belongs on a tabloid.
Proposed legends

…one of their proposed inspection marks literally contains a DO NOT EAT symbol.

ResearchBlogging.org

Physicians Committee for Responsible Medicine (2013). Re: Fecal Contamination of Poultry and Meat USDA Petition for Rulemaking

claimtoken-529d75f1bc9a5