Five Questions USDA Secretary Perdue Should Ask Before Lunch at the Clemens Hog Slaughter Plant in Coldwater, Michigan

On the eve of a visit from USDA Secretary Sonny Perdue on April 3, new documents obtained by Food & Water Watch raise serious questions about safety at a new "state of the art" hog slaughter plant in Michigan that is seeking to partially privatize its inspections process.

The Clemens Foods hog slaughter plant began operations in September 2017, with a full complement of USDA inspectors working the slaughter line. The plant has since been granted regulatory waivers to partially privatize its inspections and increase its slaughter line speed, and Food & Water Watch is urging Secretary Perdue to question plant managers on several aspects of the new privatization scheme uncovered in the documents.

"We wanted to help the Secretary out with some background on the track record of this facility's controversial hog inspection pilot program," said Tony Corbo, Senior Lobbyist at Food & Water Watch. "Company records raise important questions Perdue should ask company officials during his visit."

Prior to the opening of the new Clemens plant, pork industry trade publications were projecting that the plant would be slaughtering 12,000 head per day on one slaughter line, or 1,500 head per hour. The current line speed cap in a high-speed hog slaughter plant that receives traditional inspection is set at just 1,106 head per hour, with seven USDA inspectors stationed at key points of the slaughter process.

But the Clemens' Michigan plant was granted a regulatory waiver by the agency on September 22, 2017 to reduce the number of USDA slaughter line inspectors from 5 to 2. The USDA also permitted the plant to run its slaughter line as fast as it could, provided that it could "maintain process control." The vacated positions of USDA inspectors would be assumed by plant employees, who would also conduct ante-mortem inspections of live animals before they entered the slaughter line. It seems that the plant was being used by USDA's Food Safety and Inspection Service (FSIS) as a demonstration project to support expansion of this privatized inspection model. On February 1, 2018, FSIS proposed a rule - called the New Swine Slaughter Inspection System - to expand this privatized inspection model to all hog slaughter facilities.

Food & Water Watch filed two separate Freedom of Information Act requests for documents regarding this "state-of-the-art" plant. The documents revealed several issues that Secretary Perdue should ask company officials about during his visit:

• The plant implemented its regulatory waiver program on December 7, 2017. In a December 19, 2017 email from FSIS District Manager Paul Wolseley to FSIS headquarters staff (p. 1), he reported that as the plant increased its line speed, it reached a point where it "lost process control" and was forced to reduce the slaughter line speed. The line speed at which the plant "lost process control" was redacted, and the reason it "lost process control" was never identified.

The first question Secretary Perdue should ask the Clemens company officials is: What was the line speed at which the plant "lost process control" and what was the reason the plant was forced to reduce its line speed? Furthermore, at what line speed is the slaughter line currently running?

• On December 12, 2017, just five days after the plant shifted to the privatized inspection model, a non-compliance report was filed (pp. 2-3) against the plant because a plant employee who had been charged with conducting ante-mortem inspection of animals prior to slaughter failed to notice a dead hog in the holding pen. One of the concerns with turning over inspection duties to plant personnel is that there is no guarantee that they will be properly trained to perform those tasks that had been formerly performed by FSIS inspectors and veterinarians. Some in the veterinary community have expressed concern that untrained plant employees will not be able to detect exotic animal diseases, such as foot-and-mouth disease, that could devastate the entire livestock industry should they go unnoticed - or be properly trained to identify downed animals.

The second question the Secretary - a veterinarian by profession - should ask the Clemens company officials: How are your employees trained to detect animal diseases and to identify downed or dead hogs prior to slaughter during the ante-mortem inspection process? How often do they receive this training and do you test them for proficiency? What kind of training do your employees receive for post-mortem inspection? How often do they receive training and do they get tested for proficiency?

• Even though this plant is being advertised as "state-of-the-art," there was a design flaw discovered by FSIS inspection personnel (p. 23). It seems that hog carcasses swing so wildly on one part of the line that they inadvertently hit the stop button for the entire slaughter line.

The third question the Secretary should ask the Clemens company officials: Has the issue with the hog carcasses inadvertently striking the stop button on the slaughter line been resolved?

• Even though this is a new plant, it has already been cited numerous times (pp. 4-22) by FSIS inspectors for improper sanitation during pre-operational inspection checks.

The fourth question the Secretary should ask the Clemens company officials: What are you doing to ensure that proper sanitation of the plant is conducted prior to the start of operations each day?

• On the processing side of the plant, FSIS inspectors reported (p. 23) that meat often falls off of conveyer belts.

The fifth question the Secretary should ask the Clemens company officials: Have you been able to address the issue of meat falling off conveyor belts on the processing side of your plant to FSIS' satisfaction?

"These are all legitimate questions that need to be asked and addressed prior to using the Clemens plant experiment as a justification for the implementation to new inspection system across the entire pork industry that seems to yield no improvements in food safety," said Corbo. "We hope the Secretary asks these questions on his visit and will make the information available to the general public."

View the documents obtained by Food & Water Watch at: https://www.foodandwaterwatch.org/sites/default/files/clemens_foia_documents.pdf