By Nicole Johnson

“The general public must recognize that only after the demystification of U.S. agriculture will family farmers, labor, and consumers see beyond corporate agribusiness’ manipulations to the point where they will recognize that both their mutual interests and the future of agriculture can be best decided through a system that not only practices political democracy, but economic democracy as well.” — Ingolf Voegler


Readers of the New York Times were recently treated to a rarely glimpsed view of how the globally-sourced industrial food complex assembles the raw ingredients of the omnipresent hamburger.  In his startling expose entitled “E. Coli Path Shows Flaws in Ground Beef Inspection,” Michael Moss provides a window from which to witness well-hidden meat industry practices that most people, judging from some six hundred comments left on the New York Times website within 24 hours of the article’s publication, find thoroughly repulsive.[1]

Moss’s article tracing the processing history of the E.coli-contaminated hamburger consumed by Stephanie Smith, which left her body ravaged and permanently disabled, has much to commend it.  While detailing how Cargill shaves costs by scraping together its “American Chef’s Selection Angus Beef Patties” from trimmings and mash-like products  sold to it by no less than four suppliers, Moss uncovers how the company failed to follow its own safety plans without facing any interference from the USDA until some one got very, very sick.

However, the article leaves out critical information from its analysis that would help us understand why so much is wrong with the meat inspection process today.  Filling in these gaps is important if we want to take the correct measures improve the safety of our meat supply.  Furthermore, if we don’t gain a fuller understanding of how and why the meat industry’s inspection process became an essentially unregulated, privatized affair, we are likely to repeat the same mistake and allow Congress to pass food “safety” legislation that will serve to make the world a safer place for the cartels controlling the global produce trade but do nothing at all for the safety of our food supply.

The vested interests behind the creation of the 2009 Food Safety Enhancement Act and its Senate companion bill S. 510, the FDA Food Safety Modernization Act, are the same vested interests who were behind the earlier deregulation of the meat and poultry inspection process.  They aim to minimize the regulatory obstacles faced by transnational corporations engaged in international trade, which is increasingly becoming the movement of goods from one subsidiary affiliate to another subsidiary affiliate.  And they’re using the issue of food safety to con us into consenting to their wishes.

The Fundamental Fraud Undermining Food Safety

After reading Moss’s article, one might conclude that what’s needed to increase the safety of the food supply is more testing.  But that response misses the bigger the picture.  As illuminating as Moss’s article is, it completely ignores the fact that the meat and poultry inspection process underwent a radical transformation in the 90s that took away government meat and poultry inspectors’ authority to ensure product safety and handed it over to the slaughter and processing companies themselves.  Critics of this surrender of regulatory authority say it’s the equivalent of expecting the driver of a speeding car to pull over and write themselves a ticket.  It’s hardly news that corporations exist to maximize profits, not ensure society’s welfare.  But if you have any doubts that the honor system adopted by the USDA isn’t working, just ask Stephanie Smith.

So, how did one of the most regulated industries become deregulated?  For this, we can thank vested interests for engineering a regulatory coup:  mandating that HACCP plans, short for hazard analysis critical control point plans (pronounced ‘hassip’) be applied to the raw food in/raw food out stages of food production.

Since the early 70s, HACCP had been used successfully and voluntarily as a food safety approach by industrial food processors.  HACCP was originally designed to ensure product safety by including in the production process a “kill” step that rendered harmless any pathogens present in the food product.  But along the way, it was decided that the approach should be mandated to raw meat processing.  The problem is: in “raw food in/raw food out” food processing, such as meat slaughter and processing, there are no effective, definitive control steps available, such as cooking, to kill pathogens.

As explained by microbiologist Dr. William H. Sperber in a paper tellingly entitled “HACCP Does Not Work from Farm to Table”: “It is not an accident that HACCP evolved at the food processing step of the Farm to Table supply chain.  It is at this step that effective controls, such as cooking, drying, acidification, or refining are available to eliminate significant hazards…Safety is assured by process control, not by finished product testing.”[2].

Why should we listen to Dr. Sperber?  Well, for starters, he’s neither a lawyer nor a lobbyist whose positions and actions are informed by an allegiance to vested interests.  And, most significantly, this scientist, who’s currently Cargill’s Ambassador of Food Safety, has dedicated his professional life to food safety issues and the appropriate use of HACCP by industry.

Sperber’s career began when he was hired by Pillsbury’s Howard Bauman, the microbiologist who originally conceived and developed HACCP as an antidote to the unreliable quality-control system previously used by the company.  After an unfortunate incident that resulted in Pillsbury having to recall baby food, the company’s president demanded that Bauman ensure no Pillsbury product would ever again tar the company’s reputation.[3]

Prior to the development of HACCP, quality control consisted of testing batches of product for quality and safety.  However, the problem with testing product samples is that the technique, if done properly, requires testing a great deal of product in order to establish a statistically relevant result.  This approach proved not only costly, but — in the final analysis — unreliable, because a low level of contamination could still easily escape detection.[4]  Bauman’s solution was to design safety into the processing stage of processed food production.  The solution was so effective that HACCP was adopted by NASA so that the astronauts would not be put at risk of food-borne illness in space.

Sperber has carried on Bauman’s work with HACCP throughout his career.  In a lecture given this past June at the Institute of Food Technologists at its Annual Meeting and Food Expo in Anaheim, CA, Sperber discussed how major food safety regulations developed in the 1990s – the Pathogen Reduction/HACCP rule, often referred to as the “MegaReg,” for raw meat and poultry products; the fish and fishery products HACCP regulation; and the juice HACCP regulation — “bear little resemblance to HACCP, even though they are called HACCP rules.”[5]

Sperber notes that the MegaReg, which was developed behind closed doors in secrecy, should have included the use of aerobic plate counts to effectively monitor process control and verify safety.  Instead, testing protocols were established, which amounted to a warmed-over quality control program – just the thing Bauman’s HACCP approach was designed to replace.

Testing – Providing a False Sense of Security

Sperber says the testing that is used today “provides a false sense of security that something useful is being done, while hindering our ability to develop and use regulations and procedures better suited to protect the food supply.  Words have meaning: HACCP is not quality control.  The HACCP system emerged precisely because product testing can not reliably detect low-incidence contamination that is responsible for most, if not all, foodborne illness outbreaks.”[6]

Safety failures, Sperber notes, are most often the fault of non-compliance with sanitary design and cleaning.  Problems occur when sanitizing procedures are not followed.  Providing the necessary resources to ensure sanitary procedures are followed is the key to safe food production.

The folly of relying on testing protocols is further demonstrated by USDA’s lack of willingness to engage in effective of oversight of its own regulations.  In a report called “Hamburger Hell: The Flip Side of USDA’s Salmonella Testing Program” by Felicia Nestor and Patty Lovera, the authors expose “a systematic breakdown in the integrity of the sampling program, to the extent that its results are unable to support conclusions about changes in contamination rates.  Whether due to systematic incompetence or bad faith, USDA’s “don’t look, don’t find” policy means it is fundamentally deceiving the public with false reassurances.”[7]   This disturbing review of data obtained through the Freedom of Information Act shows that the USDA consistently postpones intervening at plants, especially large ones, even after tests show the presence of harmful pathogens.  Really now — What’s the point of all this testing if you’re not even going to act on clear evidence  proving that product posing a threat to human health is repeatedly entering the marketplace?

Given the way the USDA conducts itself, you might even begin to wonder why we bother to budget the agency’s regulatory activities at all.  Perhaps the reason we have regulatory agencies is because they make it so easy for vested interests, once they’ve captured the agency, to game the system to their advantage.

The Game Changer

In an earlier article entitled “History, HACCP and the Food Safety Con Job,” I described how the bout of regulatory reform that mandated all federal- and state-inspected meat and poultry companies to create and maintain HACCP plans was a politically-based policy masquerading as a science-based measure.  Its real achievements were to drive small meat processors out of business, increase market consolidation, and privatize the meat inspection process for large transnational corporations.[8]

These radical changes to the meat and poultry inspection process were spearheaded by none other than Michael Taylor, some one — it could be argued – who has done practically more than anyone to pervert regulatory law and legally permit the poisoning of our food supply.  This is the same Michael Taylor who represented Monsanto while a lawyer at King & Spaulding, a law firm that attends to the wishes of the top pharma, chemical, agribusiness and biotech multinational corporations.  The same Michael Taylor who had spent nearly a decade working to weaken the Delaney clause, a very good law designed to protect public health by prohibiting cancer-causing chemicals from being added to foods.  The same Michael Taylor who had just finished implementing at the FDA the pseudo-scientific policy of “substantial equivalence” so that Monsanto’s patented genetically engineered bovine growth hormone could be unleashed on the market without undergoing any pesky safety tests proving it would not cause harm to human health or the environment – no matter that it sickens cattle and has been linked to  human breast, prostrate and colon cancers.[9]  And it’s the same Michael Taylor who subsequently went to work for Monsanto as its Vice President of Public Policy where he worked on long-term strategic planning.   And now, the same Michael Taylor is the guy the Obama Administration has installed at the FDA to “fix” our food safety problems, no doubt here to put all that long-term strategic planning into action.

Ironically, Taylor’s career has been a boon for the organic food industry, which has grown steadily as the public turns away from industrial food products loaded with dangerous pesticides, GMOs, additives, aspartame, preservatives and flavor enhancers.

So what does Michael Taylor want to do to fix our food safety problems?  He wants to mandate HACCP plans for raw-food in/raw-food out produce processing, exactly what Dr. Sperber says, sensibly, can’t be done effectively.

In the 106 pages of documents and correspondence accompanying Moss’s article, we read repeatedly about how Cargill did not follow the HACCP plans it created, which should lead us to question if our post-HACCP meat supply deserves the USDA’s seal of approval.  Since Taylor’s MegaRegs took effect, the meat and poultry industry is a place in which large processors like Cargill police themselves with minimal, if any, interference from the USDA’s Food Safety and Inspection Service.  In fact, if we look, we find that the USDA even helps large processors cover up cases of gross contamination.

The Case of John Munsell and Montana Quality Foods

A compelling investigative report called “Shielding the Giant: USDA’s ‘Don’t Look, Don’t Know’ Policy for Beef Inspection” by Tom Levine, the Legal Director at the Governmental Accountability Project, provides overwhelming evidence that USDA officials work to protect business interests over the interests of public safety.[10]

John Munsell, a small businessman and owner of Montana Quality Foods, discovered that meat sold by Con Agra’s Greeley, CO, plant to his Miles City, Montana, processing plant was contaminated with E. coli O157:H7.  When Munsell tried to report the problem to the USDA, officials not only covered up the evidence, they engaged in retaliation against Munsell, eventually forcing him out of business, all to protect ConAgra and the USDA’s  role in allowing contaminated meat product into the marketplace.[11]

Had the New York Times’ Michael Moss looked at the history of this USDA/ConAgra cover-up, he would have found information that explained why Taylor’s brand of HACCP makes it inevitable that E. coli-contaminated hamburger will eventually make its way to the public, and why Stephanie Smith will not likely be the last person disabled by her dinner.

The Government Accountability Project’s investigative findings included evidence that the public was being exposed to E. coli O157:H7 for two years before the 2002 ConAgra recall finally happened, an event triggered because John Munsell was courageous enough to blow the whistle on them, despite enormous personal cost.  According to the report, “Starting in late summer 2000, FSIS repeatedly discovered that ConAgra had been receiving products returned from its customers as E. coli O157:H7 positive.  Each time the agency allowed the tainted beef to be cooked and reentered into commerce, without warning the public or imposing systematic corrective action.”

The report also found that “The regulatory double standard is a microcosm why the integrity of HACCP is at risk.  The ConAgra-USDA cover up sustains a pattern of using HACCP as a vehicle to obstruct its staff from enforcing food safety laws at big business, while bullying small business such as family firms.”

Putting Knowledge and Experience Out To Pasture

One of Taylor’s objectives in mandating HACCP was to reduce and eventually eliminate the inspectors’ traditional role at the plants and limit them to auditing paperwork completed by plant personnel.  Instead of being able to remove from the line any feces- covered carcass, inspectors are now instructed to “let the system work.”   As Taylor writes, “USDA will focus on verifying through its inspection activity that every company-designed HACCP plan is appropriate and working properly and that each company is meeting food safety performance standards.”[12]   But auditing paperwork completed by company personnel showing its record of meeting performance standards is hardly the same as having authority to immediately remove obviously contaminated product.

Another objective of Taylor’s deregulation program was to reduce personnel.  Taylor maintains that “For USDA, taking an HACCP approach will permit more efficient deployment of inspectors, allowing them to focus on the most important food safety concerns in the plants they monitor.” [13]   “Efficient deployment” translates into allowing inspectors to retire and not replacing them.   Furthermore, when new inspectors are hired, they are trained only in HACCP.

In a report entitled “Federal Meat Inspectors Spread Thin as Recalls Rise,” OMB Watch discovered that “While Congress has appropriated significantly more money since the early 1980s, the agency has not spent proportionally for personnel.  In the early 1980s, FSIS spent about 69% of its appropriated funds to pay its employees.  However, the percentage has steadily dropped.  By FY 2007, the agency only spent 57% on employee compensation.   And correlated with this decline is a drop in the number of agency workers.”[14]

While the number of workers declined, however, their responsibility increased – dramatically.  OMB Watch notes that “in FY 1981, FSIS employed about 190 workers per billion pounds of meat and poultry inspected and passed.  By FY 2007, FSIS employed fewer than 88 workers per billion pounds, a 54% drop.”

As a consequence, OBM Watch reports that “The ability of processors and manufacturers to circumvent the FSIS inspection process is aided by widespread inspector shortages.  According to The Baltimore Sun, ‘inspectors interviewed said that because of vacancies in the ranks, inspectors are often forced to do the work of two or three staff members, making it all the more difficult for them to catch the signs of disease either in the animals before slaughter, or in meat that has been butchered.’”

In its highly informative report “Safety Last: The Politics of E. Coli and Other Food-Borne Killers,” The Center for Public Integrity interviewed James Marsden, who was also interviewed by Moss for his New York Times’ article.   According to the Center for Public Integrity, Marsden made the important observation that “there is a distinction between animal-disease protection and prevention – which is what USDA inspectors have been doing for decades – and food-safety protection, which is what HACCP seeks to address.  Animal-disease protection is making sure that diseased cattle with tumors, abscesses, and other problems don’t get into the food chain.  Food safety is making sure that bacteria don’t get into it.  Both should work together.”[15]

Marsden also speculated that “Maybe [those in the industry] see this as an opportunity to say we can use HACCP and food safety as a way to deregulate the meat and poultry industry.”[16]

A tragic consequence of the decline in the number of inspectors is the corresponding decrease in the agency’s ability to meet critical needs, such as adequately performing ante-mortem inspections that ensure animals entering the plants are healthy enough to walk through the doors on their own accord.  The only parties to benefit from this situation are the meat and poultry cartel players; Americans suffer and even die without real inspection or meaningful enforcement.

Down but Not Out at Hallmark/Westland Meat Company

The one-sided focus on HACCP has a profound effect on the USDA’s traditional role in animal-disease protection.  According to testimony given in April 2008 to the House Committee on Oversight and Government Reform by Stanley Painter, the chairman of the National Joint Council of Food Inspection Local Unions of the American Federation of Government Employees, the scandal at the Hallmark/Westland Meat Company in Chino, California, “highlights one of the problems that we have attempted to raise with the agency ever since 1996 when Hazard Analysis and Critical Control Points (HACCP) inspection system was put in place.  There seems to be too much reliance on an honor system for the industry to police itself.  While the USDA investigation is still going on at Hallmark/Westland, a couple of facts have emerged that point to a system that can be gamed by those who want to break the law.”[17]

Painter says that “the bottom line is that if plant management creates a culture for their employees to skirt around FSIS regulations, they can usually find a way to do it because inspection personnel are usually outnumbered.”[18]

Without enough inspectors, public safety is dependent on company personnel to alert the veterinarian if an animal is “down” and removed from the slaughtering process, a requirement necessary to ensure downer cattle, a source of mad cow disease, are neither abused nor used for slaughter and get into the food supply.  Video shot undercover at the Hallmark/Westland Meat Company by an investigator for the Humane Society of the United States proves the honor system isn’t a viable substitute for the presence of  government inspectors.  Showing acts of extreme cruelty, the video also documented the plants’ workers were guilty of violating the Human Slaughter Act.

For the Love of Money

According to Gail Eisnitz of the Humane Farming Association and author of the disturbing book Slaughterhouse, “The privatization of meat inspection has meant a quiet death to the already meager enforcement of the Humane Slaughter Act.  USDA isn’t simply relinquishing its humane-slaughter oversight to the meat industry, but is – without the knowledge and consent of Congress – abandoning this function altogether.” [19]

Though the USDA denies this, Eisnitz points out that “They’ve gotten rid of the task codes that would direct the inspectors to actually monitor the slaughtering areas, and the handling as well, so basically, nobody’s watching what’s happening inside these operations.  The USDA meat inspectors are completely powerless when it comes to enforcing their own regulations.  They’re virtually prohibited from doing so.” [20]

The speed of the slaughter and disassembly line directly impacts a company’s bottom line.  And companies don’t really want any limitation on how fast they can go.  The implementation of HACCP has effectively eliminated the natural restriction on line speed that was dependent on inspectors’ physical ability to witness and control events at all line stations.  Maximizing profits is a lot easier that way.  In Europe, however, line speeds are slower in order to allow proper inspection to occur.

With Increased Speed Comes Increased Risk

The increase in line speed and company pressure on workers to maintain a certain pace also directly increases the likelihood of inhumane treatment of animals.  The inhumane treatment of animals, in turn, directly increases the chances that 1) animals will not be successfully stunned and rendered insensible prior to being shackled, hung and fully bleed out, which means they’re conscious and suffering while being cut to pieces along the disassembly line; 2) workers will sustain injuries from trying to perform their duties on struggling, live animals; and 3) feces will contaminate meat.

Tom Devine of the Government Accountability Project has said that “Contempt for federal law has been systematic at these plants as it extends to the treatment of animals, as well as trying to make money off of products which are contaminated with filth.  It gets so extreme, that as one whistle-blower was telling me, in order to be more productive, not to lose time, that they were skinning the cows before they had died.  Literally skinning them alive.  It’s absolutely revolting, inhumane treatment of animals at these plants.”[21]

Pre-HACCP, USDA inspectors used to be able to stop the line for a live cow, but now, with as many as 390 cattle being processed each hour, inspectors are required to leave it up to plant personnel to do the right thing while they go audit paperwork at the plant-designated critical control point.  With HACCP, the USDA has provided packers the ability to violate the Humane Slaughter Act with impunity.

Business Platforms R Us

In a 1997 article for Resources for the Future called “Preparing America’s Food Safety System for the Twenty-First Century,” Michael Taylor writes that “New technologies have long been central to building the safety, economy, and convenience of the American food supply, and the new HACCP framework encourages industry adoption of new technologies to control harmful bacteria. Continued success requires investment in technology development, rigorous but prompt government approval processes, and public understanding and acceptance of technology and its benefits.”[22]

Indeed, since HACCP was mandated, the largest processors have sought to sterilize contaminated meat by investing in costly technology like high volume static chamber steam pasteurization systems, an option unavailable to small and medium size operations.

Though Moss never mentions the subject of irradiation – a curious omission, considering Cargill is known to use it [23] — Taylor most certainly has that technology in mind when he refers to the need for public acceptance of technology.  A number of Moss’ New York Times readers even left comments suggesting that the solution to food-borne illness is to irradiate the meat supply.

Other, more knowledgeable readers, however, immediately pointed out some of the known risks irradiation poses to the nutritional value and safety of food.

There are vested interests that want to see the widespread, commercial use of irradiation, no matter the long-known risks and consequences to health.  In 2002, Public Citizen and GRACE, the Global Resource Action Center for the Environment, issued a stunning report entitled “Bad Taste: The Disturbing Truth about the World Health Organization’s Endorsement of Food Irradiation.”  The report asks the question: “How could irradiated foods be declared safe and wholesome if animals fed irradiated foods in experiments dating back 50 years have suffered dozens of health problems, including premature death, mutations and other genetic abnormalities, fetal death and other reproductive problems, immune system disorders, fatal internal bleeding, organ damage, tumors, stunted growth and nutritional deficiencies?” [24]

The report answers this question by reviewing in depth the “scientific” process by which the World Health Organization (WHO) assessed the safety of irradiated food in each of its meetings since 1961.  It found that the WHO had ceded its authority on this issue to the International Atomic Energy Agency (IAEA), which has a vested interest in resuscitating the nuclear industry and legalizing and commercializing the worldwide irradiation of food.  Because of the IAEA’s efforts, the WHO has dismissed, downplayed and misrepresented scientific evidence showing harm.

Irradiation is responsible for forming cyclobutanones, unique chemicals that are not found anywhere naturally.  As explained in the report, “Because irradiation is responsible for forming these chemicals, which are completely distinct from any known food component, they are referred to as ‘unique radiolytic products.’  Subsequent research found cyclobutanones in many common foods after irradiation, including chicken, pork, lamb, salmon, cheese, eggs, peanuts, certain fish and certain fruits.” [25]

The investigation uncovered that “Instead of analyzing whether irradiated foods are safe, wholesome and nutritious, the WHO, IAEA and FAO by the end of the 1980s had shifted almost completely to studying how they could persuade more countries to legalize irradiated food, more corporations to sell it, and more people around the world to eat it.” Attention turned to information control and how to make those responsible for shaping pubic opinion – health authorities, government agriculture, commerce and consumer affairs officials, food industry executives, food retailers, caterers, education broadcast channels and consumers – repeat positive messages about irradiation in order to put the public at ease and even develop friendly feelings about the technology. [26]

Given the WHO’s focus on public relations efforts, it shouldn’t be too surprising then to hear the ubiquitous food poison lawyer Bill Marler spout the same message when he addressed Congress on the subject of food safety.  Marler testified that “the nation requires education about the benefits of irradiation of all mass-produced food including produce.  Resistance to this practice seems to be rooted in public perception, not science.” [27]    Actually, it’s the other way around:  Resistance to the practice is rooted in science, and public perception is being manipulated by vested interested and their useful proxies.

The Center for Food Safety, however, recognizes how irradiation can be used as an economic weapon, describing to us how it contributes to consolidation of the agriculture industry and the globalization of food.

Demonstrating a comprehensive understanding of the issue, The Center for Food Safety explains that “American food processing companies see the use of irradiation as a potential means of boosting profits.  In fact, the motivation for expanding irradiation to additional categories of food may be less about getting rid of disease-causing organisms, and more about increasing market share in international trade.  Irradiation can dramatically increase the shelf life of food. This gives corporations more flexibility in marketing and transportation, making it easier for large companies to move some operations to countries with lower labor costs and lower sanitary and safety standards.  As in many other “outsourced” industries, American workers, farmers and ranchers, could lose their jobs.  In other words, food irradiation supports globalization at its worst, where concerns over long-term health risks carry less weight than the lure of expanded markets. Additionally, since irradiation has become a tool for the globalization of U.S. food production, food irradiation procedures are modeled for large, centralized operations. This furthers the consolidation of “Big Ag” companies and contributes to the destruction of small U.S. family farms — further degrading the security and diversity of our food supply.”[28]

What Does Prevention Really Require?

FDA Commissioner Margaret Hamburg said in her recent statement to the Committee on Health, Education, Labor and Pensions that one of the key questions to ask about the food safety legislation is “Does the legislation refocus the system to place greater emphasis on prevention?”[29]

The answer to her question is no.  The legislation before the Senate does not refocus the system to place greater emphasis on prevention.  If it did, we would be addressing the source of pathogens like E. coli O157:H7 and that issue has been assiduously avoided by Taylor’s legislation.

If we want to take preventive measures, then we must talk honestly about the unwholesome nature of the way we raise livestock animals and the speed and manner with which we dispatch them to their fate.

It’s an astonishing accomplishment to assemble a piece of legislation that purports to prevent the spread of E. coli O157:H7 without ever examining its source.   We can only conclude that it is an act of purposeful neglect.

A lot has been said about pathogens not being visible to the eye, and therefore, it is argued, we need to institute testing protocols to prevent them from entering the food supply.  But what some players would like us to forget is that pathogens are found in feces, and feces are not invisible to the eye (assuming of course, animal carcasses aren’t flying by too fast along the rail).  The other thing some players would like us to forget is that USDA’s FSIS inspectors no longer have the authority to correct problems they see on the line.  Instead, Taylor’s MegaRegs require that they “let the system work,” a proposition that lands too many people in the hospital each year and some in an early grave.

Were Taylor and those supporting the food “safety” legislation truly following a science-based approach to our food-borne illness problems, they would trace the outbreaks back to the practices of confined area feeding operations:  Cattle fed a high grain ration have levels of E. coli O157:H7 100 times higher than cattle allowed a roughage-based diet.[30]

What we feed to animals has a direct impact on their digestive systems and their health.

Cattle normally have a neutral pH level in their digestive system, but when they are fed grain, their systems’ pH level changes, becoming more acidic.  And it is in this acidic environment that E. coli 0157:H7 thrives.

If people eat meat or produce contaminated with normal E. coli, it would most likely be killed by the acidic environment in their digestive system.  However, if people eat meat or produce contaminated with the more virulent strain of E. coli O157:H7, that bacteria actually thrives in our acidic digestive environment, causing systemic sickness and sometimes death.  So, if we want to prevent E. Coli O157:H7 illness, we had best turn our attention to returning cattle to the diet they’re evolved to eat.  Doing so would also improve cattle health, reducing the diet-caused illnesses they experience due to grain consumption, which range from diarrhea, ulcers, liver disease, and a weakened immune system, to feedlot bloat, a life-threatening condition.  Cattle, like people, don’t thrive on the western, industrial diet.

Truth and Consequences

If we allow Taylor to get away with inappropriately applying HACCP to raw foods again –  this time to raw produce — we’ll see, under the pretext of food safety, a less safe food supply, greater market consolidation, and an increased dependence on imported fruits and vegetables.

Furthermore, the local food movement will be crushed by the weight of onerous regulations, costly new testing requirements for CAFO-generated pathogen pollution and business-busting, ineffective HACCP protocols.  While some produce farmers who sell more than half of their crops directly to consumers may be spared these burdens, the remainder will find themselves playing against Big Ag under rules designed for long-distance international trade.  It’s a game they can’t win — by design.

The public will also lose, as the FDA, an industry-captive agency, will be no more aggressive in enforcing safety regulations with the largest fruit and vegetable transnational processing corporations than the USDA has been toward meat and poultry transnational processing corporations.  But small and medium farmers that qualify as facilities will suffer the same fate as small and medium meat and poultry firms.

And while Tom Vilsak, the USDA Secretary of Agriculture, and Kathleen Merrigan, the Deputy Secretary, are busy talking up USDA support of farmers’ markets, even getting their own Face Book page, we should turn our gaze to a disturbing trend from which their song and dance is distracting us: the aggressive and wholesale outsourcing of the nation’s produce supply.

America once fed the world, but now the world is increasingly feeding us, because transnational corporations find it cheaper to import fruits and vegetables than source them domestically.  A government of the people wouldn’t put its food sovereignty and food security at risk in this way, but transnational corporations have no problem engineering such a policy:  It’s good for their investment portfolio.

The local food and sustainable agriculture movements, as well as any one interested in having a safe food supply, need to come to terms with the forces aligned against them before it’s too late.  In Congress the debate may be about making sure food coming from other countries meets “our” safety standards, but that’s deceptive.  In their report to the Agribusiness Accountability Initiative at the Conference on Corporate Power in the Global Food System, the University of Missouri’s William Heffernan and Mary Hendrickson write in “The Global Food System: A Research Agenda” that “Most of the international trade and policy debate still focuses on countries as the major unit of analysis, assuming national governments are the major decision makers even as the dominant agrifood transnational corporations (TNCs) take a larger and larger role in the global food decision-making.  Much of what passes as international decisions in the political realm are nothing more than intra-organizational decisions for TNCs. In an effort to process and distribute their products, agrifood TNCs transfer their products from one location to another, sometimes crossing borders.  These intra-firm transfers become international acts and are called international trade.”[31]

An eye-opening report filed by Food &Water Watch called “The Poisoned Fruit of American Trade Policy: Produce Imports Overwhelm American Farmers and Consumers” provides us with the details: “As U.S. investments in overseas processed fruit and vegetable operations increased over the past decade, the share of imports that are essentially shipments between food company affiliates or subsidiaries increased.  These are the different corporate divisions shipping ingredients or products to one another across national borders.  For example, Del Monte Foods Company, which owns the Del Monte processed produce brand and the Contadina processed tomato brand, operates a food processing plant in Venezuela and two processing plants in Mexico as well as a fruit packing operation in Mexico.” [32]

Food & Water Watch documents that “Between 2000 and 2007, the share of processed fruit and vegetable imports between these subsidiaries grew by more than a fifth, from 28.2 percent of processed produce imports in 2000 to 34.5 percent in 2007.  About half of the processed fruit and vegetable imports from NAFTA partners Mexico and Canada between 2000 and 2007 were from corporate affiliates.  This means that every other can of imported tomato paste or imported package of frozen sweet corn was manufactured at a US-owned factory in Mexico or Canada and shipped to the United States.  These export platforms for the US companies have also emerged under trade deals with China and Chile.  Imports of processed produce from corporate affiliates in China nearly quadrupled from 5.1 percent in 2000 to 20.4 percent in 2007.  The share of inter-corporate processed produce imports from Chile rose 74 percent from 5.8 percent in 2000 to 10.1 percent in 2007.” [32]

These realities are going to exert an unprecedented strain on US farmers of all sizes to compete with products produced more cheaply by the international affiliates of transnational corporations.  It’s essential that the public understand that “When NAFTA and the WTO went into effect in the mid 1990s, the majority of produce imports did enter during the winter.  But now imports that compete with domestic crops enter the U.S. market year round.  In 2006, the USDA reported, “Increasing fruit imports have been rising during the primary U.S. growing seasons.  Trade proponents have often used the example of seasonal fresh grape imports to explain the complementary benefits of produce imports, but now even grapes are actively competing against domestic production during the U.S. harvest season.””[33]

Despite the public demand for locally sourced food, the food safety legislation will create overwhelming obstacles to the local food movement’s efforts to create the necessary supply chain infrastructure.  Regular retail channels, which are tied into the global Big Food complex, will easily win out, leaving consumers with increasingly fewer sources of wholesome, non-industrial food products.

Those who want a safe and wholesome food supply would do well to listen to Joel Salatin, the farmer from Polyface Farm whom Michael Pollen profiled in An Omnivore’s Dilemma.  Testifying to the Domestic Policy Subcommittee on Oversight and Government Reform, Salatin said, “Folks, most of what we know as food regulations are not about safety, they are about denying market access to the local butcher, baker and candlestick maker by making regulatory overheads burdensome enough to eliminate embryonic competition from ever seeing the light of day.  You cannot have a vibrant, community-based food system at the same time you legislate an anti-small, anti-entrepreneurial, overburdensome, capricious food regulatory system.”

The proposed food safety legislation is designed to make the movement of product between international affiliates of transnational corporations a burdenless affair.  Its other achievement will be to overburden, and eventually eliminate, regional- and community-based foodsheds with costly regulations.  But under the inappropriate use of HACCP, the safety of our food supply will not be improved.

It’s high time we demystify the corporate propaganda and reject industry-crafted food safety reform based on fraud.  The next tainted product we recall should be Michael Taylor’s adulterated and misbranded HACCP plan before more bodies are added to the pile.

© 2009 Nicole Johnson


[1] Michael Moss, “E.Coli Path Shows Flaws in Ground Beef Inspection”  The New York Times, October 4, 2009.

[2]  William Sperber, “HACCP Does Not Work From Farm to Table” published by Food Control, Vol. 16, Issue 6, July 2005.

[3]  Jennifer Ross-Nazzal, “From Farm to Fork”: How Space Food Standards Impacted the Food Industry and Changed Food Safety Standards,” Chapter 12 of Societal Impacts of Space, Steven J. Dick and Roger D. Launius, Editors, National Aeronautics and Space Administration, Office of External Relations, History Division, Washington D.C., 2007, pp. 219-236.

[4] “Inside Microbiology: Advancing the Food Safety Agenda”: An Interview with William H. Sperber, Ph.D., Food Safety Magazine

[5] William H. Sperber, “Rethinking and Reinforcing Global Food Protection: Barriers and Goals,” IFT Food Microbiology Division Lecture, June 8, 2009.

[6] William H. Sperber, “Rethinking and Reinforcing Global Food Protection: Barriers and Goals,” IFT Food Microbiology Division Lecture, June 8, 2009.

[7] Felicia Nestor and Patty Lovera, “Hamburger Hell: The Flip Side of USDA’s Salmonella Testing Program”

[8] Nicole Johnson, “History, HACCP and the Food Safety Con Job,” OpEdNews, September 10, 2009.

[9] Samuel S. Epstein, MD, What’s in Your Milk? An Expose of Industry and Government Cover-Up on the Dangers of the Genetically Engineered (rBGH) Milk You’Re Drinking, Trafford Publishing, 2006.

[10] “Shielding the Giant: USDA’s ‘Don’t Look, Don’t Know’ Policy for Beef Inspection,” an investigative report by Tom Levine, Legal Director for the Government Accountability Project.

[11] Ralph Nader, “Small Businessman Whistleblower Risks It All in the Name of Conscience.” Common Dreams, December 22, 2003.

[12] Michael Taylor, “Preparing America’s Food Safety System,” Resources for the Future, Resources, Spring 1997, Issue 127, page 17.

[13] Michael Taylor, “Preparing America’s Food Safety System,” Resources for the Future, Resources, Spring 1997, Issue 127, page 17.

[14] “Federal Meat Inspectors Spread Think as Recalls Rise,” fourth in a series titled Bankrupting Government: How a Decades-Long Campaign against Federal Spending Has Undermined Public Protections.  OMB Watch. March 4, 2008.

[15] “Safety Last: The Politics of E. Coli and Other Food-Borne Killers” by The Center for Public Integrity, 1998, pp., 68-69.

[16] “Safety Last: The Politics of E. Coli and Other Food-Borne Killers” by The Center for Public Integrity, 1998, pp., 68-69.

[17] Stanley Painter, Chairman, National Joint Council of Food Inspection Local Unions, American Federation of Government Employees, AFL-CIO, Before the Domestic Policy Subcommittee of the House Committee on Oversight and Government Reform, Thursday, April 17, 2008.

[18] Stanley Painter, Chairman, National Joint Council of Food Inspection Local Unions, American Federation of Government Employees, AFL-CIO, Before the Domestic Policy Subcommittee of the House Committee on Oversight and Government Reform, Thursday, April 17, 2008.

[19] Jody Warrick, “They Die Piece by Piece.”  The Washington Post, April 10, 2002.

[20] “On the Kill Floor: U.S. Slaughterhouse Conditions” on Making Contact, Transcript #27-01. National Radio Project, July 4, 2001.

[21] “On the Kill Floor: U.S. Slaughterhouse Conditions” on Making Contact, Transcript #27-01. National Radio Project, July 4, 2001.

[22] Michael Taylor, “Preparing America’s Food Safety System,” Resources for the Future, Resources, Spring 1997, Issue 127, page 18.

[23] “Cargill: A Threat to Food and Farming.” A Report from Food & Water Watch, August 2009, p. 6.

[24] “Bad Taste: The Disturbing Truth about the World Health Organization’s Endorsement of Food Irradiation.” A Report from Public Citizen and GRACE, the Global Resource Action Center for the Environment, prepared by Mark Worth, 2002, p. 5.

[25] “Bad Taste: The Disturbing Truth about the World Health Organization’s Endorsement of Food Irradiation.” A Report from Public Citizen and GRACE, the Global Resource Action Center for the Environment, prepared by Mark Worth, 2002, p. 33.

[26] “Bad Taste: The Disturbing Truth about the World Health Organization’s Endorsement of Food Irradiation.” A Report from Public Citizen and GRACE, the Global Resource Action Center for the Environment, prepared by Mark Worth, 2002, p. 26.

[27] Bill Marler, Written Testimony before the Committee on Energy and Commerce.

[28] Center for Food Safety.

[29] Margaret Hamburg, Testimony before the Committee on Health, Education, Labor and Pensions, U.S. Senate: “Keeping American’s Families Safe: Reforming the Food Safety System.” October 22, 2009.

[30] Charles Benbrook, Review of the Published Research on the Sources and Spread of E. coli O157.  The Organic Center, September 2006.

[31] William Heffernan and Mary Hendrickson, “The Global Food System: A Research Agenda.”  Report to the Agribusiness Accountability Initiative, Conference on Corporate Power in the Global Food System, High Leigh Conference Center, Hertfordshire, United Kingdom.

[32] “The Poisoned Fruit of American Trade Policy: Produce Imports Overwhelm American Farmers and Consumers.” A Report from Food & Water Watch, December 2008, p. 6.

[33] “The Poisoned Fruit of American Trade Policy: Produce Imports Overwhelm American Farmers and Consumers.” A Report from Food & Water Watch, December 2008, p. 6.

[34] “The Poisoned Fruit of American Trade Policy: Produce Imports Overwhelm American Farmers and Consumers.” A Report from Food & Water Watch, December 2008, p. 13.

[35] Joel Salatin, “After the Beef Recall: Exploring Greater Transparency in the Meat Industry.”  Testimony before the House Committee on Oversight and Government Reform, April, 17, 2008.

Tags: , , , , , , , , , , , , ,

2 Responses to “The Festering Fraud behind Food Safety Reform”

  1. thomas a. morrow says:

    we do not want poison food
    we do not want regulation of gardens.
    stay out of our gardens..
    stay out of our lives