FOOD SAFETY

More Disclosure and 

Data Needed to

Clarify Impact of 

Changes to Poultry 

and Hog Inspections

Report to the Chairman, Subcommittee 

on Livestock, Dairy, Poultry, Marketing 

and Agriculture Security, Committee on 

Agriculture, Nutrition and Forestry,

U.S. Senate

August 2013

GAO-13-775

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-775, a report to the 

Chairman, Subcommittee on Livestock, Dairy, 

Poultry, Marketing and Agriculture Security, 

Committee on Agriculture, Nutrition and

Forestry, U.S. Senate

August 2013

FOOD SAFETY

More Disclosure and Data Needed to Clarify Impact 

of Changes to Poultry and Hog Inspections

Why GAO Did This Study

USDA inspectors provide continuous 

inspection of each meat and poultry 

carcass and its parts that enter 

interstate commerce. In 1998, USDA 

began three pilot projects at slaughter 

plants for healthy young chickens,

young turkeys, and young hogs, with a 

purpose to deploy inspection resources 

more effectively in accordance with 

food safety and other consumer 

protection requirements. Under the 

pilot projects, plant personnel sort 

carcasses before USDA’s inspection.

The pilot projects are to end when a 

final rule for each species is published. 

In January 2012, USDA published a 

proposed rule to modernize poultry 

slaughter inspections based, in part, on 

its pilot projects. GAO was asked to 

review these pilot projects. This report 

determines (1) the extent to which 

USDA has evaluated the three pilot 

projects, (2) strengths and weaknesses 

of the pilot projects based on the views 

of key stakeholder groups, and (3) the 

extent to which USDA disclosed 

limitations, if any, in sources of 

information it relied on to develop the

proposed rule. GAO reviewed relevant 

laws and documents and interviewed

USDA officials and 11 key industry, 

labor, consumer advocacy, and animal 

welfare groups familiar with the pilot 

projects.

What GAO Recommends

GAO recommends that USDA (1) 

collect and analyze information to 

determine if the young hog pilot project

is meeting its purpose and (2) clearly 

disclose to the public limitations in the 

information it relied on for the proposed 

rule to modernize poultry slaughter 

inspections. USDA concurred with 

GAO’s recommendations.

What GAO Found

The U.S. Department of Agriculture (USDA) has not thoroughly evaluated the 

performance of each of the pilot projects over time even though the agency 

stated it would do so when it announced the pilot projects. For example, in 2011,

USDA completed a report evaluating the pilot project at 20 young chicken plants

concluding that an inspection system based on the pilot project would ensure 

equivalent, if not better, levels of food safety and quality than currently provided 

at plants not in the pilot project. However, among the limitations of its evaluation

was the use of snapshots of data for two 2-year periods instead of data for the 

duration of the pilot project, which has been ongoing for more than a decade. In 

addition, USDA did not complete an evaluation on or prepare a report evaluating 

the pilot project at 5 young turkey plants and has no plans to do so because of 

the small sample size. Nevertheless, in publishing a proposed rule that includes 

an optional new poultry (chicken and turkey) inspection system, USDA stated 

that the new system was based on its experience with the pilot projects at young 

chicken and young turkey plants. As a result, USDA may not have assurance 

that its evaluation of the pilot project at young chicken plants provides the 

information necessary to support the proposed rule for both chickens and 

turkeys. However, the agency will not complete another evaluation before it 

issues a final rule. USDA has begun drafting a preliminary report evaluating the 

pilot project at young hog plants using analyses similar to those presented in the 

report evaluating young chicken plants, suggesting that similar limitations may 

apply. Agency officials stated that when USDA develops a proposed rulemaking 

to modify its slaughter inspection system for hogs, the agency will need to decide 

whether to collect additional data. Without collecting and analyzing additional 

data, it will be difficult for USDA to draw conclusions about whether the pilot 

project at young hog plants is meeting its purpose. While the pilot project is 

ongoing, USDA has the opportunity to collect and analyze additional information.

GAO identified strengths and weaknesses of the three pilot projects based on the 

views cited most frequently by 11 key stakeholder groups representing industry, 

labor, consumer advocacy, and animal welfare. On the basis of these views, 

GAO identified strengths including giving plants responsibility and flexibility for 

ensuring food safety and quality and allowing USDA inspectors to focus more on

food safety activities. GAO identified weaknesses including that training of plant 

personnel assuming sorting responsibilities on the slaughter line is not required 

or standardized and that faster line speeds allowed under the pilot projects raise 

concerns about food safety and worker safety.

USDA did not disclose certain limitations in sources of information it relied on to 

develop the cost-benefit analysis supporting the proposed rule on modernizing 

poultry slaughter inspections. GAO identified three sources of information with 

certain limitations that were not disclosed. For example, USDA did not disclose 

that it gathered no cost information from young turkey plants in the pilot project.

Furthermore, USDA generalized the results from 12 young chicken plants in the 

pilot project that responded to a 2001 cost survey to the universe of 335 young 

chicken and young turkey plants in the United States in 2012. As a result, 

stakeholders did not have complete and accurate information to inform their 

comments on the proposed rule and its potential impacts.

View GAO-13-775. For more information, 

contact J. Alfredo Gómez at (202) 512-3841 or 

gomezj@gao.gov.
Page i GAO-13-775 USDA Inspection Pilot Projects

Letter 1

Background 5

FSIS Has Not Thoroughly Evaluated the Three Pilot Projects 10

Views of Key Stakeholder Groups on Strengths and Weaknesses in 

the Pilot Projects 18

FSIS Did Not Disclose Certain Limitations in the Cost-Benefit 

Analysis It Developed to Support the Proposed Rule 23

Conclusions 27

Recommendations for Executive Action 28

Agency Comments and Our Evaluation 28

Appendix I Objectives, Scope, and Methodology 30

Appendix II Additional Information on the Young Chicken, Young Turkey, 

and Young Hog Plants in the Pilot Projects 33

Appendix III Comments from the U.S. Department of Agriculture 39

GAO Comments 44

Appendix IV GAO Contact and Staff Acknowledgments 46

Figures

Figure 1: Total Number of Samples Collected at the 20 Young 

Chicken Plants in the Pilot Project and the Similar Group 

of 64 Young Chicken Plants Not in the Pilot Project, 2006-

2010 12

Figure 2: Location of Young Chicken Plants in the Pilot Project and 

the Volume of Young Chickens Slaughtered, by State, in 

2012 34

Figure 3: Location of Young Turkey Plants in the Pilot Project and 

the Volume of Young Turkeys Slaughtered, by State, in 

2012 36

Figure 4: Location of Young Hog Plants in the Pilot Project and the 

Volume of Hogs Slaughtered, by State, in 2012 38

Contents
Page ii GAO-13-775 USDA Inspection Pilot Projects

Abbreviations

CDC Centers for Disease Control and Prevention 

FSIS Food Safety and Inspection Service

HACCP Hazard Analysis and Critical Control Point

HIMP HACCP-based Inspection Models Project

OMB Office of Management and Budget

USDA U.S. Department of Agriculture 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-13-775 USDA Inspection Pilot Projects

441 G St. N.W.

Washington, DC 20548

August 22, 2013

The Honorable Kirsten E. Gillibrand

Chairman

Subcommittee on Livestock, Dairy, Poultry, Marketing and Agriculture 

Security

Committee on Agriculture, Nutrition and Forestry

United States Senate

Dear Madam Chairman:

According to the Centers for Disease Control and Prevention (CDC), the 

U.S. food supply remains one of the safest in the world; nevertheless, 

CDC estimates that each year about 48 million Americans become sick 

from foodborne diseases. Meat and poultry products contaminated with 

pathogens such as Salmonella, Toxoplasma gondii, Campylobacter, and 

Lysteria monocytogenes cause many foodborne illnesses and deaths. To 

control the spread of such foodborne illnesses, over 3,700 U.S. 

Department of Agriculture (USDA) veterinarians and inspectors work at 

more than 900 slaughter plants. USDA inspectors provide continuous 

inspection of each meat and poultry carcass and its parts that enter 

interstate commerce. USDA inspectors positioned on slaughter lines in 

these plants are responsible for sorting carcasses to identify defects and 

directing plant personnel to remove unacceptable carcasses, among 

other things.1

 1

In slaughter plants that have received USDA approval to be inspected by USDA and 

thereby produce meat and poultry products to ship in interstate commerce (referred to as 

receiving a grant of inspection), there is a slaughter production line made up of multiple 

operations, beginning with the arrival of the animal in the receiving yard to the point where 

carcasses are chilled before they are further processed. In this report, we use the term 

“slaughter line” to refer to the entire slaughter production line that includes these multiple 

operations.

There may be multiple USDA inspectors positioned on each 

slaughter line, depending on the speed at which meat and poultry 

carcasses move down the line. For example, at plants that slaughter 

young chickens, there may be up to four inspectors on each line, and 

each inspector is responsible for inspecting up to 35 carcasses per 

minute. In addition, USDA inspectors positioned off the slaughter line 

move freely about the plant and collect samples of carcasses to test for 

microbial pathogens (e.g., Salmonella); perform food safety checks, such 

as verifying that carcasses are free of fecal material; and ensure that 
Page 2 GAO-13-775 USDA Inspection Pilot Projects

carcasses comply with the agency’s food quality standards for things 

such as bruises on chickens, which does not affect food safety.

In 1997, USDA announced the need to modify its meat and poultry 

slaughter inspection program to, among other things, make industry more 

responsible for identifying carcass defects. In 1998, USDA began three 

pilot projects—one for each species—at slaughter plants to test changes 

to its inspection systems from having its inspectors provide continuous 

inspection of each and every carcass for healthy young chickens, young 

turkeys, and young hogs to a system that uses plant personnel to 

examine each carcass for safety and quality and USDA inspectors to 

verify that safety and quality standards are met.2 According to a Federal 

Register notice announcing the pilot projects, the purpose was to deploy 

inspection resources more effectively in accordance with food safety and 

other consumer protection requirements.3

 2

USDA refers to young hogs as market hogs.

In announcing the pilot 

projects, USDA stated that the agency would thoroughly evaluate the pilot 

projects and, at the time of its evaluation, determine whether further 

testing should be conducted or whether to initiate rulemakings to adopt 

and implement new inspection systems based on the pilot projects. As of 

July 2013, 29 plants were participating in the pilot projects—19 plants for 

slaughtering young chickens, 5 for young turkeys, and 5 for young hogs. 

At participating plants under the pilot projects, plant personnel have taken 

on the sorting responsibilities of USDA inspectors positioned on the 

slaughter line for identifying carcass defects and removing unacceptable 

carcasses. However, a USDA inspector remains at the end of each 

slaughter line at each young chicken and young turkey plant and at three 

fixed locations on the slaughter line at each young hog plant to conduct a 

carcass-by-carcass inspection after plant personnel have completed 

sorting activities so that only those carcasses deemed likely to pass 

3

62 Fed. Reg. 31553 (June 10, 1997). Other consumer protection requirements include 

activities related to nonfood safety concerns, such as the wholesomeness and food quality 

of meat and poultry products. According to this Federal Register notice, USDA intended to 

test these changes at slaughter plants for young chickens, market hogs, and cattle. USDA 

extended the pilot projects to slaughter plants for young turkeys at the request of the 

turkey industry. According to USDA documents, no slaughter plants for young cattle have 

volunteered for the pilot project. Plants that slaughter young animals were selected 

because most food animals are slaughtered at a young age and because young animals 

are generally free of diseases that are more common in older animals.
Page 3 GAO-13-775 USDA Inspection Pilot Projects

inspection remain on the line.4

In December 2001, we reported on the design and methodology of 

USDA’s pilot projects and noted several limitations that do not allow 

results from plants participating in USDA’s pilot projects to be generalized 

to the universe of plants.

According to a Federal Register notice, 

removing USDA inspectors from slaughter lines is intended to free the 

inspectors to perform additional food safety and quality checks in the 

areas of greatest risk, as needed, throughout the plant.

5

In January 2012, USDA published in the Federal Register a proposed rule 

to modernize poultry slaughter inspections that affects all plants that 

slaughter poultry (chickens and turkeys) and that includes an optional 

new inspection system for all young chicken and turkey plants, which 

resembles some aspects of the inspection systems used in the pilot 

projects at young chicken and young turkey plants.

For example, we reported that plants 

participating in the young chicken pilot project were not randomly selected 

and that they did not include plants from all chicken producing areas or 

plants of all sizes. Thus, the results cannot be generalized to the entire 

population of chicken slaughter plants in the United States.

6

 4

USDA’s original design for the pilot projects involved assigning inspectors to the 

slaughter line, but not at fixed points; instead these inspectors positioned off the line (i.e., 

not at a specific point on the line) could move freely to observe different parts of the line. 

However, in 1998, the union representing USDA inspectors filed a lawsuit claiming that, 

under the pilot projects, USDA inspectors were not complying with the applicable laws and 

personally inspecting each carcass. Consequently, in 2000, USDA modified the design of 

the pilot projects to include at least one USDA inspector positioned at a fixed point on the 

slaughter line to perform a carcass-by-carcass inspection. The court concluded that, with 

this modification, the pilot projects did not violate the applicable laws.

During the public 

comment phase of the proposed rule for modernizing poultry slaughter 

inspections, USDA received more than 175,000 comments from 

stakeholders, including industry and consumer advocacy groups, as well 

as individual members of the public. As of July 2013, USDA was working 

to complete its final rule for modernizing poultry slaughter inspections, 

according to agency officials.

5

GAO, Food Safety: Weaknesses in Meat and Poultry Inspection Pilot Should Be 

Addressed before Implementation, GAO-02-59 (Washington, D.C.: Dec. 17, 2001).

6

77 Fed. Reg. 4408 (Jan. 27, 2012).
Page 4 GAO-13-775 USDA Inspection Pilot Projects

This report responds to your request that we review USDA’s pilot projects 

at slaughter plants for young chickens, young turkeys, and young hogs. 

Our objectives were to determine (1) the extent to which USDA has 

evaluated the three pilot projects, (2) strengths and weaknesses of the 

three pilot projects based on the views of key stakeholder groups, and (3) 

the extent to which USDA disclosed limitations, if any, in sources of 

information it relied on to develop the proposed rule to modernize poultry 

slaughter inspections.

To determine the extent to which USDA has evaluated the three pilot 

projects, we reviewed relevant USDA documents, Federal Register

notices, and laws. We also compared USDA’s efforts to evaluate the pilot 

projects with criteria based on social science and evaluation literature and 

published GAO guidance identified in our previous work on pilot program 

development and evaluation.7 In addition, we interviewed several officials 

in various offices within USDA’s Food Safety and Inspection Service 

(FSIS)—the agency responsible for USDA’s meat and poultry inspection 

program. To determine the strengths and weaknesses of the three pilot 

projects based on the views of key stakeholder groups, we identified 11 

key stakeholder groups representing industry, labor (including plant 

personnel and USDA inspectors and veterinarians), consumer advocacy, 

and animal welfare with sufficient knowledge about USDA’s three pilot 

projects that submitted comments on USDA’s proposed rule on 

modernizing poultry slaughter inspections.8

 7

GAO, Catastrophic Planning: States Participating in FEMA’s Pilot Program Made 

Progress, but Better Guidance Could Enhance Future Pilot Programs, 

We reviewed their comments 

to determine the extent to which the comments may apply to the pilot 

GAO-11-383

(Washington, D.C.: Apr. 8, 2011); GAO, Tax Administration: IRS Needs to Strengthen Its 

Approach for Evaluating the SRFMI Data-Sharing Pilot Program, GAO-09-45

(Washington, D.C.: Nov. 7, 2008); and GAO, Equal Employment Opportunity: DOD’s EEO 

Pilot Program Under Way, but Improvements Needed to DOD’s Evaluation Plan, 

GAO-06-538 (Washington, D.C.: May 5, 2006).

8

We developed an initial list of key stakeholder groups based on our prior experience and 

knowledge. To ensure that we included all of the relevant stakeholder groups, we asked 

these groups for suggestions on other stakeholders we should consider contacting and 

expanded the list, as needed. The 11 stakeholder groups were the American Federation 

of Government Employees/National Joint Council of Food Inspection Locals, the American 

Meat Institute, the Center for Foodborne Illness Research and Prevention, the Consumer 

Federation of America, Food and Water Watch, the Government Accountability Project, 

the Humane Society of the United States, the National Association of Federal 

Veterinarians, the National Chicken Council, the National Turkey Federation, and the 

North American Meat Association.
Page 5 GAO-13-775 USDA Inspection Pilot Projects

projects; interviewed representatives of these key stakeholder groups; 

and followed up with e-mailed questions to gauge their level of familiarity 

with each pilot project and then clarified responses, as needed. We 

developed categories of strengths and weaknesses identified most 

frequently by stakeholder groups and determined whether each 

stakeholder group had identified strengths or weaknesses that fit into 

these categories. To determine the extent to which USDA disclosed 

limitations, if any, in sources of information it relied on to develop the 

proposed rule, we reviewed the proposed rule and related Federal 

Register notices, as well as selected documents the agency relied on to

develop the proposed rule. We also interviewed several officials in 

various offices within USDA’s FSIS to clarify information, as needed. 

Appendix I provides more information on our objectives, scope, and 

methodology.

We conducted this performance audit from September 2012 to August 

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence presented provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

The Federal Meat Inspection Act and the Poultry Products Inspection Act 

give USDA overall responsibility for ensuring the safety and 

wholesomeness of meat and poultry products that enter interstate 

commerce.9

 9

21 U.S.C. §§ 601-683 and 21 U.S.C. 451-472. The Federal Meat Inspection Act was 

originally enacted in 1907 as part of the USDA appropriations act, and the Poultry 

Products Inspection Act was enacted in 1957. Both pieces of legislation have been 

amended a number of time throughout the years.

Acting under these legislative authorities, USDA inspectors 

provide continuous government inspection of each and every meat and 

poultry carcass and its parts at slaughter plants throughout the United 

States. Within USDA, FSIS is responsible for inspections at all meat and 

poultry slaughter and processing plants and has inspectors positioned 

both on and off the slaughter line. FSIS inspectors positioned on the line 

are to inspect every carcass and its parts, including the viscera (e.g., 

hearts and liver) organoleptically—by sight, touch, and smell—for defects, 

and direct plant personnel to take appropriate corrective action when 

Background
Page 6 GAO-13-775 USDA Inspection Pilot Projects

defects are found. According to a Federal Register notice, plants rely on 

FSIS inspectors to control and direct their production processes. For 

example, FSIS regulates the speed of the slaughter line based on its 

inspectors’ ability to perform proper inspection procedures. FSIS 

inspectors positioned off the line move freely about the plant to focus on 

areas of greatest risk and to perform collection of carcass samples for 

testing of microbial pathogens. Among other activities, these inspectors 

review plant records and live animals presented for slaughter. These

inspectors are also responsible for ensuring plants’ compliance with 

regulatory requirements on a daily basis and for taking regulatory 

enforcement action when deficiencies are found.

In 1997, FSIS announced the need to modify its meat and poultry 

slaughter inspection program to, among other things, make industry more 

responsible for identifying carcass defects. This approach is consistent 

with the agency’s previous adoption of the Pathogen Reduction: Hazard 

Analysis and Critical Control Point (HACCP) regulations. Under the riskbased HACCP approach, industry—rather than federal inspectors—is 

responsible for identifying steps in food production where food safety 

hazards, such as fecal material, are reasonably likely to occur and for 

establishing controls that prevent or reduce these hazards. As part of this 

approach, plants must identify the point (known as the critical control 

point) where they will establish control for a food safety hazard and take 

steps to prevent, eliminate, or control the hazard. FSIS had not extended 

the HACCP principles to slaughter inspections because the agency 

provides continuous inspection of each and every carcass. However, 

FSIS believed that changing its existing inspection systems would also 

reduce inspectors’ reliance on organoleptic inspections, allow for a shift to 

prevention-oriented inspection systems based on risk, and permit 

redeployment of its resources to better protect the public from foodborne 

diseases. Before making a permanent change to its slaughter inspection 

systems, FSIS developed the pilot projects in 1998 at young chicken, 

young turkey, and young hog plants to test whether such a change would 

achieve its intended purpose of deploying inspection resources more 

effectively in accordance with food safety and other consumer protection 

requirements. FSIS’ pilot projects at these plants are known as the 

HACCP-based Inspection Models Project (HIMP).
Page 7 GAO-13-775 USDA Inspection Pilot Projects

FSIS developed food safety and quality performance standards for plants 

in the pilot projects to meet.10 FSIS set the performance standard for food 

safety defects at zero.

11

In May 1999, FSIS negotiated an agreement with the union representing 

its inspectors that limited the number of plants participating in the pilot 

projects to 20 young chicken plants, 5 young turkey plants, and 5 young 

hog plants. According to the agreement, the pilot projects for each 

species are to end when a final rule is published for that species. Before 

converting to the inspection systems under the pilot projects, participating 

plants modified their operations to meet certain requirements, such as 

installing a new workstation at the end of the slaughter line and before the 

chiller for the FSIS inspector positioned on the slaughter line at poultry 

plants.

An example of a food safety defect is a carcass 

contaminated with fecal material because ingestion of meat and poultry 

contaminated with fecal material poses potential harm to humans. FSIS’ 

performance standards for food quality defects vary, depending on the 

animal species and the type of defects. An example of a food quality 

defect is bruises on the carcass that, while not harmful if consumed, 

affects the wholesomeness of meat and poultry products. According to 

FSIS officials, the food quality performance standards are intended to be 

more stringent than the performance standards in place at plants that are 

not participating in the pilot projects.

12

In 2006, FSIS announced a voluntary initiative—known as the Salmonella 

Initiative Program—to make improvements to control for Salmonella at 

Over the course of the pilot projects, some plants have dropped 

out, and others have joined. As of July 2013, 29 plants were participating 

in the pilot projects in 18 states. Appendix II provides additional 

information on the location of plants in the pilot projects and the volume of 

poultry and hog slaughter in the United States.

 10FSIS took a statistically based number of samples to develop these performance 

standards. In 2002, an external review concluded that the agency’s approach for 

comparing food safety and quality data to assess the performance of chicken plants in the 

pilot project against the performance standards was valid.

11The agency has a performance standard of zero for food safety defects (i.e., 

septicemia/toxemia and visible fecal material) in plants participating and not participating 

in the pilot projects. 

12The chiller is the point when eviscerated carcasses—carcasses that have had internal 

organs and any processing defects removed—are chilled in order to inhibit microbial 

growth and meet the regulatory requirements of 9 C.F.R. § 381.66(b)(1).
Page 8 GAO-13-775 USDA Inspection Pilot Projects

young chicken and turkey plants. Plants participating in FSIS’ pilot 

projects are required to participate in this program. The Salmonella 

Initiative Program permits plants to operate with an exemption (known as 

a waiver) from complying with certain regulatory requirements. For 

example, young chicken plants in the pilot project are exempt from 

meeting FSIS’ regulatory requirement that limits the slaughter line speed 

at young chicken plants and can operate the slaughter line at a faster line 

speed. Plants in the Salmonella Initiative Program must demonstrate to 

FSIS that results from their Salmonella testing consistently demonstrate 

that they maintain control over production processes. The goal of the 

Salmonella Initiative Program is to reduce and eliminate Salmonella

before products reach consumers.

In January 2012, FSIS published in the Federal Register a proposed rule 

to modernize poultry slaughter inspections based, in part, on the agency’s 

experience with the pilot projects at young chicken and young turkey 

plants. FSIS developed the proposed rule in response to an executive 

order directing agencies to review existing regulations that may have 

been outdated and modify them accordingly.13

 13As part of Executive Order 13563, federal agencies were asked to review existing rules 

that may be outmoded, ineffective, insufficient, or excessively burdensome and to modify, 

streamline, expand, or repeal them accordingly.

According to the proposed 

rule, the modernization is intended to improve food safety and the 

effectiveness of poultry slaughter inspection systems, remove 

unnecessary regulatory obstacles to innovation, and make better use of 

the agency’s resources. The proposed rule further states that inspection 

systems currently in place at chicken and turkey plants (not in the pilot 

projects) are lacking in two important respects. First, the proper role of 

industry and FSIS is obscured. Specifically, FSIS inspectors are currently 

responsible for sorting acceptable carcasses from unacceptable 

carcasses, finding defects, identifying corrective actions, and solving 

problems in production control processes, but these are roles more 

appropriately the responsibility of the slaughter plants. Second, a 

significant amount of FSIS’ inspection program personnel resources are 

allocated toward inspection activities to detect defects and conditions that 

present minimal food safety risks. According to the proposed rule, this 

allocation limits the agency resources available for food safety-related 

inspection activities. Moreover, FSIS developed an economic cost and 

benefit analysis to demonstrate the merits of the proposed rule, which, 
Page 9 GAO-13-775 USDA Inspection Pilot Projects

according to USDA, is expected to have an annual impact on the 

economy of more than $100 million.

FSIS’ proposed rule affects all poultry slaughter plants and includes 

mandatory regulatory changes. For example, the proposed rule requires 

all poultry plants to maintain written procedures to prevent contamination 

of carcasses and parts by fecal material and pathogens (e.g., Salmonella

and Campylobacter) and to test for organisms (e.g., Salmonella) to 

demonstrate control over their production processes at a point before the 

carcass enters the chiller and at a point after the carcass exits the chiller. 

In addition, the proposed rule includes the optional new poultry inspection 

system for young chicken and turkey plants.14

• For each slaughter line, there would be one FSIS inspector positioned 

at the end of the line to perform a carcass-by-carcass inspection and 

one FSIS inspector positioned off the line to perform, among other 

things, food safety and quality checks on carcasses to verify that plant 

personnel (known as sorters) have effectively performed their duties, 

such as removing fecal material on carcasses.

According to the proposed 

rule, FSIS expects that the majority of young chicken and turkey plants 

will convert to the optional new poultry inspection system. The new 

poultry inspection system resembles the inspection systems at young 

chicken and young turkey plants in the pilot projects but also has some 

differences. Similarities between the pilot projects and optional new 

poultry inspection system include, among others:

• The FSIS inspector positioned on the slaughter line would visually 

inspect (observe) each carcass after the viscera are separated from it 

and after plant personnel have sorted carcasses, at a point near the 

end of the slaughter line.

A difference between the pilot projects and the optional new poultry 

inspection system is that the new system would eliminate FSIS’ 

performance standards for food quality defects and replace them with a 

requirement that plants maintain records documenting that their products 

meet the regulatory definition of “ready-to-cook.” Ready-to-cook means 

that the products are free of such defects as feathers, oil glands, and 

 14The proposed rule will also include updates to the traditional inspection system typically 

in place at smaller, lower volume producing plants that eviscerate carcasses by hand. 

According to the proposed rule, a plant can choose to operate under the optional new 

poultry inspection system or the updated traditional inspection system.
Page 10 GAO-13-775 USDA Inspection Pilot Projects

diseases and are thus suitable for cooking without any further 

preparation. According to FSIS officials, plants could use the existing food 

quality standards—known as Finished Product Standards—to meet the 

regulatory definition of ready-to-cook.

FSIS has not thoroughly evaluated the performance of each of the three 

pilot projects over time even though the agency stated that it would do so 

when it announced the pilot projects. Specifically, FSIS completed a 

report evaluating the pilot project at young chicken plants, but its data 

analyses have limitations. FSIS did not prepare a report evaluating the 

pilot project at young turkey plants and has no plans to do so because 

data from the five young turkey plants in the pilot project provide limited 

information due to the small sample size. While FSIS has begun drafting 

a preliminary report evaluating the pilot project at young hog plants, it 

used analyses similar to those presented in the report evaluating the pilot 

project at young chicken plants, suggesting similar limitations may apply.

In 2011, FSIS completed a report evaluating the pilot project at young 

chicken plants;15 according to agency officials, the agency’s evaluation 

efforts focused on this pilot project, in part, because it has the largest 

number of plants participating. FSIS’ evaluation compared the 

performance of the 20 young chicken plants in the pilot project (1) with a 

similar group of 64 plants not participating in the pilot project,16

 15USDA, Food Safety and Inspection Service, Evaluation of HACCP Inspection Models 

Project (HIMP), August 2011. FSIS’ evaluation included 20 young chicken plants 

participating in the pilot project; however, one plant dropped out of the pilot project in 2011 

and closed its operations after the evaluation had been completed.

using 

routinely collected data, and (2) against the performance standards 

developed for the pilot project using data collected specifically for the pilot 

project. FSIS’ evaluation concludes that an inspection system based on 

the pilot project would ensure equivalent, if not better, levels of food 

safety and quality than currently provided at plants not in the pilot project. 

FSIS used this evaluation to support its January 2012 proposed rule 

modernizing poultry slaughter inspections that includes the optional new 

poultry inspection system.

16For the similar group of plants, FSIS selected plants that had similar slaughter volumes 

and line speeds and that were located in similar geographic areas in the United States.

FSIS Has Not 

Thoroughly 

Evaluated the 

Three Pilot Projects

FSIS Has Completed a 

Report Evaluating Some 

Data from the Chicken 

Pilot Project, but Its Data 

Analyses Have Limitations
Page 11 GAO-13-775 USDA Inspection Pilot Projects

We identified two limitations of FSIS’ evaluation that raise questions 

about the validity of FSIS’ conclusion that an inspection system based on 

the pilot project would ensure equivalent, if not better, levels of food 

safety and quality than currently provided at plants not in the pilot project. 

First, FSIS’ conclusion about the pilot project was based, in part, on 

comparisons of data that were not designed to be comparable. For 

example, FSIS concluded that the prevalence of Salmonella at the 20 

plants participating in the pilot project was significantly lower than in the 

similar group of 64 plants that were not participating in the pilot project 

from 2006 to 2008. However, it based its conclusion on data that were 

collected as a part of its microbial sampling program, rather than 

collecting samples from the same plants for each year. The total number 

of samples collected in each year declined from one year to the next—

indicating that the total number of plants from which samples was 

collected varied from year to year (see fig. 1).17

 17FSIS’ performance standards call for a series of samples be collected over 51 

consecutive days at each plant selected to be part of the annual sampling schedule. 

Plants included in the annual schedule are selected on risk-based criteria designed to 

focus FSIS resources on plants with the most samples positive for Salmonella.

FSIS officials confirmed 

that the total number of plants from which samples were collected varied 

from year to year, and these officials were unable to tell us how many 

plants were included in each year of the analysis. In addition, the 

possibility that lower prevalence of Salmonella was caused by something 

other than the pilot project cannot be ruled out.
Page 12 GAO-13-775 USDA Inspection Pilot Projects

Figure 1: Total Number of Samples Collected at the 20 Young Chicken Plants in the 

Pilot Project and the Similar Group of 64 Young Chicken Plants Not in the Pilot 

Project, 2006-2010

Moreover, data from the last 2 years analyzed did not show a significantly 

lower prevalence of Salmonella for plants participating in the pilot project. 

According to FSIS officials, FSIS did not collect data to demonstrate the 

relative effectiveness of plants participating and not participating in any of 

the pilot projects. Instead, the agency analyzed data for a variety of 

inspection activities performed in all plants (regardless of a plant’s 

inspection system) to ensure their compliance with regulatory 

requirements.

The second limitation that we identified in FSIS’ evaluation is that the 

agency collected more than a decade’s worth of data on the extent to 

which young chicken plants in the pilot project were meeting the food 

safety and quality performance standards developed for the pilot project, 

but it based its conclusion about the performance of the pilot project on 

the use of snapshots of data from the pilot project for two 2-year periods. 

Moreover, the time frames for the snapshots differed depending on 

whether the categories related to food safety or food quality defects. More 
Page 13 GAO-13-775 USDA Inspection Pilot Projects

specifically, the agency included snapshots of food safety data from 2000 

to 2002—when the project first began—and food safety data from April 

2009 to March 2011, and snapshots of food quality data from 2000 to 

2002 with food quality data from 2009 to 2010—the most recent data 

available at that time. Consequently, the results from the years that FSIS 

selected for analysis may not be indicative of plants’ performance over 

time. According to FSIS officials, the agency did not analyze the data for 

the majority of the years because the data were recorded on paper forms 

stored at individual plants and compiling the data for analysis was labor 

intensive.18 According to the Standards for Internal Control in the Federal 

Government,

19

Notwithstanding these limitations, FSIS used its evaluation of the pilot 

project at young chicken plants to support the proposed rule on 

modernizing poultry slaughter inspections. Moreover, the design and 

methodology limitations we identified in our 2001 report (e.g., young 

chicken plants participating in the pilot project constituted a small, 

federal agencies are to employ internal control activities, 

such as top-level review, to help ensure that management’s directives are 

carried out and to determine if agencies are effectively and efficiently 

using resources. Without analyzing data for the majority of the years of 

the pilot project in its evaluation, FSIS could not determine whether an 

inspection system based on the pilot project would ensure equivalent, if 

not better, levels of food safety and quality than currently provided at 

plants not in the pilot project over time. In addition, according to the 

Federal Register notice announcing the pilot projects, FSIS stated that 

the agency would thoroughly evaluate them; however, using snapshots of

data rather than data for the majority of the years of the pilot project, the 

agency did not conduct a thorough evaluation. Instead, FSIS 

veterinarians and inspectors evaluated the performance of their individual 

plants against regulatory performance standards on a daily basis, as they 

routinely do for all plants regardless of whether they are in the pilot 

project or not, as well as the performance standards for the pilot project. 

However, the agency has not aggregated and analyzed these daily 

results to determine how the plants participating in the pilot project have 

performed over time.

 18FSIS has been collecting similar data in a similar format at the young turkey and young 

hog plants participating in the pilot projects.

19GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 

(Washington, D.C.: Nov. 1999).
Page 14 GAO-13-775 USDA Inspection Pilot Projects

nonrandom sample) continue to prevent the results obtained from the 20 

participating young chicken plants from being generalized to the 239 

young chicken plants and 96 young turkey plants in the United States in 

2012. As a result, FSIS may not have assurance that its evaluation of the 

pilot project at young chicken plants provides the information necessary 

to support the proposed rule for poultry—both chickens and turkeys. 

However, according to the Federal Register notice supporting the 

proposed rule on modernizing poultry slaughter inspections, the agency 

conducted a comprehensive evaluation; thus, the agency will not 

complete another evaluation before it issues a final rule.

Unlike what FSIS did for the pilot project at young chicken plants, it did 

not complete an evaluation on or prepare a report evaluating the pilot 

project at young turkey plants. In publishing the proposed rule 

modernizing poultry slaughter inspections that included an optional new 

poultry inspection system, the agency stated that the new system was 

based on its experience with the pilot projects at young chicken and 

young turkey plants. According to FSIS officials, the agency did not 

prepare a report evaluating the pilot project at young turkey plants and 

has no plans to do so because data from five young turkey plants in the 

pilot project provide limited information due to the small sample size.

Instead, as part of a quantitative microbial risk assessment to estimate 

the public health impact of the proposed rule, the agency analyzed the 

relationship between the presence or absence of pathogens and the 

frequency with which FSIS inspectors positioned off the slaughter line 

carried out specific inspection activities at young turkey plants.

20

In addition, FSIS officials stated that, for the optional new poultry 

inspection system, they generalized information and data from young 

chicken plants in the pilot project to the young turkey plants in the pilot 

project because the processes to slaughter chickens and turkeys are 

According to FSIS’ analysis, there is a suggested relationship between 

young turkey plants’ participation in the pilot project and a lower 

prevalence of Salmonella and Campylobacter. 

 20USDA/FSIS, FSIS Risk Assessment for Guiding Public Health-Based Poultry Slaughter 

Inspection, Updated November 2011. In this assessment, FSIS evaluated inspection data 

and Salmonella and Campylobacter data from young turkey slaughter plants as a part of 

its peer reviewed risk assessment.

FSIS Did Not Prepare a 

Report Evaluating the 

Turkey Pilot Project
Page 15 GAO-13-775 USDA Inspection Pilot Projects

similar. However, we identified differences in the food quality performance 

standards and FSIS’ testing protocol for pathogens. FSIS acknowledged 

that the food quality performance standards are not the same. We 

determined that the five food quality performance standards developed 

for the young chicken and for the young turkey pilot project can differ by 

0.5 percent to almost 16 percent. For example, the performance standard 

for the food quality defect category that includes animal diseases (such 

as arthritis) is 1.7 percent for young chickens and 1.2 percent for young 

turkeys—a difference of 0.5 percent. In another example, the 

performance standard for the food quality defect that includes other 

defects such as feathers is 80.0 percent for young chickens and 95.9 

percent for young turkeys—a difference of 15.9 percent. 

Furthermore, FSIS’ protocols differ for testing chicken and turkey 

carcasses for Salmonella and Campylobacter. For example, for chickens, 

FSIS inspectors rinse an entire chicken carcass in a bag filled with a 

sterile water solution that is poured off and tested for these pathogens. In 

contrast, for turkeys, FSIS inspectors use a sponge—containing the same 

sterile water solution as that used to rinse chicken carcasses—to swab 

certain areas of the turkey carcass and then test the sponge for 

pathogens. According to a March 2011 Federal Register notice,21 FSIS 

acknowledged that the method used to sample carcasses affects the 

results and stated that they are not proposing to compare microbial data 

from these two species. However, even with these differences in 

sampling protocols, FSIS officials stated that the results for young 

chickens could be generalized to young turkeys. These differences raise 

questions about the extent to which FSIS can generalize results for food 

quality defects and microbial testing results from one species to the other, 

but, as we previously mentioned, the agency has no plans to do an 

evaluation of the pilot project at young turkey plants before it issues a 

final rule.

In 2011, FSIS began drafting a preliminary report evaluating the pilot 

project at young hog plants. The preliminary report uses analyses similar 

to those presented in the report evaluating the pilot project at young 

chicken plants, suggesting that similar limitations may apply. In particular, 

FSIS did not collect comparable data from plants participating and not 

 2176 Fed. Reg. 15,282 (Mar. 21, 2011).

FSIS Has Not Completed 

Its Report Evaluating the 

Hog Pilot Project
Page 16 GAO-13-775 USDA Inspection Pilot Projects

participating in the pilot project. In addition, like the turkey pilot project, 

information collected from the five young hog plants in the pilot project 

would not provide reasonable assurance that any conclusions can apply 

more broadly to the universe of 608 hog plants in the United States in 

2012 because of the small sample size. FSIS officials agreed that there 

would be concerns regarding the strength of any conclusions based on 

five plants. These officials stated that, when the agency develops a 

proposed rulemaking to modify its slaughter inspection system for hogs, it 

will need to decide whether to collect additional data. Furthermore, a May 

2013 USDA Office of Inspector General report identified areas of risk in 

FSIS’ inspection of hog plants, including those participating in the pilot 

project.22 The report found that FSIS did not critically assess whether the 

pilot project had measurably improved food safety at each participating 

plant because the agency did not adequately oversee the program.23

As FSIS officials stated, when the agency develops a proposed 

rulemaking to modify its slaughter inspection system for hogs, it will need 

to decide whether to collect additional data. However, while the pilot 

project is ongoing, FSIS has the opportunity to follow sound management 

practices by planning for and collecting key information needed to 

In 

response, FSIS stated that it would complete an evaluation that would 

include an analysis of plants participating and not participating in the pilot 

project. However, as we previously stated, the analyses that the agency 

plans to use in this evaluation are similar to those presented in the report 

evaluating the pilot project at young chicken plants, suggesting that 

similar limitations may apply. According to FSIS officials, the agency 

intends to complete this evaluation by March 31, 2014. The officials said 

that the agency could use its final report evaluating the pilot project at 

young hog plants to support a rulemaking but currently has no time frame 

for doing so. FSIS’ pilot project at young hog plants will end when a final 

rule for hog slaughter is published.

 22USDA, Office of Inspector General, Food Safety and Inspection Service—Inspection and 

Enforcement Activities at Swine Slaughter Plants, Audit Report 24601-0001-41, May 9, 

2013.

23Although the pilot project was intended to improve food safety, the Office of Inspector 

General report found that 3 of the 10 plants cited with the most noncompliance with 

regulations from fiscal years 2008 to 2011 were plants in the pilot project. In fact, the hog

plant with the most noncompliance during this time frame was a plant in the pilot project—

with nearly 50 percent more noncompliance citations than the plant with the next highest 

number.
Page 17 GAO-13-775 USDA Inspection Pilot Projects

determine whether the pilot project is meeting its purpose. We have 

previously reported that pilot programs can more effectively inform future 

program rollout when sound management practices are followed.24

Consistent with best practices in program management,25 our guide for 

designing evaluations,26

However, FSIS has not collected key information needed to determine 

whether the pilot project is meeting its purpose of deploying inspection 

resources more effectively in accordance with food safety and other 

consumer protection requirements. For example, FSIS has not collected 

information on the total costs of the pilot project to the agency or on any 

changes in the number of FSIS inspectors at the plants participating in 

the pilot project. Thus far, at young hog plants, FSIS veterinarians and 

inspectors have evaluated the performance of their individual plants 

against regulatory performance standards on a daily basis, as they 

routinely do for all plants regardless of whether they are in the pilot 

project or not, as well as the performance standards for the pilot project. 

However, the agency has not aggregated and analyzed these daily 

results to determine how the plants participating in the pilot project have 

performed over time. Without collecting and analyzing additional data, it 

and our prior work, we identified sound 

management practices to design a pilot to guide consistent 

implementation, including the type and source of data needed to evaluate 

the pilot, and to conduct analysis of the results.

 24See GAO-11-383, GAO-09-45, and GAO-06-538. Specifically, in GAO-11-383, 

GAO-09-45, and GAO-06-538, we reported that a sound, well-developed and documented 

evaluation plan includes, at a minimum: (1) well-defined, clear, and measurable 

objectives; (2) criteria or standards for determining pilot-program performance; (3) clearly 

articulated methodology, including sound sampling methods, determination of appropriate 

sample size for the evaluation design, and a strategy for comparing the pilot results with 

other efforts; (4) a clear plan that details the type and source of data necessary to 

evaluate the pilot, methods for data collection, and the timing and frequency of data 

collection; and (5) a data analysis plan to track the program’s performance and evaluate 

the final results of the project.

25See, for example, P.H. Rossi, M.W. Lipsey, and H.E. Freeman, Evaluation: A 

Systematic Approach (Thousand Oaks, Calif.: 2004); and the Project Management 

Institute. The Standard for Program Management® (Newton Square, Pa.: 2006). 

Specifically, Evaluation: A Systematic Approach covers evaluation research activities used 

in appraising the design, implementation, effectiveness, and efficiency of social programs. 

Also, The Standard for Program Management describes program phases to facilitate 

program governance, enhanced control, and coordination of program and project 

resources and overall risk management.

26See, GAO, Designing Evaluations, GAO/PEMD-10.1.4 (Washington, D.C.: March 1991).
Page 18 GAO-13-775 USDA Inspection Pilot Projects

will be difficult for FSIS to draw conclusions about whether the pilot 

project at young hog plants is meeting its purpose of deploying inspection 

resources more effectively in accordance with food safety and other 

consumer protection requirements.

We identified strengths and weaknesses of the three pilot projects based 

on the views of 11 key stakeholder groups representing industry, labor, 

consumer advocacy, and animal welfare.27

• Responsibility and flexibility. Representatives of 7 stakeholder groups 

stated that the pilot projects give plants responsibility and flexibility for 

ensuring food safety and quality. For example, representatives of 1 

stakeholder group stated that, under the pilot projects, plants had 

greater flexibility to place plant personnel where they were skilled, 

while a representative of another stakeholder group stated that the 

pilot projects gave plants responsibility for producing safe food and 

allowed plants the latitude to incorporate new methods to ensure food 

safety.

Strengths we identified in the 

pilot projects based on the views cited most frequently by stakeholder 

groups included the following:

• More focus on food safety. Representatives of 5 stakeholder groups 

stated that the pilot projects allow FSIS to focus more on food safety 

activities. For example, a representative of 1 stakeholder group stated 

that, in the pilot projects, FSIS inspectors focused on carcass and 

verification activities designed to reduce the incidence of foodborne 

pathogens.

• Potential job creation and increased production. Representatives of 3 

stakeholder groups stated that the pilot projects may result in potential 

job creation and increased production at plants. For example, a 

representative of 1 stakeholder group stated some plants that joined 

the pilot projects hired new workers, purchased additional equipment, 

and expanded their facilities. A representative of another stakeholder 

group stated that the pilot projects allowed plants to increase line 

speeds to process and sell a larger quantity of products.

 27Representatives from stakeholder groups stated that they were most familiar with the 

pilot project at young chicken plants and generally were not as familiar with the pilot 

projects at young turkey or young hog plants. However, representatives stated that their 

comments generally applied across the three pilot projects, which were all designed to 

have plant personnel assume the sorting responsibilities of FSIS inspectors positioned on 

the line for identifying carcass defects and removing unacceptable carcasses.

Views of Key 

Stakeholder Groups 

on Strengths and 

Weaknesses in the 

Pilot Projects
Page 19 GAO-13-775 USDA Inspection Pilot Projects

Weaknesses we identified in the pilot projects based on the views cited 

most frequently by stakeholder groups included the following:

• Training. Representatives from all 11 stakeholder groups stated that 

training for plant personnel that assume sorting responsibilities on the 

slaughter line is not required or standardized. For example, a 

representative of 1 stakeholder group stated that training of plant 

personnel was not required. Representatives of another stakeholder 

group stated that plants’ training programs varied based on individual 

plant standards, and a representative of another stakeholder group 

recommended that FSIS provide detailed training and guidance on, 

among other things, conditions that require carcasses to be 

condemned to ensure that uniform standards are consistently used 

across industry in training plant personnel. According to FSIS officials, 

training of plant personnel was not required for plants participating in 

the pilot projects because, among other things, FSIS inspectors 

observed the line and made the plant take corrective actions, if 

necessary. Representatives of 3 stakeholder groups further noted that 

FSIS required that some countries, which exported to the United 

States and have similar inspection programs to the pilot projects, must 

train and certify their plant personnel. However, according to FSIS 

officials, the agency has no such requirement. Rather, FSIS officials 

stated that FSIS requires that foreign governments achieve an 

equivalent level of food safety protection as the U.S. inspection 

system, and that the countries, which stakeholders groups identified, 

chose to include training and certification requirements for their plant 

personnel to demonstrate this equivalence.

• Line speed. Representatives of 7 stakeholder groups stated that 

faster line speed creates food safety and worker safety concerns. For 

example, a representative of 1 stakeholder group stated that, at young 

chicken plants participating in the pilot project, the FSIS inspector on 

the line had about one second to inspect three carcasses, which was 

not enough time, especially if a bird was contaminated with a small 

amount of fecal material—posing a food safety concern. A 

representative of another stakeholder group stated that increased line 

speeds contributed to higher rates of carpal tunnel syndrome and 

other injuries in poultry plant personnel. According to FSIS’ 2011 

report evaluating the pilot project at young chicken plants, not all 

slaughter lines at the plants in the pilot project are running at their 

maximum speed. FSIS also noted in its report that young chicken 

plants operating under the pilot project demonstrated that they are 

capable of consistently producing safe poultry products and of 

consistently meeting pathogen reduction and other performance 

standards operating at these higher line speeds. However, as 
Page 20 GAO-13-775 USDA Inspection Pilot Projects

previously noted in this report, we identified limitations in FSIS’ 

evaluation. FSIS officials also told us that the agency is collaborating 

with the CDC’s National Institute for Occupational Safety and Health 

to obtain data on the effects of increased line speed by collecting data 

at one young chicken plant, which is not participating in the pilot 

project, that has been granted a waiver from the line speed restriction 

under the Salmonella Initiative Program.28

• Reduced ability to see potential defects. Representatives of 5 

stakeholder groups stated that FSIS inspectors’ ability to see potential 

defects in young chicken carcasses is reduced because inspectors 

positioned on the slaughter line are observing the back of the carcass 

without the viscera. At young chicken plants not in the pilot project, 

FSIS inspectors examine the exterior, interior cavity, and viscera of 

each carcass. A representative of 1 stakeholder group noted that, at 

young chicken plants in the pilot project, inspectors positioned on the 

slaughter line can no longer see into the carcass’ cavity, where fecal 

contamination was most likely to be located.29

• Noncompliance with zero-tolerance standard for fecal material more 

difficult to cite. Representatives of 5 stakeholder groups stated that it 

is harder for FSIS inspectors to cite plants for not complying with 

FSIS’ zero-tolerance standard for fecal material because plants in the 

FSIS officials stated 

that inspectors observing the backs of chickens are able to identify 

fecal contamination, and they can require plant personnel to trim and 

reprocess contaminated carcasses. According to agency documents, 

observing the carcass without the viscera is sufficient for identifying all 

poultry diseases and conditions except for avian visceral leukosis, a 

viral disease that affects chickens. Because avian visceral leukosis is 

a condition that, if present, will be present throughout the entire flock, 

the agency has established a procedure at young chicken plants 

participating in the pilot project to observe the viscera of the first 300 

birds of a flock near the beginning of the slaughter line to determine 

the presence of this condition.

 28According to the CDC’s website, the mission of the National Institute for Occupational 

Safety and Health is to generate new knowledge in the field of occupational safety and 

health and to transfer that knowledge into practice for the betterment of workers by 

conducting scientific research, developing guidance and authoritative recommendations, 

disseminating information, and responding to requests for workplace health hazard 

evaluations. 

29In young chicken plants participating in the pilot project, inspectors view the backs of the 

carcasses after the birds have been sorted and cleaned and generally do not touch the 

carcasses.
Page 21 GAO-13-775 USDA Inspection Pilot Projects

pilot projects may decide to address a food safety hazard—such as 

fecal material—at a point on the slaughter line after the FSIS 

inspector.30 For example, a representative of 1 stakeholder group 

raised a concern that by allowing plants in the pilot project to move 

the critical control point for preventing, eliminating, and controlling 

fecal material to a location on the slaughter line after the FSIS 

inspector, the FSIS inspector no longer had the ability to ensure that 

the plant complied with the standard to control for that hazard.31

• Conflict of interest of plant personnel sorting carcasses.

Representatives from 4 stakeholder groups stated that plants’ 

responsibility for sorting carcasses presents a conflict of interest. For 

example, a representative of 1 stakeholder group expressed concern 

that a plant’s financial incentive to process the maximum number of 

birds conflicted with its responsibility to regulate itself and stated that if 

plant personnel continually removed birds from the line, those 

personnel might be taken off the line. FSIS officials stated that plants’ 

responsibility for sorting carcasses did not present a conflict of interest 

because FSIS inspectors performed food safety activities, inspected 

each carcass, and verified the effectiveness of plant personnel’s 

sorting activities.

More 

specifically, the FSIS inspector positioned on the line could no longer 

cite the plant for noncompliance with FSIS’ zero-tolerance standard 

for fecal material because the plant would not yet have had an 

opportunity to control for this hazard. In response, FSIS officials 

stated that there were more opportunities for identifying 

noncompliance with fecal standards for young poultry plants in the 

pilot projects because FSIS inspectors positioned off the slaughter 

line perform more food safety activities than at plants not participating 

in the pilot projects.

 30At plants not participating in the pilot projects, FSIS inspectors positioned on the 

slaughter line sort carcasses and direct plant personnel to reprocess (remove) visible fecal 

material from the carcasses. These FSIS inspectors positioned on the slaughter line do 

not cite the plants for noncompliance with FSIS’ zero-tolerance standard for fecal material.

31As previously stated, under the risk-based HACCP approach, plants must identify the 

point where they will control for food safety hazards, such as fecal material. Young 

chicken plants in the pilot project have discretion to establish the critical control point at a 

fixed location on the slaughter line either before or after the FSIS inspector’s position on 

the slaughter line. If the critical control point is located before the FSIS inspector, then the 

inspector can cite the plant if the hazard is found. In contrast, if the critical control point is 

located after the FSIS inspector, then the inspector cannot cite the plant if the hazard is 

found. 
Page 22 GAO-13-775 USDA Inspection Pilot Projects

• Insufficient evidence of success of the pilot projects. Representatives 

of 3 stakeholder groups stated that FSIS does not have sufficient 

evidence to demonstrate the success of the pilot projects. For 

example, a representative of 1 stakeholder group stated that FSIS’ 

data from the pilot project at young chicken plants demonstrated that 

FSIS inspectors on the slaughter lines missed food safety defects on 

carcasses, such as fecal material. In particular, the stakeholder group 

representative cited FSIS data showing that FSIS inspectors 

positioned off the slaughter line who are responsible for, among other 

things, verifying the food safety of a sample of carcasses, found food 

safety defects at a much higher rate than FSIS inspectors positioned 

on the slaughter line. According to FSIS officials, the rate at which 

FSIS inspectors positioned on the slaughter line detected food safety 

defects was not directly comparable to the rate at which FSIS 

inspectors positioned off the slaughter line detected food safety 

defects because the inspectors positioned on the line and off the line 

had different but complementary roles. FSIS officials maintained, in its 

2011 report evaluating the pilot project at young chicken plants, that 

the pilot project improved the safety of chicken products at 

participating plants. However, as previously noted in this report, we 

identified limitations in FSIS’ evaluation.

• Increased costs to industry. Representatives of 2 stakeholder groups 

stated that the pilot projects can result in increased costs to industry 

for additional capital investment, training, and staff. For example, a 

representative of 1 stakeholder group stated that plants participating 

in the pilot projects may need substantial capital for redesigning 

equipment and adding personnel, and a representative of another 

stakeholder group noted that plants participating in the pilot projects 

needed to add plant personnel to replace FSIS inspectors. FSIS 

officials stated that participation in the pilot projects was voluntary and 

that plants could choose whether to invest capital when participating.

FSIS officials stated that they recognized there were similarities between 

the pilot projects and the optional new poultry inspection system included 

in the proposed rule, and they are working to address concerns identified 

by stakeholder groups in the final rule on modernizing poultry slaughter 

inspections.
Page 23 GAO-13-775 USDA Inspection Pilot Projects

FSIS did not disclose certain limitations in sources of information it relied 

on to develop the cost-benefit analysis supporting the proposed rule on 

modernizing poultry slaughter inspections. As a result, the public, 

including stakeholders, did not have complete and accurate information to 

inform their comments on the proposed rule, including the uncertainty 

behind selected estimates. According to the Office of Management and 

Budget (OMB) Circular A-4,32 which provides guidance to federal 

agencies on the development of regulatory analysis, and USDA’s 

departmental regulation that details the process for developing 

regulations,33

We identified three sources of information FSIS used that contained 

certain limitations that were not disclosed in the cost-benefit analysis. 

First, in the 2012 proposed rule, FSIS did not disclose that it used a 2001 

survey of plants’ costs of converting to the pilot projects to estimate 

certain costs for a plant that slaughters young chickens or turkeys to 

operate under the optional new poultry inspection system. According to 

USDA’s departmental regulation, the quality of the data used in costbenefit analyses should be discussed in the proposed rule. However, our 

review of the proposed rule found the following limitations in the survey 

data that FSIS did not disclose:

a good cost-benefit analysis is transparent and a qualified 

third party reading the analysis should be able to understand the basic 

elements.

• Estimated costs included in the January 2012 proposed rule were 

based on cost information gathered in 2001. FSIS officials told us that 

they did not attempt to obtain more recent information because it was 

challenging to collect this type of information from plants, which 

consider such information proprietary. FSIS officials stated that there 

has been little or no change in the cost information but did not provide 

any documentation to support this statement.

• FSIS generalized the results from the 12 young chicken plants that 

responded to the 2001 cost survey to the universe of 335 young 

chicken and young turkey plants in the United States in 2012 to 

estimate certain costs for poultry plants to operate under the optional 

new poultry inspection system. However, results obtained from the 12 

 32OMB, Circular A-4, Sept. 17, 2003.

33USDA, Departmental Regulation, No. 1512, Regulatory Decision Making Requirements, 

Dec. 24, 2008.

FSIS Did Not Disclose 

Certain Limitations in 

the Cost-Benefit 

Analysis It Developed 

to Support the 

Proposed Rule
Page 24 GAO-13-775 USDA Inspection Pilot Projects

young chicken plants that responded to the survey are not 

representative of the universe of young poultry plants.

• For the young turkey plants participating in the pilot project, FSIS did 

not obtain any cost data. According to FSIS officials, the agency did 

not attempt to obtain cost information from participating young turkey 

plants because, at the time of the 2001 survey, there were only two 

such plants. These officials further stated that the process to slaughter 

chickens is sufficiently similar to that for turkeys so costs can be 

generalized. However, these officials acknowledged there are 

differences between chickens and turkeys, such as carcass size, that 

can affect costs, including chilling costs.

As a result of these limitations, the costs for a plant to convert to the 

optional new poultry inspection system in today’s economy may be 

unclear to the public, including stakeholders.

Second, to estimate selected benefits of the proposed rule, FSIS 

assumed a single value for certain economic parameters, rather than 

following USDA’s departmental regulation and OMB’s Circular A-4 and 

using a sensitivity analysis to provide for a range of uncertainty in the 

results.34

 34According to USDA’s departmental regulation, it may be necessary to provide a 

sensitivity analysis to reveal whether, and to what extent, the results are sensitive to 

plausible changes in the main assumptions and numeric inputs. A sensitivity analysis is an 

analysis of the change in major assumptions to determine uncertainty.

For example, to estimate the expected annual cost savings to 

plants in the proposed rule, FSIS assumed that plants participating in the 

optional new poultry inspection system would increase their slaughter line 

speeds by an average of 6 percent. However, the agency noted in a 

footnote in the proposed rule that line speeds could potentially increase 

by up to 25 percent (from 140 carcasses per minute to 175 carcasses per 

minute) at young chicken plants or by up to 22 percent (from 45 

carcasses per minute to 55 carcasses per minute) at turkey plants. These 

ranges in line speed are key parameters for estimating benefits to plants

and would affect the labor costs of processing each carcass, as well as 

the number of carcasses processed and overall profits. Although FSIS 

noted a range in line speed exists, it did not use a sensitivity analysis to 

calculate a range of annual net benefits to plants resulting from 

uncertainties in line speed. As a result, the public, including stakeholders, 

did not have complete and accurate information to inform their comments 

on the proposed rule and provide them with a clearer understanding of 
Page 25 GAO-13-775 USDA Inspection Pilot Projects

the potential impacts of the final rule, including uncertainty behind 

selected estimates. 

According to USDA’s departmental regulation, uncertainty is inherent in a 

cost-benefit analysis, and the uncertainties that are important to 

regulatory decisions should be identified and presented as part of the 

overall regulatory analysis. According to FSIS officials, the only 

uncertainties that are important to this regulation are related to public 

health, and the agency included a range in its estimation of the public 

health benefits of the proposed rule. However, we believe that there are 

other uncertainties in the proposed rule that are important to the costbenefit analysis, such as the expected benefit to industry from lifting the 

current restriction on line speed.

Third, FSIS used a variety of economic studies to assess the economic 

conditions in the poultry industry under the proposed rule but did not 

identify certain limitations of these studies, including that data in at least 

one of the studies were more than 20 years old. Specifically, FSIS did not 

disclose that these studies may not reflect current market conditions. 

FSIS stated that it used the best available information when it drafted the 

proposed rule and cited the studies in footnotes throughout the proposed 

rule. However, FSIS did not identify how limitations in the studies could 

potentially affect the overall cost-benefit analysis. For example, FSIS 

stated in the proposed rule that it assumed the total labor-related cost to 

process a bird was 15 percent on the basis of a study published in 2000, 

but the agency did not disclose that the study was based on data from 

1972 to 1992 for chickens and from 1967 to 1992 for turkeys. As another 

example, FSIS estimated the mark-up price of poultry to be 10 percent 

more than wholesale prices based on a study published in 2000, which

was based on information on the price of poultry from 1996. As a result, 

the public, including stakeholders, may not know if the economic 

conditions in the poultry industry presented in the proposed rule 

accurately reflect current market conditions.

According to FSIS officials, the agency plans to address some of the 

limitations in its revised cost-benefit analysis to support the final rule. For 

example, the agency plans to include a range for annual production cost 

savings in the revised cost-benefit analysis, which is part of the draft final 

rule. However, according to FSIS officials, the draft final rule is 

undergoing departmental review and was not made available to us, as it 

is subject to additional changes. It is unclear whether all of the limitations 

that we identified will be disclosed in the final rule.
Page 26 GAO-13-775 USDA Inspection Pilot Projects

Moreover, to estimate the public health impact of the proposed rule, FSIS 

developed a risk assessment that contributes to its cost-benefit analysis. 

FSIS’ risk assessment model examined how pathogen levels in poultry 

products could be affected, depending on the frequency and scheduling 

of activities performed by FSIS inspectors positioned off the slaughter 

line. We were unable to determine if the results of FSIS’ risk assessment 

accurately stated the public health benefits in the proposed rule because 

the risk assessment did not include sufficient detail about its 

methodology. According to USDA’s departmental regulation and OMB 

Circular A-4, a good analysis is transparent, and a qualified third party 

reading the regulatory analysis should be able to see what data, methods, 

models, and assumptions were used to arrive at the agency’s estimates. 

However, in its risk assessment, FSIS did not disclose its rationale for 

numerous, complex key assumptions critical to the analyses it used to 

calculate public health benefits for the proposed rule.35 In addition, in the 

proposed rule, FSIS identified a range of 1,540 to 10,547 potential 

illnesses averted by increasing the number of unscheduled inspection 

activities off the slaughter line. However, this only covered 80 percent of 

the estimated range of potential illnesses averted, and it is unclear why 

FSIS did not disclose a wider range of potential benefits.36 Had a wider 

range been used, FSIS would have increased the statistical confidence of 

its estimate in the number of illnesses averted by increasing unscheduled 

activities off the slaughter line. FSIS officials acknowledged the 

importance of disclosing sufficient details about the methodology and 

stated that the risk assessment represents a snapshot in time; they also 

said that a revised risk assessment supporting the final rule—an 

assessment that is not yet available to the public—includes more of this 

critical information. The revised risk assessment is part of the draft final 

rule that is undergoing departmental review and was not made available 

to us.

 35For example, the basis for using certain statistical analyses (e.g., distribution of 

unscheduled inspection activities off the slaughter line) were not disclosed or explained. 

36FSIS estimated that the illnesses averted would be 1,540 for the 10th percentile of the 

range of potential illnesses averted and 10,547 for the 90th percentile of the range of 

potential illnesses averted. By covering 80 percent of the possible estimated range in 

potential illnesses avoided, differences for results in this range could happen by chance 

20 percent of the time.
Page 27 GAO-13-775 USDA Inspection Pilot Projects

In an effort to deploy inspection resources more effectively in accordance 

with food safety and other consumer protection requirements, FSIS has 

been conducting pilot projects at slaughter plants for young chickens, 

young turkeys, and young hogs since 1998. These pilot projects are in 

keeping with FSIS’ broader effort to move toward a risk-based inspection 

system, which we believe is a positive step. However, we found that FSIS 

has not thoroughly evaluated how the three pilot projects have performed 

over time. Specifically, there are limitations in the agency’s data analyses 

in its report evaluating the pilot project at young chicken plants, and there 

is no report evaluating the pilot project at young turkey plants. 

Nonetheless, the agency moved forward with a proposed rule in January 

2012 on modernizing poultry slaughter inspections that included an 

optional new poultry inspection system, based, in part, on its experience 

with the pilot projects at young chicken and young turkey plants. As a 

result, FSIS may not have assurance that its evaluation of the pilot project 

at young chicken plants provides the information necessary to support the 

proposed rule for both chickens and turkeys. However, the agency will not 

complete another evaluation before it issues a final rule. To support the 

proposed rule, the agency developed a cost-benefit analysis but did not 

disclose certain limitations in sources of information—including that data 

in at least one study was more than 20 years old—it relied on to develop 

this analysis, which is not consistent with USDA regulation and OMB 

Circular A-4 stating that a good analysis for rulemaking is transparent. As 

of July 2013, FSIS officials stated that the agency plans to address some 

of these limitations as it works to complete the final rule. Without 

complete disclosure from FSIS, the public, including stakeholders, did not 

have complete and accurate information to inform their comments on the 

proposed rule and provide them with a clearer understanding of the 

potential impacts of the final rule, including the uncertainty behind 

selected estimates. By addressing these limitations moving forward in its 

rulemaking for modernizing poultry slaughter inspections, FSIS can 

prepare for more transparency in the development of a future proposed 

rule to modify slaughter inspection for hogs based on the pilot project at 

young hog plants.

In 2011, FSIS began drafting a preliminary report evaluating the pilot 

project at young hog plants, which uses analyses similar to those 

presented in the report evaluating the pilot project at young chicken 

plants, suggesting that similar limitations may apply. FSIS officials stated 

that the agency intends to complete its evaluation of the pilot project at 

young hog plants by March 31, 2014. They also stated that the agency 

would need to decide if additional data would be collected when it 

proceeded forward with a rulemaking effort for hogs. Without collecting 

Conclusions
Page 28 GAO-13-775 USDA Inspection Pilot Projects

and analyzing additional data, it will be difficult for FSIS to draw 

conclusions about whether the pilot project at young hog plants is 

meeting its purpose of deploying inspection resources more effectively in 

accordance with food safety and other consumer protection requirements. 

Because the pilot project at young hog plants is ongoing, FSIS has the 

opportunity to follow sound management practices by planning for and 

collecting key information needed to determine whether the pilot project is 

meeting its purpose. As we have previously reported, pilot programs can 

more effectively inform future program rollout when sound management 

practices are followed.

We recommend that the Secretary of Agriculture direct the Administrator 

of the Food Safety and Inspection Service to take the following two 

actions:

• Clearly disclose to the public limitations in the information—including 

the cost-benefit analysis—the agency relied on for the rulemaking to 

modernize poultry slaughter inspections.

• As FSIS continues its evaluation of its pilot project for young hogs, 

collect and analyze the information necessary to determine whether 

the pilot project is meeting its purpose.

We provided a draft of this report to USDA for its review and comment. 

USDA’s written comments and our detailed response to them are 

reproduced in appendix III. In its written comments, USDA concurred with 

both of our recommendations. More specifically, USDA concurred with 

our recommendation that it clearly disclose to the public limitations in the 

information—including the cost-benefit analysis—it relied on for the 

rulemaking to modernize poultry slaughter inspections. According to 

USDA, when it issues the final rule, it will present the updated analyses in 

a manner that will facilitate the public’s understanding of the information 

used to support its rulemaking. USDA also concurred with our 

recommendation to collect and analyze the information necessary to

determine whether the pilot project for young hogs is meeting its purpose, 

while continuing its evaluation of this pilot project. According to USDA, it 

plans to complete such an evaluation by March 31, 2014, at which time it 

will determine whether a permanent program is warranted. 

USDA also made several general comments. For example, USDA 

commented that, throughout our report, we state that the purpose of the 

pilot projects was to “...deploy inspection resources more effectively...”.

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
Page 29 GAO-13-775 USDA Inspection Pilot Projects

USDA further commented that, while this might have been true when the 

pilot projects were initiated in 1997, the agency’s thinking has evolved 

over the years to focus less on efficiencies and more on public health and 

food safety. We recognize that USDA’s descriptions of the pilot projects, 

as stated in the Federal Register notices, have evolved over the years. 

However, we believe that the purpose stated in our report—deploying 

inspection resources more effectively in accordance with food safety and 

other consumer protection requirements—remains valid because the 

Federal Register notices cited by USDA continue to mention effective use

of resources as a component of its pilot projects. Moreover, agency 

officials directed us to the Federal Register notices because the agency

could not provide us with documents defining the pilot projects’ purpose.

As our report states, pilot programs can more effectively inform future 

program rollout when sound management practices are followed, 

including the development of an evaluation plan with well-defined, clear, 

and measurable objectives. 

Furthermore, USDA provided technical comments in its written response, 

which we have incorporated, as appropriate, in the report. 

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the 

Secretary of Agriculture, the appropriate congressional committees, and 

other interested parties. In addition, the report will be available at no 

charge on the GAO website at http://www.gao.gov. 

If you or your staff members have any questions regarding this report, 

please contact me at (202) 512-3841 or gomezj@gao.gov. Contact points 

for our Offices of Congressional Relations and Public Affairs may be 

found on the last page of this report. Key contributors to this report are 

listed in appendix IV.

Sincerely yours,

J. Alfredo Gómez

Director, Natural Resources and Environment
Appendix I: Objectives, Scope, and 

Methodology

Page 30 GAO-13-775 USDA Inspection Pilot Projects

This report responds to your request that we review U.S. Department of 

Agriculture’s (USDA) pilot projects at slaughter plants for young chickens, 

young turkeys, and young hogs. Our objectives were to determine (1) the 

extent to which USDA has evaluated the three pilot projects, (2) strengths 

and weaknesses of the three pilot projects based on the views of key 

stakeholder groups, and (3) the extent to which USDA disclosed 

limitations, if any, in sources of information it relied on to develop the 

proposed rule to modernize poultry slaughter inspections.

To determine the extent to which USDA has evaluated the three pilot 

projects, we reviewed relevant USDA documents, Federal Register

notices, and laws. We also compared USDA’s efforts to evaluate the pilot 

projects with criteria based on social science and evaluation literature and 

published GAO guidance that were identified in our previous work on pilot 

program development and evaluation. Our previous work dealt with pilot 

projects at the Federal Emergency Management Agency, the Internal 

Revenue Service, and the Department of Defense where we identified 

key features of a well-developed evaluation plan that increases the 

likelihood that evaluations would yield methodologically sound results and 

support effective program and policy decisions.1

To determine the strengths and weaknesses of the three pilot projects 

based on the views of key stakeholder groups, we identified key 

stakeholder groups representing industry, labor (including plant personnel 

and USDA inspectors and veterinarians), consumer advocacy, and 

animal welfare that submitted comments on USDA’s proposed rule on 

We believe that the key 

features identified in those reports are applicable to pilot projects, in 

general, including USDA’s three pilot projects. In addition, we interviewed 

several officials in various offices within USDA’s Food Safety and 

Inspection Service—the agency responsible for USDA’s meat and poultry 

inspection program.

 1

GAO-11-383, GAO-09-45, and GAO-06-538. Specifically, in GAO-11-383, GAO-09-45, 

and GAO-06-538, we reported that a sound, well-developed and documented evaluation 

plan includes, at a minimum: (1) well-defined, clear, and measurable objectives; (2) 

criteria or standards for determining pilot-program performance; (3) clearly articulated 

methodology, including sound sampling methods, determination of appropriate sample 

size for the evaluation design, and a strategy for comparing the pilot results with other 

efforts; (4) a clear plan that details the type and source of data necessary to evaluate the 

pilot, methods for data collection, and the timing and frequency of data collection; and (5) 

a data analysis plan to track the program’s performance and evaluate the final results of 

the project.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-13-775 USDA Inspection Pilot Projects

modernizing poultry slaughter inspections. We identified 11 key 

stakeholder groups with sufficient knowledge about USDA’s pilot projects 

at young chicken, young turkey, and young hog plants to identify 

strengths and weaknesses for these pilot projects.2 These stakeholder 

groups were the American Federation of Government 

Employees/National Joint Council of Food Inspection Locals, the 

American Meat Institute, the Center for Foodborne Illness Research and 

Prevention, the Consumer Federation of America, Food and Water 

Watch, the Government Accountability Project, the Humane Society of 

the United States, the National Association of Federal Veterinarians, the 

National Chicken Council, the National Turkey Federation, and the North 

American Meat Association.3

 2

We developed an initial list of key stakeholder groups based on our prior experience and 

knowledge. To ensure that we included all of the relevant stakeholder groups, we asked 

these groups for suggestions on other stakeholders we should consider contacting and 

expanded the list, as needed.

We reviewed their comments to USDA’s 

proposed rule to determine the extent to which the comments may apply 

to the pilot projects; interviewed representatives of these key stakeholder 

groups; and followed up with e-mailed questions to gauge their level of 

familiarity with each pilot project and then clarified responses, as needed. 

Three of our analysts worked together to develop categories of strengths 

and weaknesses identified most frequently by stakeholder groups, and 

two analysts independently determined whether each stakeholder group 

had identified strengths or weaknesses that fit into these categories. Any 

discrepancies in coding were discussed, and agreement was reached 

between the analysts, or resolved through a third analyst’s review. We 

also visited 10 slaughter plants for young chickens, young turkeys, and 

young hogs to learn about the variations in slaughter inspection systems 

between plants participating and not participating in the pilot projects. In 

selecting these plants, we chose plants in states that are the top 

producers of young chickens, young turkeys, and young hogs and that 

have at least one plant that is participating in a pilot project and at least 

one plant that is not participating in a pilot project for one of those 

species. On the basis of these selection criteria, we visited plants in 

Georgia for young chickens, Indiana for young turkeys, and Minnesota for 

3

The Center for Science in the Public Interest was also included in our methodology but 

we were unsuccessful in obtaining an interview. We also contacted People for the Ethical 

Treatment of Animals and the United Food and Commercial Workers International Union, 

but these stakeholder groups did not respond to our e-mail questions specific to strengths 

and weaknesses of USDA’s pilot projects.
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-13-775 USDA Inspection Pilot Projects

young hogs. For each species, we visited at least one plant participating 

and one plant not participating in the pilot projects. We interviewed plant 

management and USDA veterinarians and inspectors working at these 

plants, and we toured the plants.

To determine the extent to which USDA disclosed limitations, if any, in 

sources of information it relied on to develop the proposed rule, we 

reviewed the proposed rule and related Federal Register notices, as well 

as selected documents the agency relied on to develop the proposed 

rule. We also reviewed relevant guidance such as the Office of 

Management and Budget Circular A-4,4 which provides guidance to 

federal agencies on the development of regulatory analysis, and the 

USDA departmental regulation that details the process for developing 

regulations.5

We conducted this performance audit from September 2012 to August 

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence presented provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

We also interviewed several officials in various offices within 

USDA’s Food Safety and Inspection Service to clarify information, as 

needed.

 4

OMB, Circular A-4, Sept. 17, 2003.

5

USDA, Departmental Regulation, No. 1512, Regulatory Decision Making Requirements, 

Dec. 24, 2008.
Appendix II: Additional Information on the 

Young Chicken, Young Turkey, and Young Hog 

Plants in the Pilot Projects

Page 33 GAO-13-775 USDA Inspection Pilot Projects

As of July 2013, 29 plants were participating in the pilot projects in 18 

states. More specifically, there were 19 participating young chicken plants 

located in 10 states. These 10 states accounted for almost 66 percent of 

the more than 49.3 billion pounds of young chickens slaughtered in 

2012.1

 1

We used 2012 data on the annual volume of chickens slaughtered, by state, because 

those are the most recent data available. The states with plants that were participating in 

the pilot project, as of July 2013, were the same states as in 2012. In 2011, one plant 

dropped out of the pilot project for young chickens and closed its operations. If this plant is 

included, then the 20 young chicken plants in the pilot project were located in 11 states. 

Because this plant closed its operations in 2011, it did not contribute to the total volume of 

young chickens slaughtered in 2012. 

(See fig. 2.)

Appendix II: Additional Information on the 

Young Chicken, Young Turkey, and Young 

Hog Plants in the Pilot Projects
Appendix II: Additional Information on the 

Young Chicken, Young Turkey, and Young Hog 

Plants in the Pilot Projects

Page 34 GAO-13-775 USDA Inspection Pilot Projects

Figure 2: Location of Young Chicken Plants in the Pilot Project and the Volume of Young Chickens Slaughtered, by State, in 

2012

Note: Information on volumes was for the total live weight of young chickens slaughtered. According 

to USDA, the agency did not publish all of the data by individual states to avoid disclosure in states 

with low slaughter volumes. These states were included in the “None or minimal slaughter” category 

and collectively slaughtered about 140 million pounds of young chickens. In 2012, in the 26 states 

where young chickens were slaughtered and for which data were reported, the volumes slaughtered 

ranged from about 8.2 million to almost 6.8 billion pounds per state.
Appendix II: Additional Information on the 

Young Chicken, Young Turkey, and Young Hog 

Plants in the Pilot Projects

Page 35 GAO-13-775 USDA Inspection Pilot Projects

In terms of the pilot project at young turkey plants, four of the five young 

turkey plants in the pilot project were located in states that accounted for 

about 33 percent of the more than 7.4 billion pounds of young turkeys 

slaughtered in 2012; one young turkey plant was located in Michigan—a 

state with a lower volume of young turkeys slaughtered—and data were 

not available on the volume of young turkeys slaughtered in this state.2

 2

We used 2012 data on the annual volume of turkeys slaughtered, by state, because 

those are the most recent data available. The states with plants that were participating in 

the pilot project, as of July 2013, were the same states as in 2012.

(See fig. 3.)
Appendix II: Additional Information on the 

Young Chicken, Young Turkey, and Young Hog 

Plants in the Pilot Projects

Page 36 GAO-13-775 USDA Inspection Pilot Projects

Figure 3: Location of Young Turkey Plants in the Pilot Project and the Volume of Young Turkeys Slaughtered, by State, in 

2012

Note: Information on volumes was for the total live weight of young turkeys slaughtered. According to 

USDA, the agency did not publish all of the data by individual states to avoid disclosure in states with 

low slaughter volumes. These states were included in the “None or minimal slaughter” category and 

collectively slaughtered about 1.2 billion pounds of young turkeys. In 2012, in the 11 states where 

young turkeys were slaughtered and for which data were reported, the volumes slaughtered ranged 

from about 111 million pounds to more than 1.1 billion pounds per state.
Appendix II: Additional Information on the 

Young Chicken, Young Turkey, and Young Hog 

Plants in the Pilot Projects

Page 37 GAO-13-775 USDA Inspection Pilot Projects

In terms of the pilot project at young hog plants, the five hog plants in the 

pilot project were located in five states that accounted for about 30 

percent of the more than 31 billion pounds of hogs slaughtered in 2012.3

 3

We used 2012 data on the annual volume of hogs slaughtered, by state, because those 

are the most recent data available. The states with plants that were participating in the 

pilot project, as of July 2013, were the same states as in 2012.

(See fig. 4.)
Appendix II: Additional Information on the 

Young Chicken, Young Turkey, and Young Hog 

Plants in the Pilot Projects

Page 38 GAO-13-775 USDA Inspection Pilot Projects

Figure 4: Location of Young Hog Plants in the Pilot Project and the Volume of Hogs Slaughtered, by State, in 2012

Note: Information on volumes was for the total live weight of hogs slaughtered commercially, which 

includes hogs slaughtered in federally inspected plants and other plants but excludes animals 

slaughtered on farms. USDA’s slaughter statistics did not distinguish between young and mature 

hogs. According to USDA, the agency did not publish all of the data by individual states to avoid 

disclosure in states with low slaughter volumes. These states were included in the “None or minimal 

slaughter” category and collectively slaughtered about 1 billion pounds of young hogs. The volume for 

Maryland included the slaughter information from Delaware, and the volume for New Hampshire 

included the slaughter information from other New England states—Connecticut, Maine, 

Massachusetts, Rhode Island, and Vermont. In 2012, in the 40 states where hogs were slaughtered 

and for which data were reported, the volumes slaughtered ranged from about 151,000 pounds to 

over 8.2 billion pounds per state.
Appendix III: Comments from the 

U.S. Department of Agriculture

Page 39 GAO-13-775 USDA Inspection Pilot Projects

Appendix III: Comments from the 

U.S. Department of Agriculture

See comment 2.

See comment 1.

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.
Appendix III: Comments from the 

U.S. Department of Agriculture

Page 40 GAO-13-775 USDA Inspection Pilot Projects

See comment 4.

See comment 3.
Appendix III: Comments from the 

U.S. Department of Agriculture

Page 41 GAO-13-775 USDA Inspection Pilot Projects

See comment 7.

See comment 6.

See comment 5.
Appendix III: Comments from the 

U.S. Department of Agriculture

Page 42 GAO-13-775 USDA Inspection Pilot Projects

See comment 9.

See comment 8.
Appendix III: Comments from the 

U.S. Department of Agriculture

Page 43 GAO-13-775 USDA Inspection Pilot Projects
Appendix III: Comments from the 

U.S. Department of Agriculture

Page 44 GAO-13-775 USDA Inspection Pilot Projects

The following are GAO’s comments on the U.S. Department of 

Agriculture’s letter dated August 15, 2013.

1. USDA commented that our report does not highlight what the agency 

considers to be the main objectives of the proposed rule to modernize 

poultry slaughter inspections—to reduce the risk of foodborne illnesses by 

focusing FSIS inspection activities on those tasks that advance the 

agency’s core mission of food safety. However, our report includes this 

information. For example, our report states, “according to the proposed 

rule, the modernization is intended to improve food safety and the 

effectiveness of poultry slaughter inspection systems, remove 

unnecessary regulatory obstacles to innovation, and make better use of 

the agency’s resources,” among other things. 

2. USDA commented that throughout our report we state that the purpose 

of the pilot projects was to “...deploy inspection resources more 

effectively...”. USDA further commented that, while this might have been 

true when the pilot projects were initiated in 1997, the agency’s thinking 

has evolved over the years to focus less on efficiencies and more on 

public health and food safety. We recognize that USDA’s descriptions of 

the pilot projects, as stated in the Federal Register notices, have evolved 

over the years. However, we believe that the purpose stated in our 

report—deploying inspection resources more effectively in accordance 

with food safety and other consumer protection requirements—remains 

valid because the Federal Register notices cited by USDA continue to 

mention the effective use of resources as a component of its pilot 

projects. Moreover, agency officials directed us to Federal Register 

notices because USDA could not provide us with documents defining the 

pilot projects’ purpose. As our report states, pilot programs can more 

effectively inform future program rollout when sound management 

practices are followed, including the development of an evaluation plan 

with well-defined, clear, and measurable objectives. 

3. USDA commented that we did not mention the validity of the agency’s 

approach for comparing food safety data. We modified our report to 

include this information. USDA also commented that we did not include a 

number of conclusions from a 2002 external review, which focused on the 

validity of using food safety, microbial, and other consumer protection 

(food quality) data to assess the accomplishments of young chicken 

plants participating in and those not participating in the pilot project. Our 

report acknowledges this external review, but looking at the validity of the 

performance measures the agency developed for the pilot project was 

beyond the scope of our review.

GAO Comments
Appendix III: Comments from the 

U.S. Department of Agriculture

Page 45 GAO-13-775 USDA Inspection Pilot Projects

4. We modified our report to clarify the footnote about the food safety 

performance standard.

5. We modified our report to clarify the description of how the data from 

young turkey plants were used in USDA’s risk assessment.

6. We modified our report to clarify USDA’s perspective on training and 

that this training discussion is specific to those plants participating in the 

pilot projects.

7. We modified our report to include a statement about USDA inspectors’ 

abilities to cite plants for noncompliance at plants not participating in the 

pilot project.

8. USDA commented that our discussion of line speed is misleading 

because, among other things, it implies that a higher line speed than the 

average used in the analysis would lead to additional costs of processing. 

We recognize that higher line speeds lead to lower per unit labor costs

and have not made statements to the contrary. However, we note that 

USDA did not incorporate the impact of a range in line speeds in its 

estimates of benefits to plants. These ranges in line speed are key 

parameters for estimating benefits to plants and would affect the labor 

costs of processing each carcass, as well as the number of carcasses 

processed and overall profits. We modified our report to clarify that 

although FSIS noted a range in line speed exists, it did not use a 

sensitivity analysis to calculate a range of annual net benefits to plants 

resulting from uncertainties in line speed.

9. USDA commented that our statement about how the agency plans to 

address some of the limitations in the cost-benefit analysis is not 

completely accurate. We modified our report to state that the agency 

plans to include a range for annual production cost savings in the revised 

cost-benefit analysis, which is part of the draft final rule. However, USDA 

also stated that the final rule will not provide a range of benefits to plants 

based on uncertainties in line speed. As explained above in comment 8, 

we believe line speed is a key parameter in the estimation of benefits to 

plants.
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 46 GAO-13-775 USDA Inspection Pilot Projects

J. Alfredo Gómez, (202) 512-3841 or gomezj@gao.gov.

In addition to the contact named above, Mary Denigan-Macauley 

(Assistant Director), Marie Bancroft, Kevin Bray, Stephen Carter, Barbara 

El Osta, Michele Fejfar, Diana C. Goody, Armetha Liles, Cynthia Norris, 

and Dae Park made key contributions to this report.

Appendix IV: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(361439)
Appendix IV: GAO Contact and Staff 

Acknowledgments

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