Second, I-ask that this request and three of FWW’s pending FOIA requests, 18-46, 18-64, and
18-149, receive expedited processing, as indicated in the attached certification.

I will expect as expedited response within 10 days, as provided by law.

Thank you for your prompt attention to this matter. Please contact me at (202) 683-2451 or
zeorrigan@fwwatch.org if you have any questions.

Sincerely,

Zachary B. Corrigan
Senior Staff Attorney

Food & Water Justice Program
Food & Water Watch

zcorrigan@fwwatch.org



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MEEMEEEEENIN Food & Waler Watch « 1616 P SI. NW, Suite 300 * Washington, DC 20036 foodawaterwatch
T +202,683.2500 * F +202.683.2501 * www.foodandwaterwatch.org Nace

Freedom of Information Act Officer Received in USDA/FSIS
Freedom of Information Act Officer
USDA, Food Safety and Inspection Service

Room 2168 South Building FEB 2 3 2018
1400 Independence Ave., SW .
Washington, DC 20250 FOIA Office

Delivered via email at fsis.foia@usda.gov on February 23, 2018
Dear FOIA Officer:

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. § 552, I hereby submit the
following FOIA request and ask that that the United States Department of Agriculture (USDA
or agency) process these and three other pending FOIA requests in an expedited matter, as
detailed below.

First, I request that the agency provide me the following:

1. All records, including all correspondence, memos, notes of telephone calls,
electronic messages transcripts, minutes and notes of meetings and/or other
memorializations detailing the process and criteria for selecting the 21 non-HIMP.
plants studied as part of Food Safety and Inspection Service (FSIS)’s “Evaluation of
the HACCP Inspection Models Project for Market Hogs” report (Hog HIMP Report)
(located at https://www. fsis.usda.gov/wps/wem/connect/f7be3e74-552f-4239-ac4c-

59a024fd0ec2/Evaluation-HIMP-Market-Hogs.pdf?7MOD=AJPERES).
2. To the extent that any exist, any records that provide the estimated line speeds for

the five Hog HIMP plants and 21 non-HIMP plants studied as part of FSIS’s Hog
HIMP Report in calendar years (CY) 2010-2012, CY 2013, and either Fiscal Year
(FY) or CYs 2014-2017.

3, To the extent that any exist, any record that provides the number of inspection
procedures performed per establishment in the five HIMP and 21 non-HIMP
facilities under PHIS in CYs 2012 through 2017 (along with the totals and total
SSOP and HACCP procedures), as the agency’s Hog HIMP Report provided for
PBIS in Table 3-1 for CY 2010; and to the extent that no such records already exists,
any records in spreadsheet form that detail the number of inspection procedures
performed at the five HIMP and 21 non-HIMP facilities under PHIS in CYs 2012-
2017.

4. Any records in spreadsheet form that provide the number of regulation verifications
(for all inspections regulations) performed per establishment in the five HIMP,
plants, 21 non-HIMP facilities, and all market hog establishments for CYs 2006-
2017.

5. Any records in spreadsheet form that provide the number of Public Health
Regulations (PHR) verifications, applicable to market hogs for each year performed,
per establishment, in the five HIMP and 21 non-HIMP facilities for CYs 2013-2017,
as the agency’s Hog HIMP Report provided for with the 2012 and 2013 PHR
verifications in Tables 3-4 through 3-5 for CY 2012-2013.



10.

13.

14.

15.

16,

All records that provide the analysis for this agency conclusion on page 21 of the
Hog HIMP Report; “The sorting rates in HIMP market establishments by
establishment sorters are statistically significantly higher than condemnation rates in
non-market Hog establishments for [2012-2013].”

To the extent that any exist, any records that show the sorting and condemnation
rates in the five HIMP and 21 non-HIMP facilities for CYs 2014-2017, as the
agency’s Hog HIMP Report provided for CY 2012-2013 in Table 3-7; and to the
extent that no such records already exists, any records in spreadsheet form that detail
the number of carcasses sorted and condemned at the five HIMP and 21 non-HIMP
facilities for CYs 2014-2017.

To the extent that any exist, any records that show the PHR Noncompliance Rates
(NRs) in the five HIMP and 21 non-HIMP facilities for CYs 2014-2017 based on the
PHRs for that particular year, as the agency’s Hog HIMP Report provided for CY
2012-2013 in Table 3-10.

To the extent that any exist, any records that show the FS-2 NRs in the five HIMP
and 21 non-HIMP facilities for CY 2014-2017, as the agency’s Hog HIMP Report
provided for CY 2012-2013 in Table 3-13.

Any records that show the OCP and FS performance standards in the five HIMP
facilities for CYs 2014-2017, as the agency’s Hog HIMP Report provided for CY
2009 and CY 2012-2013 in Tables 3-15 through 3-16.

. Any records that show the Nationa] Residue Sampling Directed and Inspector-

Generated Sampling in the five HIMP facilities for CYs 2014-2017, as the agency’s
Hog HIMP Report provided for CYs 2006-2010 and 2012-2013 in Tables 3-19
through 3-20.

. For such chemical testing listed above in item 11 and the testing for years provided

in Hog HIMP report Tables 3-19 through 3-20, all data showing the number of
suspected carcasses for testing, the number of actually carcasses condemned, the
number of eligible carcasses for KIS tests, and the number of KIS test actually
performed for each plant by district,

Any copies of the agency’s “Assessment of the Potential Change in Human Risk of
Salmonella Illnesses Associated with Modernizing Inspection of Market Hog
Slaughter Establishments” (Risk Assessment) currently located at

https://www. fsis.usda.gov/wps/wem/connect/0c03ed4d-68bf-4bd9-80e0-
b8f3aa6ffl Ge/ModernizationSwineS laughterRiskAssessment.pdf?7MOD=AJPERES
with a complete set of data tables where the data is not cut off (see page 55, 90, e.g.)
Any workplace injury analysis performed by the agency in support of the New Swine
Inspection System proposed rule, 83 Fed. Reg. 4,780 (Feb. 1, 2018)(“NSIS proposed
rules”)

Any analysis of Humane Methods of Slaughter Act violations referenced in the NSIS
proposed rules,

Any records detailing the analysis of the swine slaughter inspection systems of Denmark
and the Netherlands, as referenced in the NSIS proposed rules.

. Any records detailing and analyzing the operations of the Canadian establishments

operating under the HACCP-based Inspection Program (“HIP”) for swine slaughter,
including but not limited to all import rejections since March 2006 from these plants
and all records detailing the deficiencies found by FSIS audit staff of the HIP
inspection system during the agency’s September 12-30, 2016 Canadian Audit.



18. Any records identifying the 40 swine slaughter plants the agency expected to opt
into the New Swine Slaughter Inspection System, along with all inspection data,
microbiological and residue testing, and food safety assessments for these plants
dating from CY 2006 to present.

19. Any records of Salmonella test results collected for the FSIS Nationwide Market
Hogs Microbiological Baseline Data Collection Program.

20. Any records of Salmonella test results underlying Table 2 in the Risk Assessment (at
p- 22), and records sufficient to indentify which data were used to calculate each
figure presented in the table.

21. All records, including all correspondence, memos, notes of telephone calls,
electronic messages transcripts, minutes and notes of meetings and/or other
memorializations detailing the process and criteria for selecting establishments from
which routine microbiological data was analyzed for the following figures in Table 2
identified. in item 20 above: the non-HIMP plants (16 plants), the HIMP plants (4
plants), and the 35 Large and Small non-HIMP establishments (undisclosed number
of plants),

22. Any records identifying any market-hog establishment that was using antimicrobial
chemicals at the end of the slaughter process and prior to the “post-chill” testing,
during any of the data collection underlying the Table 2 Summary in item 20 above;
the type of chemical intervention the establishment used; and the dates on which the
establishment used the intervention,

23. Any records identifying which establishments, from which data was collected for
Table 2 identified in item 20 above, were using a hot-boning process at the end of
the slaughter process‘and/or any establishment at which the “post-chill” data was
taken before the carcass entered the cooler.

24, Any records identifying the non-market hog slaughter plants the agency believes will
convert to NSIS and the criteria the agency plans to use for conversions.

25. Any records containing data that the agency has on Salmonella rates in market hogs
compared to non-market hogs.

26. All Salmonella Initiative Program (SIP) waivers granted to swine slaughter plants
and the microbiological testing data provided to the agency as a result of the waivers

27. Any records providing any analysis of the plants that the agency believes will have
two off-line FSIS. inspectors under NSIS and the criteria to be used to make that
determination.

Tam requesting these records as a representative of Food & Water Watch, a non-profit
consumer advocacy organization. I request a waiver of fees because my interest in the records
is not primarily commercial, and disclosure of the information will contribute significantly to
public understanding of USDA inspections and plant performance with these inspections under
Hog HIMP and such inspections and plant performance under the recently proposed New Swine
Inspection System rules.

If my request is denied in whole or in part, I expect a detailed justification for withholding the
records. As part of this, FWW asks that the agency detail which records it provides are
responsive to each numbered item above and, to the extent that the agency does not have
responsive records for each request, that it indicates that it does not have such records. FWW
also requests any segregable portions that are not exempt to be disclosed. FWW consents to a
rolling release of records if necessary.