Humane Methods of Handling and Slaughter: Public Reporting on Violations Can Identify Enforcement Challenges and Enhance Transparency
Published: 2008-04-17T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In fiscal year 2007, more than 150 million cattle, sheep, and other animals destined for human consumption were slaughtered in the United States. The U.S. Department of Agriculture's (USDA) Food Safety and Inspection Service is responsible for enforcing the Humane Methods of Slaughter Act (HMSA), which mandates that animals are handled and slaughtered humanely. GAO reported on USDA's efforts to enforce HMSA in 2004 (Humane Methods of Slaughter Act: USDA Has Addressed Some Problems but Still Faces Enforcement Challenges, GAO-04-247). More broadly, GAO has also issued many reports that address federal oversight of the U.S. food safety system. This testimony focuses on (1) GAO's 2004 report on the frequency and scope of reported HMSA violations and enforcement actions by USDA, (2) information on trends in staffing and funding for USDA food inspections, and (3) information on overall federal oversight of food safety. To provide this new information, GAO analyzed personnel and funding data from USDA and the Office of Management and Budget, and interviewed USDA food safety inspection officials.
section_title: What GAO Found
paragraphs: In January 2004, GAO reported that incomplete and inconsistent inspection records made it difficult to determine the frequency and scope of HMSA violations, inspectors did not always document violations of the act, and they did not consistently document the scope and severity of each incident. GAO also reported that enforcement actions to address noncompliance with the act were inconsistent, and that USDA was not using consistent criteria to determine when to suspend plant operations in cases of serious or repeated violations. The Congress has urged USDA to report annually on trends in compliance with humane slaughter methods. Such public reporting can enhance transparency, but USDA's most recent report was in March 2003 and relied on incomplete data. For example, that report said very few infractions were for inhumane treatment, but GAO found that at least one-fourth of the infractions were for ineffective stunning which fails to meet humane standards. USDA has taken actions to address the recommendations GAO made in 2004 about oversight of HMSA. However, GAO has not evaluated the effectiveness of these actions. USDA faces resource challenges that may make it difficult for it to enforce HMSA and ensure the safety of the food supply. Although USDA's budget for food safety-related activities has increased since 1988, staffing for these activities has declined from its highest level in 1995. Agency officials noted the overall decline is due, in part, to consolidation in the meat industry, resulting in fewer facilities. In 2004, GAO found that USDA lacked detailed information on how much time its inspectors spend on humane handling and slaughter activities, making it difficult to determine if the number of inspectors is adequate. USDA has taken actions to address most of GAO's recommendations for assessing its resource needs for HMSA, but GAO has not evaluated these actions. Although not directly related to HMSA activities, the quantity of meat and poultry inspected and passed by USDA has grown, and the quantity of meat and poultry recalled has increased. USDA has oversight responsibility for ensuring the safety of meat, poultry, and processed eggs. For example, federal regulations prohibit companies from processing and selling meat from disabled cows--which have a higher probability of being infected with bovine spongiform encephalopathy--without explicit USDA inspector approval. However, USDA is only 1 of 15 agencies that collectively administer at least 30 laws related to food safety. This fragmentation is the key reason GAO added the federal oversight of food safety to its High-Risk Series in 2007 and called for a governmentwide reexamination of the food safety system. GAO has reported on problems with this system--including inconsistent oversight, ineffective coordination, and inefficient use of resources. Going forward, as GAO has recommended, a governmentwide, results-oriented performance plan and a reconvened President's Council on Food Safety could build a sustained focus on the safety of the nation's food supply.

section_title: Letter
paragraphs: I am pleased to be here today to discuss the U. S. Department of  Agriculture’s (USDA) implementation of its program to ensure that  animals destined for human consumption are handled and slaughtered  humanely. More than 150 million cattle, sheep, hogs, and other animals  ultimately destined to provide meat for human consumption were  slaughtered in fiscal year 2007, at some 700 federally inspected slaughter  facilities throughout the United States. The Food Safety and Inspection  Service (FSIS), within USDA, is responsible for enforcing the Humane  Methods of Slaughter Act (HMSA), which prohibits the slaughtering of  animals, or the handling of animals in connection with slaughtering, unless  it is humane. However, the recently documented inhumane treatment of  disabled cows slaughtered at the Westland/Hallmark plant in California  and the entry of their meat into the market calls into question FSIS’s  enforcement of the act. In particular, federal regulations prohibit  companies from processing and selling meat from disabled  (nonambulatory) cows without explicit FSIS inspector approval.  Nonambulatory cows raise particular concerns because they have a higher  probability of being infected with bovine spongiform encephalopathy,  commonly known as mad cow disease.
In 2004, we reported that FSIS was not adequately recording instances of  noncompliance with HMSA, and thus could not assure the Congress that it  was fully enforcing the act at federally inspected slaughter facilities.  Specifically, we found the following:  Incomplete and inconsistent inspection records made it difficult to  determine the frequency and scope of humane handling and slaughter  violations. Those inspection records showed that inspectors did not  always document violations of HMSA and that when they did, the  inspectors did not consistently document the scope and severity of each  incident. Enforcement actions to address noncompliance with the act and  regulations were also inconsistent.
FSIS officials were not using consistent criteria to suspend plant  operations. As a result, plants in different FSIS districts were not subject  to comparable enforcement actions.
FSIS lacked detailed information on how much time its inspectors spent  on humane handling and slaughter activities, making it difficult to  determine if the number of inspectors is adequate. In general, FSIS  officials believed that, with the introduction of a District Veterinary  Medical Specialist (DVMS) in 2002 at each of the agency’s field offices, the  number of personnel devoted to humane handling and slaughter  compliance was adequate.
Our 2004 report did not specifically assess FSIS’s effectiveness in  enforcing the humane handling and slaughtering provisions of HMSA, such  as those related to the Westland/Hallmark incident.
In this context, my testimony today focuses on (1) GAO’s 2004 report on  the frequency and scope of reported HMSA violations and enforcement  actions by USDA, (2) trends in staffing and funding for USDA food  inspections, and (3) GAO’s designation of federal oversight of food safety  to its High-Risk Series.
In summary, I would like to make three observations. First, FSIS has taken  actions to address the recommendations we made in our 2004 report to  improve its reporting of humane handling and slaughter methods at  federally inspected facilities. These recommendations principally dealt  with weaknesses in FSIS’s internal reporting of the frequency and scope of  HMSA violations. However, without further evaluation and public  reporting to enhance transparency and accountability, we do not know the  effectiveness of these actions.
Second, although the FSIS budget has increased since 1988, staffing levels  have declined since 1995, and some districts have experienced high  vacancy rates among inspectors, possibly impairing enforcement of HMSA  and food safety regulations generally. Meanwhile, the volume of meat and  poultry inspected and passed by FSIS has grown, along with the number of  pounds of recalled meat and poultry. Staff levels are expected to rise  slightly in 2008 as FSIS fills vacant positions.
Third, USDA’s FSIS is only 1 of 15 agencies that collectively administer at  least 30 laws related to food safety. This fragmentation is the key reason  GAO added the federal oversight of food safety to its High-Risk Series in  2007 and called for a governmentwide reexamination of the food safety  system. The fragmentation results in federal resources for food safety  being directed to multiple agencies. For example, the majority of federal  expenditures for food safety inspection were directed toward USDA’s  programs for ensuring the safety of meat, poultry, and egg products, even  though USDA is responsible for regulating only about 20 percent of the  food supply.
This testimony is based on new and previously issued work. To analyze  trends in FSIS resources, we examined personnel and funding data from  FSIS and the Office of Management and Budget for the past 20 years and  determined they were sufficiently reliable for our analyses. To provide  updated information on our previously issued reports, we interviewed  FSIS officials and gathered information on the status of our  recommendations. We conducted our work from April 2 through April 14,  2008, in accordance with generally accepted government auditing  standards. These 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 obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: The Congress passed the Humane Slaughter Act in 1958 following intense  and broad-based public concerns about cruelty and abuse of livestock in  meat-packing plants. At that time, the Congress determined that using  humane methods of slaughter prevented the needless suffering of  livestock, resulted in safer and better working conditions for employees,  and brought about improvements in products and economies of slaughter  operations, among other benefits. However, the act was limited to federal  government agencies, which were required to contract for or procure meat  products only from producers and processors that employed humane  slaughtering methods in all of their plants. In 1978, the Congress passed  HMSA, which required that all federally inspected slaughter  establishments adopt humane handling and slaughter methods.
FSIS has issued regulations and directives to enforce the act. Important  requirements of these regulations and guidance include the following:    Animals stunned before slaughter must be rapidly and effectively rendered  insensible before they are slaughtered. Stunning is effective when the  animal feels no pain, is rendered instantly unconscious, and remains  unconscious until slaughtered.
Dragging of disabled and other animals unable to move while conscious is  prohibited.
All holding pens and driveways and ramps must be designed, built,  and maintained to prevent injury to livestock.
Livestock should be provided with access to water in holding pens, and  food if held for more than 24 hours.
The use of electrical prods and other devices to move livestock must not  be excessive.
FSIS is responsible for ensuring compliance with HMSA. FSIS is also  responsible for ensuring the safety of most meat, poultry, and processed  egg products at federally inspected facilities. Currently, FSIS employs in- plant about 7,800 inspectors—that is, public health veterinarians, food  inspectors, and consumer safety inspectors. These inspectors work  collaboratively, and are responsible for inspecting animals prior to  slaughter, as well as the carcasses after slaughter, in order to ensure the  food is safe for human consumption. According to FSIS officials, as  inspectors carry out their food safety and other activities, they are  responsible for monitoring compliance with humane handling and  slaughter requirements at plants that are covered by HMSA. According to  FSIS, while HMSA requires inspectors to observe the entire handling and  slaughter process, inspectors do not have to observe all animals all the  time for HMSA compliance.
When inspectors observe a violation of HMSA or its implementing  regulations, they are required to notify plant management and document  the violation.
In response to HMSA noncompliance, FSIS can take a number  of enforcement actions, which impose restrictions on a facility’s ability to  operate, including the following:    For less serious violations of HMSA, inspectors at a facility can issue a  “reject tag” to quickly respond to violations that are limited in scope.  Inspectors place these reject tags on a piece of equipment or an area of the  plant, prohibiting use until the violation is corrected.
For more serious violations, the district manager can suspend inspection  until violations are addressed. This usually results in suspended  operations at the facility (or part of the facility) because without federal  inspections the facility’s products are prevented from entering interstate  and foreign commerce.
In the rare cases where a plant fails to respond to FSIS concerns about  repeated or serious violations, the administrator of FSIS can withdraw  inspection. This removes the grant of inspection from a facility, preventing  its products from entering interstate and foreign commerce. The facility  must reapply for and be awarded a grant of inspection before federal  inspections may resume.
section_title: FSIS Has Taken Actions Intended to Improve Its Records on Humane Slaughter Violations, but Public Reporting Can Enhance Transparency
paragraphs: In 2004, we identified weaknesses in FSIS’s regulations and guidance for  recording compliance with HMSA in key areas: (1) the frequency and  scope of humane handling and slaughter violations, and (2) actions to  enforce compliance with humane handling and slaughter provisions. FSIS  has taken steps to improve its reporting of humane handling and slaughter  violations. However, although the Congress has urged USDA to report  annually on violations and trends in compliance, USDA has not issued  such a report since March 2003. Such public reporting can enhance  transparency.
In 2004, we reported that incomplete and inconsistent FSIS inspection  records made it difficult to determine the frequency and scope of humane  handling and slaughter violations. Available FSIS records showed that  during the 28 months between January 2001 and March 2003, inspectors  wrote 553 noncompliance records to document violations of HMSA and  the implementing regulations at 272 facilities across the United States.  According to these inspection records, ineffective stunning, which does  not quickly render animals insensible to pain, and in many cases results in  a conscious animal reaching slaughter, was the most prevalent type of  noncompliance. To a lesser extent, the records showed incidents of, in  declining order of prevalence: poor facility conditions, failure to provide  water to animals awaiting slaughter, excessive force, and excessive use of  electric prods. However, in conducting this analysis, we found internal  control problems that call into question the reliability of FSIS records  regarding compliance with the act. First, because the agency had not  stored its noncompliance records in electronic form, it could not provide  us with at least 44 of the 553 records from January 2001 through March  2003. Second, almost half of the DVMSs we interviewed at the time of our  review reported that inspectors did not always document noncompliance  when they should have because they were unsure about regulatory  requirements. Third, the noncompliance records did not consistently  document the scope and severity of violations. For example, some  noncompliance records mentioned that ineffective stunning occurred, but  did not provide the cause of the violation or the number of animals  affected.
We also reported FSIS took inconsistent enforcement actions to address  noncompliance with HMSA. Inspectors stationed in slaughter plants had  not consistently issued reject tags, which temporarily halt operations in all  or part of a plant. Several of the DVMSs we interviewed attributed the  inconsistent enforcement actions to inspectors’ inexperience, lack of  clarity regarding their authority, or the misperception that certain  violations were minor. We found similar inconsistencies at the district  management level. District managers can decide to take the more serious  enforcement action of withdrawing inspectors from the plant, most likely  suspending a plant’s operations, when they are notified of serious  violations. However, they lacked clear criteria on when to do so, which  can lead to inconsistent enforcement. We found, for example, one case in  which a district manager did not suspend inspections after inspectors had  issued 16 noncompliance records to a slaughter facility documenting the  plant’s failure to properly stun animals. In contrast, another  facility’s failure to provide access to water and to maintain acceptable  pen conditions led to a suspension of operations. As a result, FSIS could  not ensure that humane slaughter requirements are consistently  enforced across districts, a fact that undermines FSIS efforts to enforce  the act.
To provide more useful information and to help strengthen oversight of  HMSA, we recommended in 2004 that the Secretary of Agriculture direct  FSIS to (1) include in noncompliance records specific information on the  type and cause of violations, (2) establish additional criteria for when  districts are to take enforcement actions in cases of repetitive violations,  and (3) require that district offices and inspectors clearly document the  basis for enforcement actions that they take in response to  repetitive violations, among others. In response to these recommendations  FSIS took steps intended to strengthen its oversight of humane handling  and slaughter methods at federally inspected facilities. In particular, it has  issued additional guidance to its district offices and inspectors to assist  them in determining when to take enforcement actions for repeated  violations. The guidance includes, among other things:    categories for the types and causes of humane handling and slaughter  violations to be reported on noncompliance records;   questions inspection personnel should use to assist them in determining  when a noncompliance trend exists; and   examples of noncompliance activities affecting an animal’s safety or  constituting inhumane treatment of an egregious nature that would  warrant immediate enforcement by inspection personnel.
Although the agency’s actions were responsive to our recommendations,  without further evaluation, we do not know the effectiveness of these  actions.
Finally, FSIS has not reported annually on trends in compliance with  humane slaughter methods, as urged by the Congress, and its most recent  data on violations were incomplete. Public reporting is the means through  which the federal government communicates the results of its work to the  Congress and the American people. Such reporting is in the public interest  and promotes transparency in government operations. In 2002, the  Congress urged the Secretary of Agriculture to fully enforce the Humane  Methods of Slaughter Act and report annually to the Congress on the  number of violations and trends recorded by FSIS inspectors. According  to FSIS officials, in response to the Congress and as part of its annual  appropriations process, USDA has provided the House and Senate  appropriations committees information on the number of suspensions as  well as general information on HMSA activities. However, in recent years,  USDA has not reported to the Congress on the number of violations and  trends recorded by its inspectors. In its most recent report, in March 2003,  USDA indicated to the Congress that during fiscal year 2002, “very few  infractions were for actual inhumane treatment of the animals.” However,  we identified shortcomings in the data used to make this finding. At the  time of our review, officials told us that the statement was based on a  sample of approximately half of the noncompliance records available. In  contrast, our analysis of all of the noncompliance records FSIS provided  for fiscal year 2002 showed that one-fourth of the 366 noncompliance  incidents documented by inspectors were for incidents of ineffective  stunning which fails to meet humane standards in USDA regulations. Lack  of complete and consistent data can make it difficult for FSIS to accurately  assess compliance with the act, and prevents transparency in the reporting  of violations.
section_title: FSIS’s Budget Has Increased as Staffing Has Declined
paragraphs: Unlike the budgets of other federal agencies responsible for food safety,  the budget for FSIS has seen a marked increase since 1988. As shown in  figure 1, the agency’s budget authority increased from $392 million in fiscal  year 1988 to $930 million in fiscal year 2008, or 137 percent. When adjusted  for inflation, the increase is about 47 percent.
The Administration’s proposed fiscal year 2009 budget calls for an increase  in FSIS’s funding to $952 million. When adjusted for inflation, the  proposed increase is about $4 million, or 0.5 percent.
While FSIS’s budget authority has significantly increased since the late  1980s, the number of FSIS employees has declined. As shown in figure 2,  from fiscal year 1995 to fiscal year 2007, the number of full-time employees  at FSIS fell from about 9,600 to about 9,200, or 4 percent. Vacancy rates  across FSIS have declined to about 7 percent, and for its inspector  positions vacancies have declined to about 4 percent. However, 2 of the  agency’s 15 districts—Boulder and Des Moines—reported vacancy rates  among their inspector positions of about 22 percent and 11 percent,  respectively. As the figure also shows, staff levels are expected to rise  slightly in 2008 as FSIS fills vacant positions. Agency officials noted the  overall decline is due, in part, to consolidation in the meat industry,  resulting in fewer facilities, and the introduction of the Hazard Analysis  and Critical Control Point system, which is a risk-based effort to reduce  food contamination.
Furthermore, in 2004 we reported FSIS did not have data on the number of  inspectors devoted to compliance with HMSA or on the amount of time  that inspectors spend on humane handling and slaughter requirements.  Without such information, FSIS could not determine the appropriate  number of inspectors for different-sized plants or the number of inspectors  needed overall to effectively enforce the act.
We recommended that FSIS (1) develop a mechanism for determining the  level of resources that the agency devotes to humane handling and  slaughter activities, (2) develop criteria for determining the appropriate  level of inspection resources, and (3) periodically assess whether that  level is sufficient to effectively enforce the act. In response to these  recommendations, FSIS took steps intended to improve its monitoring of  resources needed to ensure compliance with HMSA. Specifically, FSIS  implemented a system that tracks inspectors’ time spent verifying that  humane handling and slaughter requirements are met,   developed policy that instructs FSIS managers to use data on the amount  of time devoted to humane handling and slaughter activities to assist in  inspection resource planning, and   established performance measures and targets to compare against time  spent on daily activities to enforce compliance with HMSA.
Again, these actions were responsive to our recommendations, but  without further evaluation, we do not know the effectiveness of these  actions.
Although not directly pertaining to FSIS’s enforcement of HMSA, the  quantity of meat and poultry inspected by the agency, as well as the  quantity of meat and poultry recalled, identifies some of the current  challenges the agency faces. Meat and poultry consumption in the United  States has increased sharply. As shown in figure 3, the quantity of meat  and poultry inspected and approved by the agency has increased from  about 65 billion pounds in 1988 to more than 100 billion pounds in 2007.  Much of the increase is due to the expanding U.S. poultry market.
Although the number of recalls has declined in recent years, the quantity  of meat and poultry recalled has increased sharply. Meat and poultry  product recalls declined from 125 in 2002 to 58 in 2007. However, 2 of the 6  biggest meat recalls in U.S. history have occurred in the past 6 months. In  October 2007, Topps Meat Company LLC announced the recall of 22  million pounds of ground beef used for frozen hamburgers due to E. coli  contamination. At the time, the Topps recall was the fifth largest in U.S.  history. The E. coli-contaminated meat sickened at least 32 people in eight  states. On February 17, 2008, Westland/Hallmark Meat Company  announced the recall of more than 143 million pounds of beef, the largest  recall in U.S. history. The quantity of meat and poultry recalled has  increased from 5 million pounds in 1994, the first year for which data were  readily available, to 145 million in just the first quarter of March 2008.
section_title: Federal Oversight of Food Safety Is a High- Risk Area that Needs Governmentwide Reexamination
paragraphs: While today’s hearing focuses specifically on FSIS’s responsibilities for the  oversight of food safety, it is important to note that FSIS is 1 of 15 federal  agencies that collectively administer at least 30 laws related to food safety.  This fragmentation is a key reason we designated federal oversight of food  safety as a high-risk area. Primary responsibility for food safety lies with  USDA—which has oversight responsibility for meat, poultry, and  processed egg products—and the Food and Drug Administration (FDA)— which is responsible for the safety of virtually all other foods. In addition,  among other agencies, the National Marine Fisheries Service (NMFS) in  the Department of Commerce conducts voluntary, fee-for-service  inspections of seafood safety and quality; the Environmental Protection  Agency (EPA) regulates the use of pesticides and maximum allowable  residue levels on food commodities and animal feed; and the Department  of Homeland Security is responsible for coordinating agencies’ food  security activities. This federal regulatory system for food safety, like  many other federal programs and policies, evolved piecemeal, typically in  response to particular health threats or economic crises.
In 2007, we added the federal oversight of food safety to our High-Risk  Series, which is intended to raise the priority and visibility of government  programs that are in need of broad-based transformation to achieve  greater economy, efficiency, effectiveness, accountability, and  sustainability. Over the past 30 years, we have reported on issues—for  example, the need to transform the federal oversight framework to reduce  risks to public health as well as the economy—that suggest that the federal  oversight of food safety could be designated as a high-risk area. The  fragmented nature of the federal food oversight system suggests the  government could plan more strategically to inspect food production  processes, identify and react more quickly to outbreaks of foodborne  illnesses, and focus on promoting the safety and integrity of the nation’s  food supply.
While we have reported on problems with the federal food safety system— including inconsistent oversight, ineffective coordination, and inefficient  use of resources—most noteworthy for today’s hearing is that federal  expenditures for the oversight of food safety have not kept pace with the  volume of foods regulated by the agencies or consumed by the public. We  have reported that four agencies—USDA, FDA, EPA, and NMFS—spent a  total of $1.7 billion on food safety-related activities in fiscal year 2003.  USDA and FDA were responsible for nearly 90 percent of those federal  expenditures. However, the majority of federal expenditures for food  safety inspection were directed toward USDA’s programs for meat,  poultry, and egg products even though those programs cover only about 20  percent of the food supply. In contrast, FDA accounted for only 24 percent  of expenditures even though it is responsible for regulating about 80  percent of the food supply.
Others have called for fundamental changes to the federal food safety  system overall. In 1998, the National Academy of Sciences’ National  Institute of Medicine concluded that the system is not well equipped to  meet emerging challenges. In response to the academy’s report, the  President established a Council on Food Safety, which released a Food  Safety Strategic Plan in January 2001. The plan recognized the need for a  comprehensive food safety statute and concluded, “the current  organizational structure makes it more difficult to achieve future  improvements in efficiency, efficacy, and allocation of resources based on  risk.”
Taken as a whole, our work indicates that the Congress and the executive  branch can and should create the environment needed to look across the  activities of individual programs within specific agencies, including USDA,  and toward the goals that the federal government is trying to achieve. To  that end, we have recommended, among other things, that the Congress  enact comprehensive, uniform, and risk-based food safety legislation and  commission the National Academy of Sciences or a blue-ribbon panel to  conduct a detailed analysis of alternative organizational food safety  structures. We have also recommended that the executive branch  reconvene the President’s Council on Food Safety to facilitate interagency  coordination on food safety regulation and programs. According to  documents on the council’s Web site, the current administration has not  reconvened the council.
These actions can begin to address the fragmentation in the federal  oversight of food safety. Going forward, to build a sustained focus on the  safety and integrity of the nation’s food supply, the Congress and the  executive branch can develop expectations for food safety and follow up  with congressional oversight and strategic planning by agencies, including  USDA. We have previously reported that a governmentwide performance  plan that is mission based and results oriented would help ensure agency  goals are complementary and mutually reinforcing. Furthermore, this plan  would help decision makers balance trade-offs and compare performance  when making resource allocations and restructuring decisions.
Mr. Chairman, this concludes my prepared statement. I would be happy to  respond to any questions that you or Members of the subcommittee may  have.
Contact points for our Offices of Congressional Relations and Public  Affairs may be found on the last page of this testimony. For further  information about this testimony, please contact Lisa Shames, Director,  Natural Resources and Environment (202) 512-3841 or shamesl@gao.gov.  Key contributors to this testimony were Thomas Cook, Assistant Director;  Kevin Bray; Mary Denigan-Macauley; Leslie Mahagan; Ben Shouse; Carol  Herrnstadt Shulman; and Tyra Thompson.
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