Contamination of product by rust, condensation, and other foreign material from deteriorated or poorly maintained overhead structures. (See pp. 15 and 34.)

Examples illustrating sanitation problems at federally inspected and nonfederally inspected plants visited by GAO are located on pages 16 to 30 and pages 34 to 40, respectively.

At the plants visited, Consumer and Marketing Service inspection personnel had not consistently

rejected for use equipment and plant areas or suspended inspection in federally inspected plants when unsanitary conditions were found; and recommended the withdrawal of Federal grading services at nonfederally inspected plants that were found operating under unsanitary conditions. If Federal inspection service is suspended, a plant cannot slaughter animals or process meat for movement in interstate commerce. The withdrawal of grading service from a nonfederally inspected plant precludes the plant's using any official mark or other identification of the Federal grading service. (See pp. 6 and 8.)

GAO was unable to ascribe to any one cause the failure of inspection personnel to require plant managements to promptly and effectively correct unsanitary conditions. GAO believes, however, that a primary cause of the lack of uniformity and leniency in enforcement of sanitation standards was a lack of clear and firm criteria setting forth the actions to be taken when unsanitary conditions were found.

GAO believes that weaknesses in the Consumer and Marketing Service's system for reporting on plant reviews also contributed to the inadequate enforcement of sanitation standards at federally inspected plants. Because reports generally did not show what action, if any, was taken to correct reported unsanitary conditions, information was not readily available to Consumer and Marketing Service management as to whether appropriate and timely corrective actions were required by inspection personnel. (See p. 41.)

Clear and firm criteria-setting forth the actions to be taken when unsanitary conditions are found-and improved reporting policies can provide a basis for improving the enforcement of sanitation standards at meat plants. In the final analysis, GAO believes that the effectiveness with which such standards are enforced will be dependent on the resolve of Consumer and Marketing Service personnel at each and every level-from the plant inspectors to the Washington officials.

RECOMMENDATIONS OR SUGGESTIONS

The Administrator of the Consumer and Marketing Service should reemphasize to individual employees at all levels their responsibilities for the enforcement of regulations to ensure that meat and meat food products are wholesome and unadulterated.

To assist employees at all levels in carrying out their responsibilities the Administrator should establish

criteria setting forth specific conditions under which inspection and grading services should be suspended at plants in violation of sanitation standards and under which equipment and specific plant areas in federally inspected plants should be rejected for use until made acceptable; and

a uniform reporting policy whereby action taken and to be taken will be a required part of all reports pertaining to observed sanitation deficiencies. (See p. 42.)

AGENCY ACTIONS AND UNRESOLVED ISSUES

The Administrator of the Consumer and Marketing Service (see app. I) stated that:

The conditions described in GAO's report are of deep concern to the Department of Agriculture, and the Department is and has been determined to eliminate such threats to the wholesomeness of the Nation's meat and poultry products.

The emphasis and objectives of the major inspection improvement program already under way and now being intensified in the Consumer and Marketing Service are completely in line with and responsive to GAO's recommendations.

Much has been accomplished but much remains to be done.

With respect to specific actions taken and planned, the Administrator stated that:

A letter had been directed to all Consumer Protection Program personnel clearly outlining inspection objectives and procedures regarding sanitation and assuring each employee of full support for his efforts in enforcing sanitation standards.

Meetings would be held with committees from major meat packer organizations for the purpose of reemphasizing meat inspection objectives and developing an educational program for their membership on the whole spectrum of meat inspection, particularly sanitation.

Revised procedures, forms, and instructions had been issued to assist inspectors in carrying out the Consumer and Marketing Service's policy at plants where unsanitary conditions are found, including criteria for withholding or suspending inspection for cause.

The Administrator also provided detailed information on enforcement actions taken as a result of the inspection improvement program. He stated that, although the record demonstrates progress during the past year, the need for still further action is acknowledged.

The action needed will be determined by a management study now under way to determine improvements needed in administration. This study is expected to have strong impact on carrying out GAO's recommendation relating to improved reporting systems to demonstrate actions taken.

The Administrator provided the following report on the status of the 48 plants visited by GAO as determined by recent Consumer and Marketing Service plant visits.

Federal inspection has been discontinued at five of the 40 federally inspected plants.

Conditions of sanitation in 27 of the federally inspected plants have been so improved as to meet Consumer and Marketing Service sanitary requirements.

Two of the eight nonfederally inspected plants ceased operations following withdrawal of recognition for Federal grading service.

Four nonfederally inspected plants' operating conditions are now acceptable.

In the remaining eight federally inspected plants and the two non-federally inspected plants, action has been taken to protect the product while the remaining needed plant improvements are being completed.

GAO believes that the actions already taken and the further actions outlined by the Administrator, if fully implemented, substantially comply with its recommendations and will provide greater assurance to the consuming public that meat products are processed under sanitary conditions. GAO believes, however, that, even with the intensified enforcement actions planned by the Consumer and Marketing Service, continuing efforts of all inspection personnel to require compliance with sanitation standards are vital to maintaining the integrity of the inspection program and ensuring the consumer public of a wholesome product.

MATTERS FOR CONSIDERATION BY THE CONGRESS

This report discusses matters of such importance to the consuming public that the Congress may wish to consider the facts revealed and the steps being taken to correct the situation.

APPENDIX F

[Comptroller General's report to Congress: Digest]

CONSUMER AND MARKETING SERVICE'S ENFORCEMENT OF FEDERAL SANITATION STANDARDS AT POULTRY PLANTS CONTINUES TO BE WEAK

WHY THE REVIEW WAS MADE

The General Accounting Office (GAO) made this follow-up review at poultry plants to determine whether the Consumer and Marketing Service had improved the enforcement of sanitation standards after GAO's earlier reviews. This review covered 68 federally inspected plants, including 17 of the 40 plants GAO covered in its prior review and 51 plants selected at random from five of the leading poultry slaughtering and processing States. The 68 plants accounted for about 19 percent of the 13 billion pounds of poultry slaughtered in the United States in calendar year 1970.

FINDINGS AND CONCLUSIONS

Enforcement of sanitation standards still weak

Following GAO's earlier reviews, the agency took some actions to improve the enforcement of sanitation standards, including:

Sending letters to its inspection program employees, including plant and supervisory inspectors, clearly outlining inspection objectives and sanitation procedures and assuring each employee full support for his efforts in enforcing sanitation standards.

Issuing revised procedures, forms, and instructions, including criteria for withholding or suspending inspection, to assist inspectors in carrying out. the agency's policies. (See p. 12.)

The actions taken by the agency have not been successful in achieving adequate enforcement at the plants GAO visited. For each of the 68 plants, supervisory inspectors, who accompanied GAO and evaluated each plant for compliance with the agency's standards, reported some deficiencies. The types and extent of the deficiencies, classified as either minor variations or unacceptable conditions, varied from plant to plant.

The evaluations showed that unacceptable conditions:

Continued to exist at most of the 17 plants covered in GAO's prior review. In many cases the conditions were similar to those previously noted.

Existed at most of the 51 randomly selected plants. At many of these plants, the conditions appeared to be of a long-standing nature and were similar to conditions noted at most of the 17 plants.

Four case studies illustrating the types of sanitation problems at the plants GAO visited are included on pages 19 through 39.

After most of GAO's fieldwork had been completed, the agency implemented a revised regulation providing criteria on the amount of moisture which may be absorbed and retained in poultry during processing. When the amount of moisture absorbed is determined to be above the specified limits, the inspector is to require that all poultry processed be held and drained to acceptable levels. Because of the timing of the regulation's implementation, GAO did not determine how well it was being implemented. (See p. 48.)

Conclusions

Many of the sanitation deficiencies appeared to have existed over a long period. In GAO's opinion, this situation is indicative of a lack of strong, day-to-day enforcement by the agency's plant inspectors and of a lack of effective supervisory review. Weaknesses in the agency's enforcement of sanitation standards may be widespread.

Adequate criteria and policies now exist for enforcing sanitation standards. Such criteria and policies, however, provide only a basis for improving enforcement. In the final analysis the effectiveness with which sanitation standards are enforced depends on the resolve of the agency's employees at every level-from plant inspectors to Washington officials.

Ways must be found to demonstrate convincingly to the agency's inspection employees that consumer protection is the main objective of enforcing sanitation standards and that strict enforcement of such standards is essential. (See p. 41.)

RECOMMENDATIONS OR SUGGESTIONS

In August 1970 two consultants hired by the Department of Agriculture completed a study of the agency's consumer protection programs. The consultants recommended a number of changes for reorganizing the programs. Most of the recommendations were adopted; however, one recommendation-that a separate agency be established within the Department for consumer protection programswas not. The consultants stated that the recommendation was predicated on their belief that:

There is an inherent difference between the nature of the agency's marketing activities and that of its consumer protection activities which creates an internal conflict.

Consumer protection is so large an area and has such complex problems that it needs a full-time administrator.

GAO recommends that the Secretary of Agriculture reevaluate the consultants' recommendation because GAO believes that implementation of the recommendation would demonstrate convincingly that the Department was placing emphasis on consumer protection.

77-615-72-24

GAO recognizes that, should the Department adopt the consultants' recommendation, its full implementation would take some time. Also, if a separate agency were established within the Department, many of the employees now responsible for enforcing sanitation standards would continue to be responsible.

For these reasons GAO recommends also that the Secretary explore other and more immediate avenues to improve and emphasize the enforcement of sanitation standards. Such avenues might include an intensification of efforts already under way to strengthen supervision and to improve the training of inspection employees as well as increased use of disciplinary action when inspection employees do not meet their responsibilities. (See p. 42.)

AGENCY ACTIONS AND UNRESOLVED ISSUES

The Department (see app. I) said:

That it initially decided not to adopt the consultants' recommendation to establish a separate agency because the consultants had stated that the meat and poultry inspection program also could function within the existing agency and because one advantage of keeping it there would be that separate administrative support functions would not have to be developed.

That the agency was attempting to respond in specific ways to deficiencies in its supervisory structure which had been totally inadequate and was taking or planning other actions to improve the enforcement of sanitation standards. That the merits of establishing a separate agency should be considered but that, in its judgment, it would be a grave error to consider the creation of a new agency until the actions already under way and others being planned had been given a reasonable time test.

MATTERS FOR CONSIDERATION BY THE CONGRESS

The Congress may wish to consider the matters discussed in this and earlier reports in connection with a number of measures now before the Congress. These measures include bills to establish a separate Department of Consumer Affairs and the President's Reorganization Plan which would transfer the agency's poultry and meat inspection activities to a proposed Department of Human Resources. (See p. 43.)

APPENDIX G

[Comptroller General's report to the Congress: Digest]

BETTER INSPECTION AND IMPROVED METHODS OF ADMINISTRATION NEEDED FOR FOREIGN MEAT IMPORTS

WHY THE REVIEW WAS MADE

The Federal Meat Inspection Act provides that no meat or meat food products be imported into the United States

If adulterated or improperly marked, labeled, or packaged: and

Unless produced by foreign meat plants which are approved to export to the United States and which are in compliance with U.S. inspection, sanitation, and facility requirements.

The Consumer and Marketing Service (C&MS), Department of Agriculture, is responsible for (1) determining that foreign countries' inspection systems and plants comply with U.S. requirements and (2) inspecting meat and meat food products presented at U.S. ports of entry for inspection before American consumption.

The General Accounting Office (GAO) made this review to determine the adequacy and effectiveness of C&MS practices and procedures in carrying out these responsibilities.

During fiscal year 1971, about 1.7 billion pounds of foreign meat products were passed for entry for U.S. domestic consumption and about 25.2 million pounds were rejected.

FINDINGS AND CONCLUSIONS

To provide greater assurance that foreign meat and meat products (1) are imported only from plants which comply with U.S. requirements for wholesome products processed under sanitary conditions and (2) receive thorough and uni

form inspections at U.S. ports before being accepted for entry, C&MS needs to strengthen its administration of the import meat inspection program.

Compliance with basic requirements

Although foreign countries' inspection officials were required to withdraw certifications to export to the United States from many plants that did not meet U.S. requiremens (called delisting), C&MS records showed that some plants had been permitted to remain eligible to export to the United States.

C&MS criteria for delisting should be mandatory for plants that do not meet basic U.S. requirements until needed corrections are made to ensure that U.S. consumers are safeguarded. (See p. 14.)

A GAO staff member accompanied C&MS foreign programs officers-veterinarians experienced in U.S. meat inspection on their reviews of 80 plants in four major meat-exporting countries-Australia, Argentina, Canada, and Denmark. The officers' reports showed that some plants complied with U.S. requirements; others did not.

Because of serious deficiencies at 14 of the 80 plants, C&MS had the plants delisted. (See pp. 16 to 25.)

Delays in delisting plants

Delistment procedures were such that a considerable period of time-averaging 45 days in calendar year 1970-generally elapsed between the dates that the C&MS officers found deficiencies and the dates that the plants actually were delisted. In the interim meat products processed in the plant were eligible for export to the United States unless C&MS determined that the plant constituted a health hazard. Of 327 plants delisted in 1970, two were classified as health hazards.

Such time lapses virtually could be eliminated, GAO believes, if C&MS authorized its foreign officers (1) to delist plants provisionally when they inspected the plants and (2) at the same time, to direct foreign country officials to suspend the exporting of products by provisionally delisted plants, subject to a final determination by C&MS. (See p. 26.)

Products from delisted plants eligible for import

C&MS permits meat products from a delisted plant (1) to be presented for entry for American consumption if certified by foreign country inspection officials as having been produced prior to the date that delistment took effect and (2) to be imported into the United States if they pass inspection at the port of entry.

About 13 million pounds of meat products were imported from 11 of the plants delisted after GAO's visit. Importation of meat products produced prior to delistment for conditions that could render the products unsound, unhealthful, unwholesome, or otherwise unfit as human food is, obviously, not in the best interest of U.S. consumers. (See p. 29.)

Frequency of reviews

C&MS records showed that it had not reviewed some plants as often as it considered desirable. For plants delisted in calendar year 1970, an average period of 10 months elapsed between reviews which showed conformance with U.S. requirements and reviews which resulted in delistments.

C&MS said that reviews were infrequent because it did not have enough foreign programs officers and because its officers were stationed in the United States and spent only about 30 weeks a year in foreign countries. In May 1971 the agency began stationing some of its officers in foreign countries. (See p. 32.) Inspections at ports of entry

To improve inspections at ports of entry, the agency needs to:

Establish a sampling plan for inspecting packaged meat products and improve its sampling plan for examining canned products to ensure that the number of items examined is representative of the total lot or shipment. (See p. 39.)

Establish adequate criteria for identifying and classifying defects found during examinations of canned products and inspections of packaged products to ensure maximum uniformity in determinations to accept or reject such products. About 396 million pounds of processed canned meat products were presented for entry during fiscal year 1970. (See p. 39.)