New Poultry Inspection System NPIS

1. New Poultry Inspection SystemNPIS Dennis R. Johnson OFW Law NTF Technical Regulatory Committee February 16, 2012

2. Overview Proposal would reduce the number of chicken and turkey slaughter inspection systems to two: • Traditional • New Poultry Inspection System Proposal also would make other significant changes to the poultry slaughter regulations.

3. For Both Traditional and NPIS • Establishment must have a program to prevent contamination of product with fecal or enteric pathogens throughout the process. • Only express regulatory requirements for this program: • Must be written; and • Must include testing pre- and post-chill for Salmonella, Campylobacter, or an indicator organism.

4. For NPIS Only • Establishment responsible for sorting birds. • Maximum Line speeds: 175 bpm broiler; 55 bpm turkeys. Note – these are the maximum speeds, not guaranteed speeds. • 300 birds per flock examined by FSIS for avian leukosis (broilers only).

5. Modification of other regulations The proposal would: • Eliminate generic E. coli testing; • Permit flexibility in chilling (and temperatures during further processing) by replacing specific time/temperature requirements with a performance requirement (no outgrowth of the pathogens);

6. Expressly add on-line reprocessing and permit alternative anti-microbials at off-line reprocessing; • Remove finished product standards, establishments must document the products meet the definition of “ready to cook”; and • Revoke the not-used-since-1999 Salmonella performance standards.

7. Other Provisions • SIP is not at an end – if an establishment wishes any regulatory waiver, not covered by the proposal, it must participate in SIP. • Air Chilling – FSIS would define air chilling and limit claims to products comporting with the definition.

8. So, is this a good thing? Politics – Driven by budgetary savings, Inspectors’ Union will have/find concerns. It is Mandatory – Cannot opt out. Open Questions – What are FSIS’ expectations; likely get a hint when FSIS releases its Sanitary Dressing Directive, 6,410.3. Comments Due: April 26, 2012

9. Questions???