“Major deficiencies associated with the establishment’s physical conditions were observed that could pose imminent threat to product.”

– Conclusion from USDA Food Safety Assessment of Boar’s Head (Jarratt, VA), October 2022

In September/October of 2022, the USDA’s Food Safety and Inspection Service (FSIS) conducted a Food Safety Assessment (FSA) of the Boar’s Head production plant in Jarratt, Virginia.

The FSA, which was conducted by an Enforcement Investigation and Analysis Officer (EIAO), followed on the heels of numerous instances of non-compliance with sanitation, cleaning, and maintenance norms documented by Inspection Program Personnel.

The FSA began on September 27, 2022, with a “walk-through” to evaluate the production facility’s compliance with Sanitation Performance Standards.

During that walk-through, the EIAO observed nearly 100 individual instances of non-compliance, including:

• condensation beading on pipes and ceilings; in some cases directly above ready-to-eat product
• rusting brackets, clamps, and conduits
• peeling paint
• loose caulking
• trash on floor
• smoke and soot collected on ceiling and overhead pipes
• holes in walls and floors
• exposed insulation around piping
• green mold in the vicinity of a crack in a wall
• live insects

The second phase of the FSA focussed on compliance with Sanitation Standard Operating Procedures (SSOP). This part of the assessment was performed only after plant quality assurance personnel had completed their own pre-operation inspection and declared the areas to be ready to begin production.

During the SSOP inspection, performed on September 28th, September 29th, and October 4th, the EIAO documented 46 individual instances of inadequate cleaning and six maintenance issues, including:

• multiple instances of product residue on and around production equipment, including on surfaces that would come into contact with fresh product
• beads of condensation
• numerous missing links in a conveyor belt line

Upon checking the facilities SSOP records for the dates in question, the EIAO discovered that neither the deficiencies nor any corrective action had been documented, as required.

Finally, in the course of reviewing the company’s HACCP plan and records, the EIAO found that multiple sites had been omitted from the list of Food Contact Surfaces in the Environmental Monitoring Program.

What happened next?

NOTHING!

No warning letter. No suspension of operations (except for a 1-hour pause in a single part of the facility).

And, as far as can be determined from subsequent routine inspections, no real change in the company’s attitude or behavior.

The on-site inspector continued to log instances of product residue and “meat over-splash” in areas that had been cleared by plant QA personnel for production.

Mentions of rust continued to appear on the inspection logs.

Insects still crawled onto the pages of the reports.

And condensation periodically beaded on the ceiling, sometimes above a product-contact area.

What about Listeria?

In all of the inspection reports, covering a two-and-a-half year period from January 2022 through July 2024, there is not a single mention of Listeria.

We don’t know whether, and to what extent, the company conducted environmental and finished product testing for Listeria, and there is no indication that the 2022 Food Safety Assessment included any such sampling.

The only testing that has been made public consisted of twelve finished product samples collected by the Virginia Department of Agriculture at the request of the FSIS and analyzed by a USDA laboratory. Listeria monocytogenes was not recovered from those samples.

Some things never change

In mid-September 2002, the CDC alerted the public to an outbreak of Listeria monocytogenes that was responsible for 26 illnesses and 4 deaths. By October 4th, the number of confirmed illnesses had increased to 40. Seven people died and three pregnant women miscarried.

Epidemiological analysis linked the outbreak to sliced turkey deli meat. Eventually, the outbreak strain was found in environmental samples collected at Pigrim’s Pride in Franconia, PA and from ready-to-eat poultry products manufactured by JL Foods (a company unaffiliated with Pilgrim’s Pride).

Both companies had a long history of Listeria monocytogenes contamination in their production facilities, dating back at least to 1990 in the case of JL Foods. In both cases, FSIS closed its collective eyes to multiple instances of non-compliance at both facilties.

What needs to be done?

Food safety regulation and enforcement is suffocating within the FDA. The relatively recent reorganization may help, but feels too much like a rearrangement of deck chairs on the Titanic.

For decades, enforcement of food safety regulations for meat and poultry products within the USDA has taken a back seat to the agency’s mandate as a promoter of US agricultural products and industries. There is an inherent conflict of interest in these dual mandates that cannot be solved by nibbling around the edges.

The current system in the United States is fraught with overlapping jurisdictions and completing interests. Arbitrary definitions can place a single plant be under FSIS jurisdiction for some products and FDA jurisdiction for others.

The only sensible solution is to do what many of the USA’s trading partners have already done.

Combine the food safety mandates of the FDA and FSIS into a single, independent Food Safety Agency.

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