The Department of Agriculture’s (USDA) proposal to “modernize” the poultry inspection system by replacing government inspectors with company employees, and speeding up the processing line to a staggering 175 birds per minute, has been exposed on numerous occasions as a disaster-waiting-to-happen for food and worker safety. In its zeal to save money for poultry corporations, the White House’s Office of Information and Regulatory Affairs (OIRA) failed to conduct its much-vaunted “interagency review” before giving the proposed rule its stamp of approval—it even neglected to invite the Occupational Safety and Health Administration (OSHA) to weigh in on the obvious dangers posed to workers.
As if more evidence were needed that the poultry rule is a horrible idea, it turns out that the rule also poses a number of serious threats to the environment that went unaddressed in the USDA’s analysis, as CPR President Rena Steinzor and I explain in a letter sent today to OIRA Deputy Administrator Dominic Mancini.
As proposed, the rule threatens to significantly increase water pollution in at least two distinct ways. First, it would lead to an increase in the use of poultry-sanitizing chemicals, which then have to be discharged into nearby water bodies where they will have toxic effects on aquatic life and threaten ecosystems. Poultry plants are expected to increase their reliance on something called “online reprocessing” (OLR), where all carcasses, visually contaminated or not, pass through automatic sprayers on the line that drench them with large amounts of antimicrobial chemicals like chlorine and trisodium phosphate (imagine a car wash … but for chickens). In the more traditional method, only those carcasses that are visually identified as contaminated are taken off the line for reprocessing, undergoing procedures that use smaller amounts of chemicals.
Half of all poultry plants already use OLR under waivers from the USDA, but the new rule would eliminate the need to obtain a waiver, paving the way for wider adoption of the practice. Even more importantly, with three chickens whizzing by every second under the new rule, and a sharp reduction in government inspectors, it would be nearly impossible to spot contaminated carcasses that should be taken off the line. Companies will turn to OLR as a way of indiscriminately disinfecting all the birds on the line: those plants that don’t already use OLR will start, and the rest are likely to install chemical washers and sprayers at additional points on the line.
As an entirely separate consequence, the faster line speeds permitted by the rule would enable poultry plants to increase the number of birds they slaughter every day, producing more pollutant-filled wastewater—containing larger amounts of blood, urine, feces, feathers, fat, and bone—that will also be discharged into surface waters. (On average, poultry plants produce 9.3 gallons of wastewater per chicken.)
In its proposed rule, the USDA quickly dismissed any significant rise in the number of birds slaughtered, insisting that there simply won’t be a market for that many additional poultry products. Because the agency predicted that the rule would have only a trivial effect on the price of poultry, it concluded that expected sales of poultry would remain essentially the same.
However, we found two major flaws in the USDA’s analysis. First, the agency severely underestimated the expected increase in line speeds and the resulting cost savings and growth in production capacity, which would likely reduce prices by more than the USDA predicted. Second, the agency looked only at domestic consumption, completely ignoring the enormous (and growing) foreign market for U.S. poultry exports, which has been shown to be much more responsive to slight changes in price than the domestic market. (In 2012, U.S. companies shipped 7.2 billion pounds of broiler meat to other countries.) As a result, the number of birds slaughtered and the amount of polluting wastewater produced under the rule are likely to be much greater than the USDA acknowledges.
To make matters worse, existing regulations and water permit programs are not equipped to handle large increases in the chemicals used in OLR or the pollutants that come from a rise in slaughtering, as we discuss in the letter:
Most poultry plants do not even have limits for these chemicals in their wastewater permits, so additional discharges will generally go undetected and unaddressed …. In the last three years, 68 percent of poultry plants with data available exceeded their effluent limits for one or more pollutants; a significant rise in slaughtering would only increase and intensify these permit violations. The USDA did not acknowledge any of these damaging outcomes in its Federal Register notice explaining the proposal, adopting the same “hear no evil, see no evil” position on these issues as it did on the worker safety ones.
We conclude our letter today by calling on OIRA to ensure that the Environmental Protection Agency (EPA) be given the opportunity to scrutinize the rule’s environmental implications this time around, as the Office prepares to review the USDA’s final version of the rule.
The letter is posted here.