The National Chicken Council (NCC) submitted official comments Wednesday in response to its September 1 petition to institute a voluntary waiver program allowing chicken processing plants opting into the New Poultry Inspection System (NPIS) to increase line speeds to any speed at which the plant can maintain process control.The comments, among roughly 21,000 other comments filed to the Food Safety Inspection Service (FSIS) in the Federal Register docket, highlight three points from the original petition: food safety, worker safety and support for businesses.

“A line speed waiver would not undermine food safety,” the comments read. “A preliminary analysis of data from NPIS and non-NPIS establishments released by FSIS on October 19, 2017 further confirms that plants permitted to operate at line speeds greater than 140 birds per minute had comparable Salmonella and Campylobacter levels for both whole chicken carcasses and chicken parts – both of which are below FSIS performance standards.”

In addition, the comments stated that a waiver does not risk worker safety. “In fact, worker safety in poultry plants has improved dramatically in the past two decades, with worker illness and injury rates reported by the U.S. Bureau of Labor Statistics dropping more than 80 percent since 1994.” The total recordable poultry processing illness and injury rate for 2016 was 4.2 cases per 100 full-time workers per year, down from 4.3 in 2015. NCC noted that rate is lower than rates in the soft drink, cheese and bakery industries, among others.

NCC’s final point was that the waiver program would add support to American businesses. The waiver program “will create an incentive to enhance food safety systems by rewarding those establishments that are willing to invest the money and expertise to develop food safety systems that can maintain process control at higher line speeds.” The comments added that the waiver program would further a key Trump Administration goal of removing burdensome and costly regulations, therefore making a more efficient use of public funds than the current system.

The comment period for the petition closed Thursday, December 13, 2017.