Northern Ag Network Note: This is the second part of a nine-part editorial series written by Miles City, Montana’s John Munsell. John and his family had owned a small meat packing plant in the town for 59 years. An E.coli positive lab test from meat in his facility in 2002 and subsequent testing resulted in John moving his focus to the way that USDA handles inspections of small plants and what needs to be fixed. This series is also being posted on the Food Safety News website and John will be interacting with commenters online there. A link to the first part of this series is available at the bottom of this story.
by John Munsell, FARE
Prior to discussing negotiations in the following months between FSIS enforcement officials and my plant, we must describe contemporary FSIS meat inspection policies in existence in 2002, which remain to this day. Faulty agency designs in current meat non-inspection protocol birthed the problems seen at my plant, justifying FSIS’s persistent misbehavior.
Subsequent to the Jack in the Box E.coli outbreak in 1993 which sickened hundreds of consumers and killed four, FSIS perceived the need to change its meat inspection system. The old system was incapable of detecting invisible pathogens, such as the newly-emergent E.coli O157:H7 bacterium responsible for the Jack in the Box outbreak. The previous system was organoleptic in nature, meaning dependence upon the senses, such as sight, smell, and touch. Invisible bacteria such as E.coli O157:H7 and Salmonella cannot be detected via sight, smell and touch. FSIS was aware of a food production system previously authored by Pillsbury in the 1960’s designed to produce consistently safe food for NASA and the Army. Pillsbury named its protocol “Hazard Analysis Critical Control Point”, or HACCP (pronounced “HASS-up”). Pillsbury designed HACCP for foods which were subjected to a “Kill Step”, protocol such as full cooking or irradiation which “kills” all bacteria, producing a consistently safe food. Pillsbury built safety into each individual step of food production, initially validating the safety of each step with substantial microbial testing. Subsequently, food plants utilizing Pillsbury-style HACCP have done very little testing, because their products are consistently safe, in stark contrast to FSIS’ current demand for increased microbial testing. Why the difference? The reason is that FSIS-style HACCP is not true HACCP, which this report will reveal. Another reason for the difference is that raw meat products produced under FSIS-style HACCP are NOT consistently safe, thereby necessitating increased amounts of microbial testing.
FSIS proudly proclaimed that FSIS-style HACCP would be “Science Based”, in stark contrast to its previous organoleptic system. When we questioned what the agency meant by “science based”, the agency stated that sampling for microbiological testing would be required under HACCP. Indeed, in the 56 years of my plant’s existence prior to HACCP, neither the agency nor I collected any meat samples for microbial analysis. Upon HACCP’s advent, both the agency and I collected dozens of samples, four of which were positive for E.coli O157:H7 at my plant. Can’t argue with lab results.
FSIS perceived potential industry opposition to HACCP, thus had to dangle carrots in front of the industry to obtain voluntary industry acceptance of this dramatic change. During meetings with the industry to roll out USDA-style HACCP, the agency made the following promises:
- Under HACCP, FSIS would embrace a “Hands Off” role in meat inspection. (Personal note: this promise reveals the agency’s desire to not inspect meat production lines)
- Under HACCP, FSIS would voluntarily relinquish its previous command-and-control authority.
- Under HACCP, FSIS would no longer police the industry, but that the industry was to police itself. (Personal note: this would work quite well, if all humans were honest. What would happen to tax revenues if IRS allowed us to police ourselves?)
- Each meat & poultry plant could write its own personalized HACCP Plan, and the agency could not dictate what must be in each HACCP Plan. The deceitfulness behind this promise will be fully explained later in this report, which will reveal the widespread extent of corruption within the agency.
Like other plant owners, I was thrilled at the prospect of less FSIS oversight at my plant, having authority to police myself, and to witness FSIS operating in the lack of any policing actions and no command-and-control authority. Sugar plums were dancing in my head. I fully endorsed this deregulated system of non-inspection. Only later did I discover that these promises were furtively intended only for the big plants, while the agency has been fully noncompliant with all four promises at small plants which lack political and economic clout. FSIS has used HACCP to deregulate large plants, while hyper-regulating the small plants. Pretty nifty! The agency has successfully pulled off the ultimate “Bait & Switch” – all under the umbrella of pseudo science.
FSIS-style HACCP was mandated in the agency’s “Pathogen Reduction: HACCP Rule” in 1996. Large plants implemented HACCP on January 26, 1998. One year later medium-sized plants implemented HACCP, followed by small plants in 2000.
FSIS mandated that every federally-inspected meat & poultry plant implement a HACCP Plan, although FSIS-style HACCP had dramatic differences from Pillsbury’s original HACCP system, a well kept secret. (I was not aware of this until 2009, a full seven years after my recall. FSIS has successfully concealed these core differences, even from industry insiders). Although Pillsbury’s HACCP regimen required the afore-mentioned kill steps, FSIS-style HACCP does not require kill steps. Therefore, plants producing raw meat & poultry designed HACCP Plans with the absence of kill steps. Plants using Pillsbury-style HACCP Plans easily qualify for deregulation, because (1) safety is built into each step of their production system, and (2) their products have been subjected to a kill step. Such plants truly deserve deregulation. FSIS-style HACCP simply required plants to author a written HACCP Plan, after which they enjoyed the four agency promises listed above. The assumption was that if a plant merely has a written HACCP Plan, all their raw products would be safe, even though they had NOT been subjected to a kill step.
Central to FSIS-style HACCP is the need to document, document, and document, and then document even more: a classic paper chase. USDA-inspected plants now oversee a daily plethora of HACCP paperwork, inundating themselves with paper flow, much of which has zero connection to safe food. HACCP Plans are to say what we do, then we must do what we say. The only way we can prove that we are doing what our HACCP Plans are saying is to cover our derrieres with an abundance of paper flow, which by the way, can be manipulated via falsification. FSIS could care less, as the agency primarily exists to audit paperwork, not inspect meat. Even though a plant’s HACCP Plan is professionally written, worthy of a Pulitzer Prize (in science fiction), including scientific references, bells and whistles, it can still produce contaminated meat. FSIS fails to acknowledge that food safety is not determined by paper flow, 3-ring binders with cutsie stickers and labels, and bulging files. FSIS wisely fails to acknowledge that sanitary production practices (not paperwork) produce safe meat. After HACCP’s advent, inspectors dedicated much more time inspecting my paperwork than inspecting my meat production lines. Does that increase your confidence in meat safety? Only if you have been duped by FSIS-style “science”. Although FSIS-style HACCP was initially described as a Pathogen Chase, it quickly degenerated into a Paper Chase.
Two common statements from FSIS inspectors and veterinarians since HACCP’s advent have been:
- FSIS implemented HACCP primarily to lessen the agency’s legal liability in the event of an outbreak, since the agency cannot be held even partially liable for contaminated meat which FSIS hadn’t inspected in the first place. As such, it has been recommended that FSIS-style HACCP be renamed HASSLE, as in “Hazard Analysis Sorta Scientific Liability Evasion”.
- Much more importantly, FSIS hierarchy covets COMFORT in its dealings with the influential big packers. Comfort is best accomplished via deregulating the large packers, relegating the agency to a “Hands Off” non-involvement role. Since FSIS willingly forfeited its previous policing authority and command-and-control under HACCP, the agency no longer experiences the delicate discomfort involved with attempting enforcement actions against the industry’s high volume elite, who now policed themselves. As such, FSIS used HACCP as a Trojan Horse which was disingenuously labeled “Food Safety”, but inside the horse was the agency’s ultimate objective, which was Deregulation and Agency Comfort.
With this as a background, let’s see how the Minneapolis District Office (DO) responded to the fact that my plant had experienced three consecutive days of adverse lab test results for E.coli O157:H7, perhaps a unique event in the history of the meat industry. These adverse lab results also provided the agency a golden opportunity to identify the source plant which was grossly noncompliant with E.coli control measures. This incontrovertible evidence would have enabled FSIS to identify the true source, providing justification for swift and effective agency enforcement actions at the Source, to the benefit of public health.
Initially, the DO stated that not only did I have a failure in my HACCP Plan, but that I had multiple failures because of multiple lab positives. Secondly, the DO stated that I must reassess my HACCP Plan, and implement corrective actions to prevent recurrences.
I quickly reminded them that copious documentation of source evidence, compiled in real time both by the inspector and by my own staff provided indisputable evidence that the meat sampled was Coarse Ground Beef I had purchased from one well-documented outside firm. Furthermore, I reminded them that the documentation also proved that the meat sampled at my plant came from a clean grinder, that is, that no other grinds had been performed earlier in the day which could have potentially deposited residual bacteria which might have caused subsequent grinds to be cross contaminated. I also reminded the DO that the samples on all three days were single source grinds, that is, I did not commingle meats from various sources into one grind. All of this was documented by the inspector who collected the three samples. Open and shut case. Or so I thought. I never claimed to be brilliant, you know. My dad would never tell me jokes on Saturday nights, as he was afraid I’d laugh in church on Sunday. Anyway, as I commenced my HACCP Reassessment, FSIS allowed me to continue to operate, but did not allow me to grind under the USDA Mark of Inspection. My plant could continue operations as before, but could not grind under inspection. Now, try to operate a small meat plant without a grinder!
I wrote numerous HACCP reassessments, all of which were rejected by the DO as being “inadequate”. These Reassessments were time consuming, costly, and all futile. Before this scenario terminated, the DO rejected fourteen reassessments, ironic when the industry average is one to two reassessments prior to resumption of normal operations. Fourteen rejections would be laughable, except it’s not funny………unless you worked at the Minneapolis DO. Perhaps FSIS wasn’t as “Science Based” as we had been lead to believe. Sometimes, “science” can be stranger than fiction. Please remember that one of the four FSIS pre-HACCP promises was that each plant could write its own HACCP Plan, and that the agency couldn’t tell us what must be in our HACCP Plans. Subsequent historical events continue to reveal to small plants systemic agency misbehavior as shown below. When FSIS officials decide to disagree with entries in HACCP Plans, agency officials automatically resort to the following sophistry:
“Your HACCP Plan has a failure, and is inadequate”
“We can’t tell you what is inadequate, nor where the failure is, because it’s your Plan”
After small plant owners don’t know how to proceed, FSIS concludes:
“You should consider implementing the following steps”.
This is allegedly merely a “suggestion”, mind you.
Then, after the plant implements the agency’s suggestions, the agency frequently concludes:
“Your actions are inadequate”
FSIS-style HACCP is a crazy, convoluted mendacious system, which FSIS lifer bureaucrats have ingeniously designed and mastered.
After a few rejections, a remarkable event transpired which has haunted the agency ever since. An agency veterinarian by the name of Dr. Daryl Burden (now deceased) had previously been assigned to a large plant in the Pacific Northwest, where he observed ongoing pathogen problems. When plant management prevented his access to documents, Dr. Burden sent numerous emails to top agency brass in DC, only to be told he must allow the plant to operate as is, he had lost sight of “The Big Picture”, and reminding him to be a team player. Dr. Burden quickly became a liability to the agency because of his dogged documentation of recurring problems, coupled with the agency’s refusal to demand corrective actions at the plant, a benefit of FSIS-style HACCP. The agency’s solution to this delicate problem was to reassign Dr. Burden, to remove him from the problem plant. To the agency’s eternal regret, FSIS relocated Dr. Burden to my area, and my plant was one of the first into which he stepped. Dr. Burden unwittingly inherited a gold mine.
Dr. Burden was immediately instructed by the Minneapolis DO to review my most recent Reassessment, and issue a report to the DO whether I was yet in “full compliance”. To the horror of the DO, not only did Dr. Burden state that he personally felt that my most recent Reassessment was adequate, but he went far beyond the assignment given to him and revealed that the source meat originated from another plant. Dr. Burden’s hand-written statement (I still have the original) included the following statements:
“Review of the three consecutive e.coli O157:H7 failures strongly suggest a common source of the contaminant – coarse ground product of a single identified lot received from Est 969” [ConAgra’s plant in Greeley, CO].
“I recommend acceptance of Est 7679 [my plant] response and implemented measures, and suggest a follow-up investigation of the source of the product considering the serious public health implications of other possible e.coli O157:H7 adulterated product from the same production lot”.
Inspector Ronald G. Irvine (now retired) hand-wrote “I concur with the above!”, signed the document, and dated it 3-1-02, 10:00 am. Dr. Burden asked me to fax the letter to the Minneapolis DO, which I did. He left quickly, to drive back to his home in the Black Hills of South Dakota. Before leaving, he asked me how soon he would be out of cell phone range, as he stated that he knew that the DO would be angrily calling him as soon as they read the fax. American consumers, and me in particular, benefitted by Dr. Burden’s courageous act to document the truth in writing, a task which the agency had not requested from him. The absence of this one document would have doomed my advocacy to ruination, as I would have been portrayed as a sore loser, unwilling to accept my well-deserved punishment for allegedly introducing adulterants into ground beef.
Now, the cat was out of the bag, and the agency had to devise strategy to recapture the loose feline.
Wouldn’t you know it, early the following week Dr. Burden walked into my office, and sheepishly stated “The District Office wants me to POLITELY ask you if you would return that letter please”. I stated “It’s too late, I’ve already made dozens of copies and distributed them in many states”, a true response. Dr. Burden punched the air with his fist, smiled with great glee, thanked me, and walked out. This cat wasn’t going back into the bag, much to the chagrin of the Minneapolis DO.
The succeeding weeks were filled with more conference calls with DO officials. Of course, calls were typically several of them, versus one of me. Numerous subsequent HACCP reassessments were provided to the DO, all of which (of course) were rejected. I finally concluded that the agency would never grant me the right to grind again, partly because of the Alcatraz invitation, and because of Dr. Burden’s letter.
In one telephone discussion with an official at the Minneapolis DO, I made reference to Dr. Burden’s letter. I was cautioned “Mr. Munsell, it would be good for you to never again mention that letter”. The FSIS DO had now resorted to overt suppression of source evidence. So much for “science”.
During one telephone conference with Minneapolis DO officials, when I made mention of the letter written & signed by FSIS veterinarian Dr. Daryl Burden & inspector Ronald Irvine, DO personnel responded by stating:
“They were not authorized to make that statement. That was just their personal opinion”
So much for documenting evidence in real time.
The November/December, 2003 issue of Mother Jones magazine included a story which revealed FSIS misdeeds at my plant, and the agency’s lack of oversight of the meat industry. One of many highly revealing statements in the article questioned the agency’s desire to document all evidence:
“Never mind that the local federal inspector had seen the beef go straight from the package into a clean grinder – a USDA spokesman called that testimony ‘hearsay’”
When confronted with well-documented but embarrassing evidence, agency officials blithely dismiss scientific evidence as “hearsay”, “personal opinion”, and then the all-encompassing solution “the inspector was not allowed to make that statement”. It is unfortunate when well-meaning FSIS inspectors get in trouble for telling the truth. It is also unfortunate that food safety has been entrusted to an agency which prohibits its field force from documenting all evidence without artificial restrictions from the agency itself. As such, consumers continue to be imperiled, justified by FSIS-style deregulated “SCIENCE”.
The Mother Jones article included another revealing quote from an agency official:
“USDA spokesman Steve Cohen also argues that Munsell never proved the source of the initial E.coli contamination and suggests that he ‘got a good deal’ on the ConAgra meat”
When FSIS lacks any logical explanation for its misbehavior, it resorts to slander. The agency insinuates that I knowingly purchased E.coli O157:H7-laced meat from ConAgra, simply because I was offered a discounted price. Since the coarse ground beef was frozen, I did purchase it at a discounted price compared to fresh coarse ground beef. But think about it further: Steve Cohen’s statement is an official agency admission that FSIS was cognizant that ConAgra was shipping to me coarse ground beef that was adulterated with E.coli O157:H7 pathogens. (I didn’t know it, but FSIS apparently knew). So, how did FSIS respond? It shut down my grinder for four months, while taking no actions at the source originating slaughter plant.
How does FSIS respond when presented incontrovertible evidence of pathogen-laced meat? Answer: it kills the messenger. And later……..consumers.
During one visit of FSIS enforcement officials to my plant, they stated that improper employee hygiene by my employees may very well have been the cause of the three successive days of E.coli O157:H7 positive samples. I asked them to explain. They stated that one of my employees may have used the rest room, and afterward did not wash his/her hands, potentially leaving human fecal material on their fingers. Then, the employee allegedly went directly to the processing room and ground the meat from which the inspector collected a sample, which was now contaminated with human feces. These officials intentionally ignored the well-known fact that we don’t grind meat with bare hands, because the meat is so cold. And, before grinding, employees put on cotton gloves (for warmth), and then cover the cotton gloves with plastic gloves which keep the cotton gloves dry and warm. I was incredulous at their inane suggestion, and replied that if poor employee hygiene was indeed the source of the problem at my plant, then I have an employee carrying a horrific load of pathogens in their intestines, and the employee must either be in the hospital or at the morgue. I suggested that we review my payroll records, to see who had recently been sick. They declined my offer, and never resurrected this argument again. I bring up this issue to reveal how FSIS will fabricate an unlimited number of false accusations designed to provide ingenious theoretical examples of how further processing plants ostensibly introduce pathogens into the food chain. This is done to obfuscate the true source of contamination, thereby insulating the truly noncompliant large source slaughter plant from fecal accountability. Since my recall, numerous other victimized plant owners have told me they’ve been accused of the same. While E.coli O157:H7 can indeed be introduced at downstream locations, FSIS should at least provide plausible examples.
My wife Kathy and I drove to Minneapolis to argue our case in person with six DO personnel. We met on Friday, May 3, 2002 from 2:30 – 6:30 pm, a 4-hour exercise in feckless, feeble futility. Although the agency proffered endless “suggestions”, none of which were viable, such as the idea of my irradiating my entire product line, four particular agency statements exposed the agency’s unethical bias against small plants:
- When I complained about the mountain of boneless trimmings accumulating in my freezer, which I could not grind, the DO folks told me I could legally sell the trim, but could not grind it myself. I was stunned. FSIS thus unknowingly admitted that my kill floor was NOT the source of my e.coli problem.
- One of the DO personnel stated that I had not proven that the sampled meat was not from my own kill floor. So much for the copious documentation compiled by the inspector and my staff during those ill-fated three days of sampling. Essentially, DO personnel assumed the unilateral authority to summarily reject all documentation provided by their own field force, and rewrote history from their remote locations. And secondly, since FSIS still contended that my kill floor was the probable source of the problem, why did the agency authorize me to sell trimmings into commerce which originated from my own kill floor? The DO refusal to accept documentation both from its own field force and from me invalidates the agency’s original endorsement of copious documentation, a foundational pillar of HACCP. It is interesting to note that ConAgra quickly issued me a full credit for the three batches of meat I destroyed which was produced on the three consecutive days of E.coli O157:H7 positives. In the total absence of any negotiations, ConAgra immediately refunded me for all the meat I had to destroy. No questions asked. Although ConAgra quickly granted my request for a credit, which constitutes ConAgra’s acknowledgement that their coarse ground beef was tainted, the Minneapolis FSIS DO continued its mantra that I had not proven that the bad meat had not originated from my own kill floor. As such, the Minneapolis DO claimed that it knew more about the scenario that its own inspector, ConAgra and I knew. But as this report will show, the Minneapolis DO cover-up would eventually be unraveled.
- The manager of the Minneapolis DO stated that FSIS Inspector Dan Ellis was not authorized to state that the meat he sampled at my plant in January, 2002 was Coarse Ground Beef I had purchased from an outside source supplier. This agency admission should boil the blood of all meat consumers. FSIS itself states that its own inspectors are not authorized to admit the truthful origin of contaminated meat. FSIS deprives its employees the right of free speech, or to document unrestricted truth which would benefit public health imperatives. A full revelation of FSIS corrupt practices could make vegetarians out of all of us.
- As the meeting progressed, and the subject of multiple Reassessments and an equal number of rejections were discussed, while the DO artfully dodged informing me what I needed to do, my wife Kathy finally raised her hands and said with exasperation “Just tell us what you want us to do”. The FSIS officials responded “We can’t tell you what to do, because it’s your own HACCP Plan (see Promise #4 in Part 1 of this report), and you can write it the way you want to”. FSIS authorizes plants to write their own individualized HACCP Plans, then the agency rejects the HACCP Plans as being inadequate. However, the agency does not have to explain what is the source of the inadequacy, nor describe changes necessary (in the agency’s mind) to resolve the alleged inadequacy. At this point in the meeting, my wife Kathryn stated “Bottom line: you’re just trying to shut us down”. The manager of the DO replied “Oh no, Mrs. Munsell, we want to help you get up & running, don’t we” as he looked to his assistants, all of whom bobbed their heads in agreement, like puppets on strings. FSIS officials claimed they wanted to get us up and running, but their actions proved otherwise.
Reminds me of an incident in my home kitchen, decades ago. As our family ate supper, we noticed that our cat had a mouse entrapped in its mouth, the only evidence of which was the rodent tail protruding from our cat’s teeth. Cats love to torment trapped mice, temporarily placing them within the cat’s mouth, throwing the mouse in the air, batting it around, and finally administering the terminal coup de grace. An apt description of how FSIS plays with small plants.
I desperately sought outside assistance, as my inability to personally push for justice with FSIS hit a stone wall. Montana Senators Max Baucus and Conrad Burns, and Representative Denny Rehberg all pleaded on my behalf, to no avail. I joined the National Meat Association (NMA), as I had previously belonged to its predecessor Western States Meat Association fifteen years earlier, and I perceived that its Executive Director Rosemary Mucklow might provide assistance. I also joined the National Association of Meat Purveyors, and contacted officials within the National Cattlemen Beef Association (NCBA) who might speak some sense into top FSIS officials in DC. Although officials from these groups made contacts on my behalf, all of my HACCP Reassessments continued to be “Rejected”, with no specific reasons for rejection, nor solutions provided as what would be required by the agency.
To my relief, NMA and NCBA, at their expense, hired a consultant to work with me to bring this imbroglio to a conclusion. The consultant, Dr. Helmut Blume, was uniquely and preeminently qualified to run the gauntlet on my behalf. He had retired from FSIS only five months earlier, where he had served as the manager of the agency’s District Office in Salem, Oregon. He was highly respected both in the industry, and in the agency. Dr. Blume flew to Miles City to meet with me, and reviewed my HACCP Plan and related programs. He personally knew the manager of the Minneapolis DO because of his many years in the agency. We agreed that Dr. Blume would contact Minneapolis on my behalf, explain that he was a consultant for me, and jointly work with the Minneapolis DO manager to devise specific actions I needed to implement for the resumption of our grinding operations. I suddenly became optimistic.
Dr. Blume and the Minneapolis DO manager eventually hammered out a number of actions for me to implement to gain the right to resume grinding under USDA inspection auspices. I fully complied with this list, and submitted the finished list to the DO which rejected it as “inadequate”. Dr. Helmut Blume was shocked, not understanding how the agreement he had with Minneapolis was summarily rejected as “inadequate”. Dr. Blume suggested that maybe he couldn’t help me, and perhaps I didn’t want his assistance. I disagreed, stating that he was my only hope. So, Dr. Blume dejectedly offered to contact the Minneapolis DO again, and see if an agreement could be hammered out.
Well, an agreement was made, and Dr. Blume again provided me an itemized list of requirements mandated by the Minneapolis DO, with which I fully complied. After reviewing these corrective actions, the DO concluded that the newest measures were “inadequate”. Now, the cat (a.k.a. agency corruption) was fully out of the bag. The FSIS District Office in Minneapolis was now engaged in overt corruption, perhaps mandated from top agency officials in DC. Perhaps for the first time, NCBA, NMA, and Helmut Blume perceived the full extent of the agency’s corruption at my plant. They also realized that the previous relationships they had developed over the decades with FSIS officials was valueless. Damn the evidence!
Please remember here that FSIS piously proclaims that each plant can write its own HACCP Plan, and that the agency can’t dictate what belongs in the HACCP Plan. Actions by the Minneapolis DO provide a new definition for the term “disingenuous”. But mind you, Minneapolis DO actions were based in “science”.
When I contacted Dr. Blume with this development, he was incredulous. I suggested to him “Perhaps now is the time for me to go public”. I fully anticipated Dr. Blume would forcefully disagree, because he was a HACCP advocate, and was loyal to the agency. Nevertheless, after several surprising seconds of hesitation, he defiantly replied “Give Mickey [DO manager] one more chance, then go public”.
During the four months we couldn’t grind, we lost many customers. Our competitors referred to us as “that E.coli plant” with great success. We came to discover that our customers slowly developed the perception, over four long months, that E.coli O157:H7 had become pervasive in our plant, potentially cross-contaminating all our other products as well. One angry customer called, and asked “When did you start trying to kill your customers?” Sales plummeted. It was an ugly sight to watch our family owned business atrophy.
At that time, my family had owned and managed the business for 56 years, and I readily perceived that I would be the shamed captain as our ship sank into the agency’s bottomless abyss of corruption and virtual lack of accountability. But, as is said “It is darkest just before the dawn”, I did not see the bright light which was around the corner, one which no author could ever devise in his/her wildest imaginations. Just when FSIS was about to tip me over, it was upended itself by what I call divine intervention, which will be revealed in Part Three.
Didn’t read Part 1 of this series? Please read “Confessions of a Montana ‘E. Coli Terrorist.’”
Source: John Munsell
Posted by Haylie Shipp
