Avoiding Noncompliance Part 2
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Welcome. Iím Sheila Johnson with FSIS. With me today is Pam Ogasawara from the Office
of Field Operations to talk about ways you can prevent noncompliance records.
Pam has been with FSIS for more than 20 years. In addition to being an inspector in plants
in the United States, she has reviewed meat and poultry plants and laboratories overseas
as well. As the deputy director for the State Program Liaison Staff, Pam worked closely
with state programs and other federal agencies on inspection issues. Currently, sheís
a program manager focusing on new inspection initiatives.
Thanks for coming by, Pam.
Iím glad to be here, Sheila.
In an earlier podcast we started off our discussion on noncompliance records Ė recommending that small and
very small plant managers study the regulations closely to keep their plant in compliance.
Today, weíre going to delve a little deeper and cite some specific examples in which FSIS
would generate a noncompliance record, or NR.
Pam, what are some common examples of NRs you have encountered?
One common NR involves noncompliance with regulatory requirements related to monitoring
procedures and frequencies in the plantís HACCP plan.
Basically, in the Hazard Analysis, the plant determines whether there are food safety
hazards at each step in the process.
If a hazard is identified it is reasonably likely to occur, then the plant puts a Critical
Control Point in its HACCP plan to control the food safety hazard at that step.
Each Critical Control Point has a Critical Limit. This is the maximum or mininum value
to which a food safety hazard must be controlled to prevent, eliminate, or reduce the
hazard to an acceptable level.
For each Critical Control Point in its HACCP plan, the plant must list the monitoring
procedures needed and the frequency at which they should be performed to ensure the Critical
Limits are met.
Plant personnel are then responsible for following the HACCP plan by conducting the monitoring
procedures at each Critical Control Point at the correct frequency to ensure compliance
with the Critical Limits.
Okay. Letís illustrate a scenario for our listeners.
Sure. Letís say the HACCP plan for a swine slaughter plant has a Critical Control Point
that requires the monitoring personnel to examine four swine carcasses per hour for visible
fecal contamination before FSIS inspects the carcass.
While performing verification of the monitoring requirement, the FSIS inspector determines
that the plantís employees did not examine any carcass between 9 and 10 a.m.
So, the FSIS inspector will say that the plant personnel are not conducting monitoring
procedures as specified in the HACCP plan and the incident must be documented as a noncompliance?
Youíre absolutely correct. Itís very important for plant employees to follow the HACCP
plan, because if it is not followed, food safety may be jeopardized.
Letís illustrate another example. Letís say the HACCP plan in a poultry slaughter plant
specifies that the Critical Limit for a chlorinated carcass rinse is a concentration of
20 to 50 parts per million chlorine.
The monitoring procedures specified in the HACCP plan require that the plant personnel
measure the chlorine concentration twice per eight hour shift.
While reviewing the monitoring logbook for this Critical Control Point, FSIS inspectors
determine that during the last three days, monitoring checks for the chlorine concentration
were conducted only once per eight hour shift. So, what does that mean?
The incident must be documented as a noncompliance since the plant did not perform monitoring
procedures at the frequency specified in its HACCP plan.
Youíve got it! And, in response to the NR, the plant must provide corrective actions and
preventive measures to identify the cause and eliminate it from happening again.
So, to avoid monitoring noncompliance, you need to be sure that the plant employees fully
understand the importance of checking the HACCP plan and conduct the monitoring procedures
at the frequency listed in the HACCP plan.
You may also want to consider the frequency that is set in the HACCP plan for plant employees
to conduct verification procedures which verify that the plan is implemented as written.
Well, this is very interesting. I believe these specific examples youíve brought to light
will be very helpful for our listeners. Pam, thanks again for taking the time to explain
how plants can prevent noncompliance.
In future podcasts, weíll address the appeals process and other concerns such as recordkeeping,
supporting documentation and record authenticity often documented on NRs.
For more information, please visit the FSIS Web site at
www.fsis.usda.gov. Thanks for tuning in.
Well, thatís all for this episode. Weíd like your feedback on our podcast. Or if you
have ideas for future podcasts, send us an e-mail at
email@example.com. To learn more about food safety, try our web site at
www.fsis.usda.gov. Thanks for tuning