Food Safety and Inspection Service United States Department of Agriculture Washington, D.C. 20250-3700

Key Facts: HACCP Final Rule

Revised January 1998

Key Facts: Role of the Inspector Under HACCP

The Pathogen Reduction; Hazard Analysis and Critical Control Point (HACCP) Systems; Final Rule establishes far-reaching changes in the respective roles of industry and FSIS inspection personnel in assuring the public a meat and poultry food supply that meets appropriate sanitation and safety standards and is not adulterated or misbranded. This new regulatory system represents a change in regulatory philosophy and thus changes the focus, tasks, behavior, and priorities of Agency employees--particularly frontline employees and supervisors. It more clearly defines and separates the role of the food producer and regulator.

• Traditionally, some plants have relied on inspectors to identify deficiencies on a daily basis before the company would take action to correct food safety problems. This factor, and the prescriptive nature of the requirements, often blurred the line between industry and regulator.

• The final rule clarifies that regulated establishments are to be responsible for manufacturing products that are not adulterated or misbranded and meet performance criteria and standards.

• Under the new system, plants have clear, affirmative responsibilities for preventing food safety hazards. The Agency’s enforcement strategy, based on Salmonella testing by FSIS, embodies an objective, uniform systems approach that will be administered and applied in a fair, equitable, and common sense manner. The Agency will continually monitor and adjust its enforcement program and activities to reflect these principles while ensuring food safety.

• Many of the activities carried out in the traditional inspection program, including carcass-by-carcass inspection, not only responded to some of the public’s most basic expectations of its government, but are also required by law. These activities will continue.

• Inspector’s roles under HACCP will change based on the implementation schedule contained in the final rule. Effective January 26, 1998, large plants (500 or more employees) implemented HACCP. Small plants (10 or more employees but fewer than 500) will be required to implement HACCP by January 25, 1999, and very small plants (under 10 employees or annual sales of less than $2.5 million) must meet this requirement by January 25, 2000. Until all plants are operating under the Pathogen Reduction and HACCP rule, inspectors will be carrying out both traditional and HACCP-based inspection, but in different plants.

• Under the new system, FSIS inspection personnel exercise the following regulatory oversight responsibilities:

• Determine Basic Compliance/Noncompliance. The inspector will decide on the adequacy of an establishment’s initial sanitation standard operating procedure (SSOP), HACCP plan, and E. coli testing to ensure they conform with regulatory requirements. If needed, the inspector will decide on the adequacy of any revisions.

• Determine Other Compliance/Noncompliance. The inspector will decide, on an ongoing basis, that an establishment is: (a) carrying out its HACCP and SSOP plans and E. coli testing, as well as meeting the Salmonella pathogen reduction performance standards; and (b) meeting the regulatory requirements for economic adulteration, wholesomeness, residue, export, custom exempt/retail, facilities and equipment, sewage, water, and pest and rodent control.

• Prepare Noncompliance Reports. The inspector will document failure to meet regulatory requirements.

• Take Enforcement Actions. The inspector will take appropriate actions when a plant is not in conformance with established regulatory requirements.

• The Agency will examine current tasks related to carcass-by-carcass inspection to determine what changes should be made to improve effectiveness and make the use of inspection resources more productive. This review will ensure that inspector tasks will remain consistent with the new HACCP requirements at slaughter, FSIS’s verification strategy, improvements in process control under HACCP, and the new performance criteria and standards.

For Further Information Contact:

• Media Inquiries: (202) 720-9113
• Congressional Inquiries: (202) 720-3897
• Constituent Inquiries: (202) 720-8594
• Consumer Inquiries: Call the USDA Meat and Poultry Hotline at 1-800-535-4555; in the Washington, DC area, call (202) 720-3333; TTY: 1-800-256-7072. 

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