IKE Scenario 02-02: Salmonella "A set" Failure: February 14, 2002
You are an IIC in a large broiler plant. Today you logged onto LEARN and observed completed set results stating, "SET FAIL", were transmitted for the Salmonella performance standard "A set". You are familiar with directives associated with accessing LEARN, inspector responsibilities corresponding with subsequent enforcement actions, and recent direction from the District Manager outlining newly established day-to-day activities in establishments subject to Salmonella performance standards.
As a critical thinker, what actions would you take at this point?
|You are aware that notification directed to the establishment, which indicates that they did not meet the performance standard, will take the form of a letter issued from the District Office...not an NR. This is a recent policy change.|
|You conduct an assessment of the HACCP plan and SSOP procedures to determine if they have been implemented correctly. You review the acceptability of the hazard analysis, decisions, supporting documentation, and CCP justification statements. You note the hazard analysis indicates use of trisodium phosphate is not identified as an antimicrobial intervention. Use is stated as a quality issue and a food safety hazard is not listed at that specific process step. Through review and observation while performing you 03J procedures, you have observed monitoring of the densitometer on an hourly frequency. The calibration of this equipment for process monitoring is performed at a weekly interval. You remember a problem with calibration recently. Review of the documents indicate that five positive Salmonella findings occurred during the period of time that the TSP percentage dropped to 5 percent as a result of a calibration problem. Typically, the plant maintains and monitors a minimum of 8 percent TSP.|
|You prepare to conduct a comprehensive review and evaluation of data generated from inspection findings for slaughter (03J) with SSOP data, E. coli data, and Salmonella performance standard data during the "A set" collection time frame. Your primary focus is trend identification and relational links bridging the systems.|
|You verify that the slaughter dressing process is in control to prevent fecal contamination. Correlations between zero tolerance noncompliances and stated corrective action are evaluated. Review of the accepted responses from plant management assists to determine if a design failure exists or there has been a failure to execute proposed corrective action. You note similar responses for the last 10 noncompliances, "will slow the line when heavier fowl are slaughtered". You have never observed management segregate birds by weight or voluntarily slow the line.|
|Plant management presents and initiates further planned action in response to the letter received from the District Office, which outlined their responsibilities subsequent to their failure to meet the performance standard. After concurrence with your circuit supervisor, you develop and execute an action plan to verify implementation of corrective actions by plant management. In addition, you report your findings electronically at a specified interval to the circuit supervisor with a cc. to the District Manager.|
These actions are consistent with the message provided in the Next Step Work Unit meetings conducted by the Agency.
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