IKE Scenario 04-02:  SALMONELLA EARLY WARNING:  MARCH13, 2002

You are an inspector at a large pork slaughter plant. The plant is currently in the process of being sampled for market hogs Salmonella performance standard testing. Plant management tells you that they received a call from the District Office informing them that positive results for this sample set are currently one over the 50% of the maximum number of positives allowed for meeting the standard. This call served as an "early warning" notification that the plant is on target to fail this set.

Plant management recognized the serious nature of the call and has established additional anti-microbial intervention measures after reassessment of their 03J HACCP plan. Their request for suspending sampling relates to a "reasonable period of time to validate the efficacy of the newly established measures". They are respectively requesting that you stop sampling for a month.

After consideration of the rationale provided by plant management, what actions should you take?

Inform plant management that reassessment and modification of their HACCP plan is appropriate, but the collection of the sample set continues until completion. Existing policy does not provide allowances for validation of newly established procedures once sample set collection begins.
The "early warning" notification report which is provided orally by the District Office sets forth language regarding the continuation of the sample set. It clearly indicates that "FSIS will continue to collect samples until the sample set is complete."
Knowing the plant has reassessed and modified their HACCP plan, you would perform an 03A01 unscheduled, basic compliance, procedure using FSIS Form 5000.1 to determine if the HACCP plan still meets regulatory requirements.

As the IIC, you are aware of the recent direction from the district manager outlining newly established day-to-day activities in establishments subject to Salmonella Performance Standards. You decide to assess the data available and create an action plan. You review the NRs* in the file, PBIS Establishment summary data, PREP data, and plant records associated with SSOPs and HACCP. You evaluate the data to determine if trends exist to direct your subsequent actions. You correlate with your in-plant inspection team to ensure that they understand the action plan you have developed. You want to pay particular attention to 05A02, 03J, 01B, 01C procedures. What corrective actions has the establishment implemented to date?

Note: Implementation of newly established measures is commendable, but agency expectations are that a prudent establishment would perform reassessments of their HACCP plans on an ongoing basis and implement necessary anti-microbial interventions as necessary to meet the performance standard.

Note: "Early Warning" notification is provided to plant management by a representative of the District Office. This is to afford plant management the opportunity to make necessary adjustments to ensure that the performance standard are met. Additionally, the prompt for the "early warning" notification may occur at different times throughout the completion of the sample set. It may occur early during the sample set or it may occur late enough to preclude a meaningful evaluation of the process and, as a result, not provide sufficient time to make appropriate process modifications

 

 

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