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

Office of Policy, Program Development and Evaluation

Meat and Poultry Advisory Committee Staff

Standing Sub-Committee Number 2

Issue – Industry’s Petition for Proposed Changes to HACCP Final Rule:
Agency Current Thinking

1.  What is the Committee’s reaction to the Agency’s thinking? – We basically agree

1. FSIS must define pre-requisite programs

Pre-requisite programs should enhance CCPs.

Pre-requisite programs should be in a separate section of the regulations. (The legal authority to review records)

Voluntary, but verifiable i.e., proper documentation accessible to FSIS

[Ex thermal processing – equipment maintenance SOP]

2. Interpretation of "May" vs. "Reasonably Likely"

We basically agree that the Agency cannot respond positively to this part of the petition at this time.

3. Produced vs. Enter Commerce

We feel that "produced" is the proper term – "produced" is after pre-shipment review – pre-shipment review, if not completed, product can move off-site while awaiting test result – still under plant control

2.  Are there additional factors or concerns that should be considered by the Agency in developing its
response to the petition?

The Agency should address implementation issues identified by the Agency including its inspectors and by industry.

3.  Are there additional areas of concern about which the Agency should develop guidance and instructional material to continue the success of HACCP implementation?

Improve Training

FSIS should try not to judge too narrowly.

Encourage Development and adoption of technology – esp. to eliminate subjective judgments.

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Last modified:  November 25, 2002