National Advisory Committee on
Meat and Poultry Inspection Meeting
June 5, 2001
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
- 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
[Ex thermal processing – equipment maintenance SOP]
- Interpretation of "May" vs. "Reasonably Likely"
We basically agree that the Agency cannot respond positively to this
part of the petition at this time.
- 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
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?
FSIS should try not to judge too narrowly.
Encourage Development and adoption of technology – esp. to eliminate