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

Industry Petition to Amend Meat and Poultry HACCP Regulations

National Advisory Committee on Meat and Poultry Inspection
May 2000 Public Meeting

Issue Paper on Current Thinking

• Industry Petition on HACCP ("Amend the meat and poultry HACCP regulations to increase the effectiveness of the HACCP systems").

• The American Meat Institute submitted a petition to the agency, on behalf of a group of eight industry organizations.

• The petitioner requested that the agency amend specific sections of the HACCP regulations (9 CFR 417) to improve them and to make them more consistent with the HACCP principles published in 1998 by the National Advisory Committee on Microbiological Criteria for Food (NACMCF).

• The HACCP regulations (9 CFR 417) became effective in January 1997 and were based, in large part, on an earlier version of the HACCP principles document published by NACMCF.

• FSIS considers the issues raised by the petitioner to be related to the implementation of HACCP and, as such, is a policy matter of importance to NACMPI.

• The petitioners support the adoption of HACCP as the best system available for enhancing the safety of meat and poultry.

• The petitioners identified numerous "technical" differences between the NACMCF principles document and 9 CFR 417 requirements. The differences are summarized, as follows:

• The rule is written and interpreted too narrowly.

• The definition and interpretation of a food safety hazard is different from the NACMCF principles document.

• The rule does not adequately define when a product is within an establishment’s control.

• The provision regarding inadequate plans is too strictly interpreted.

• FSIS is pursuing the following plan for addressing the petition:

• Draft and send a letter acknowledging receipt of the petition.

• The agency submitted a response on January 21, 2000.

• The petition is identified with the number 00-01.

• Publish the petition in a Federal Register Notice.

• Begin surveying selected establishments to assess the content of HACCP plans.

• Develop non-regulatory documents (Directive/Notices) to address aspects of the petition requiring clarification rather than regulatory changes.

• Investigate the development of regulatory changes, as well as the impact of any changes since no data were submitted with the petition.

1. The industry petition relies mainly on the NACMCF document and does not provide any data or examples to support its request. Is NACMPI aware of information that would support taking any of the actions requested in the petition?

2. Would amending 417.2(a) in the manner suggested in the petition result in regulations that provide the level of public health protection required by the FMIA and the PPIA?

3. Should FSIS consider regulatory modifications that would acknowledge the prerequisite programs concept of NACMCF?

4. Do FDA regulations, such as GMP regulations, offer an approach that FSIS should consider? How would such an approach fit within the HACCP concept? How would FSIS implement such an approach?

5. What will be the effects of making FSIS and FDA HACCP regulatory requirements dissimilar?

6. Should the changes suggested in the industry petition be considered in light of the views expressed on HACCP by Codex and other countries?

• Daniel L. Engeljohn, Director, Regulatory Development Division (202) 720-5627.

• Copy of petition.

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Last modified:  November 25, 2002