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
- 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
- The provision regarding inadequate plans is too strictly
- 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,
- 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
- Develop non-regulatory documents (Directive/Notices) to address
aspects of the petition requiring clarification rather than regulatory
- Investigate the development of regulatory changes, as well as the
impact of any changes since no data were submitted with the petition.
- 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?
- 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?
- Should FSIS consider regulatory modifications
that would acknowledge the prerequisite programs concept of NACMCF?
- 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
- What will be the effects of making FSIS and
FDA HACCP regulatory requirements dissimilar?
- 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