The In-Distribution Project

Table of Contents

Background
Activities
Accomplishments
Conclusion and Recommendation
Appendix 1

  
I. Background

FSIS’ goal is to reduce the risk of foodborne illness associated with the consumption of meat and poultry products to the extent possible.  To achieve this goal, FSIS is carrying out a strategy that recognizes the need to take steps at each segment of the farm-to-table continuum to improve food safety.

A significant challenge to the Agency in effecting this strategy is to determine how to deploy its inspectors and enforcement personnel so that they are in place to respond to the needs identified using public health risk analysis principles.  For example, there are indications that risks to consumers from inspected products sometimes stem from hazards associated with the handling of products during transportation, storage, and retail sale (commonly referred to as in-distribution).  Although in some cases other agencies have the authority, and possibly the resources, to respond to these types of problems, in many cases they do not.  In such cases, it is important that FSIS have the ability to use its resources to address the risks identified.  One of the ways that FSIS is developing its ability to address hazards at every step of the farm-to-table continuum is by experimenting with placing inspectors in the food distribution chain to ensure that food safety gains made inside the meat and poultry establishments with the implementation of SSOPs and HACCP are not lost because of mishandling of product after it leaves the plant.

Thus, FSIS has been developing and evaluating an in-distribution project that will permit the Agency to decide whether, and, if so, where and how, to deploy its inspectors at in-distribution sites.  FSIS’ role in distribution is to focus on meat and poultry products that have been produced by federally inspected establishments to verify that they are not being adulterated or misbranded as they move to the consumer.

The in-distribution project is intended to provide FSIS with an opportunity to analyze conditions that occur outside federally inspected plants.  A second goal is to measure the effect of a sustained FSIS presence on those conditions.  A third objective of the project is to obtain information about how to coordinate FSIS food safety verification activities in distribution with those already being performed by state and local governments. FSIS is interested in exploring cooperative agreements with State and local governments that would assist in ensuring the government’s ability to maintain the integrity of the mark of inspection.

II. Activities

Phase One:

Phase One of the project began in 1999. FSIS identified four separate locations for the first in-distribution test areas—Philadelphia-Hatfield, PA circuits; Harrisonburg, VA and surrounding areas; Alabama; and an area that includes three circuits in Minnesota.  The locations were selected because they are examples of an urban areas, rural areas, and combination urban-rural areas.

In Phase One of the project, FSIS deployed 11 consumer safety inspectors to verify the safety and wholesomeness of meat and poultry products as they move to consumers.  They received compliance based training to prepare them for their duties.

After formal training was presented to the In-Distribution Inspectors (IDIs) in January 2000, they participated in a two-week, on-the-job shadow training with a compliance officer.  This activity was completed in April of 2000.  The duties IDIs performed in Phase One included reviewing of a wide range of commercial operations, examining meat and poultry products in commerce, conducting recall effectiveness checks, conducting sampling to verify compliance with FSIS requirements, and conducting follow-up inquiries on consumer complaints.

During Phase One of the project over 1000 firms were visited.  IDI’s performed inspection of 106 different meat and poultry products at these firms.  These visits resulted in 3 notices of detention.

As the project progressed, FSIS decided in April 2000 to focus it on product that bears the mark of inspection that is actually in distribution channels.  FSIS also determined that information gathering would be a significant role for IDIs.  The Agency’s expectation was that the information that IDIs gathered would help FSIS to determine the hazards and risks to the public presented by conditions occurring in distribution channels.

Based on the refinement in the focus of the project, a public meeting was held in June of 2000.  This meeting was designed to inform the public of the Agency’s thinking and to obtain input from interested constituents.

Attendees at the public meeting were informed of the Agency’s desire to use the project to obtain information on how best to ensure food safety in distribution, and how FSIS can more effectively use its resources.  The agency stated that the project would still be limited to the existing 11 in-distribution inspectors, with exploration into developing partnerships with state and local jurisdictions.  FSIS also stated that the focus of the project is to verify the safety of meat and poultry products in-distribution, to collect information to determine how to improve approaches to verifying food safety in distribution channels, and to evaluate in-plant HACCP programs based on information gathered through the project.  The Agency stated that the verification analyses conducted by the IDIs would be food- safety driven, as well as addressing other consumer protection concerns.

Additional training focusing on understanding food safety hazards and controls was provided to IDIs from June through September 2000.  The IDIs then began using this training to make determinations regarding the integrity of the mark of inspection on product being held in warehouses and by distribution firms.

IDIs obtain information and determine whether conditions exist that may render product adulterated and perform sampling activities as directed by Headquarters.  In cases where a determination is made that there is product that appears to be adulterated or misbranded, the suspect violations are referred to the District Offices for enforcement action.  FSIS is also exploring whether some other consumer protection activities that are being carried out within the plant may better be carried out while products are in distribution channels, such as nutrition labeling verification.

Another aspect of Phase Two has been to actively explore forging partnerships with state and local entities, including developing a relationship with the Minnesota Department of Agriculture.  We have included Minnesota State inspectors in our training activities and provided them with the same instructional manual that is used by FSIS IDIs.  The State inspectors coordinate with the IDIs in Minnesota to assure that we are not conducting duplicative efforts.  Our IDIs also furnish information on state product when it is observed during their activities.  In one instance, a case of uninspected product was referred to the state for action.  IDIs in all four states coordinate with state officials and sometimes local departments.  FSIS in-distribution personnel concentrate on firms that have not received state visits and on entities with respect to which no information on inspected product conditions exists.

In Phase Two of the project, IDIs have visited 1500 in-distribution firms, including retail stores, restaurants, warehouses, cold storage facilities, nursing homes, hospitals, and hotels.  Over the past few months alone, over 440 retail observations and analyses were conducted, 223 at distributors and 67 at hotels and restaurants.  These visits include observations and information covering eight of the nine HACCP processes.  The examinations have indicated that the majority of potential hazards in these firms are physical with biological hazards reported next in order of precedence.  This information has been used to allow FSIS to focus its in distribution efforts where they will have the greatest impact on public health protection.

III. Accomplishments

The Agency has made progress in structuring the in-distribution project to obtain information and to design a method to ensure that the effort results in improved food safety and public health protection throughout the distribution continuum.  There are a number of steps we have taken to achieve this end.

Over the past year FSIS has continued to update the manual for IDIs.  These updates are the results of correlation with the field IDIs.  Frequently asked questions and their answers have been incorporated into the manual text.

In addition, FSIS has added a form to allow for collection of shipping data from a federally inspected plant.  This form is used in conjunction with a visit to the distribution firm.  New forms also focus on reporting the nature and types of food safety hazards encountered, the controls that exist, if any, and the types of control programs that firms have in place.  These may be programs such as cross contamination prevention, recall procedures, sanitation standard operating procedures, or HACCP plans.  These forms allow reporting of conditions in firms that have a direct impact on food safety.  FSIS uses these forms to correlate and analyze the results of IDI visits.  Headquarters uses this information to determine if there is a particular type of firm that poses particular public health hazards.  The information will be used to report local IDI activities to circuit supervisors and to the states in which we are establishing partnerships.  FSIS is also using the data to determine any correlation between the conditions observed in-distribution and the performance of federally inspected plants.

The results of our study to date indicate that nearly all in-distribution firms, regardless of size, are aware of and have in place a method to control product temperature.  Most firms also have some type of employee training and at least a basic understanding of sanitary procedures, even if no written or formal sanitation program exists.  Although the existence of HACCP plans is restricted mainly to large corporate entities, many smaller firms are becoming aware of the need for process control.

The project has resulted in raising the awareness of food safety hazards in firms in distribution channels, and of the controls that are needed to address these hazards to ensure safe products reach the consuming public.

The visits by IDIs have also resulted in a positive public health impact, as firms become aware of systematic methods of control through discussions with in-distribution personnel.  The IDIs are serving not only to ensure the integrity of the mark of inspection, and thereby food safety, but are also providing valuable information to these firms on food safety controls.

We are learning about the hazards that present themselves to in-distribution firms, the controls that are being used to ensure that product does not become adulterated or misbranded, and how effective performance standards can be framed to ensure that adverse effects from the hazards do not occur.

Based on the analysis of the information from the project a number of areas have been identified for exploration.  The questions that we will be exploring are:

Do in-distribution firms have written GMPs or SOPs; sanitation programs; building and maintenance programs; recall/holding procedures; microbiological testing programs for environmental conditions or product; quality control or product standard testing; pest control programs; HACCP plans; returned goods/product disposal programs; cross contamination controls; temperature controls for product in storage, in production, in transit, and for incoming product; and do firms conduct physical condition examinations of product?  These areas have been identified as crucial to hazard control and the presence or absence of these controls will reveal a great deal about the state of in distribution firms ability to maintain product in an unadulterated condition.

IV. Conclusion and Recommendation

As part of FSIS’ commitment to a farm to table food safety approach to protecting the public health, the IDI program is the first effort that systematically explores the conditions in firms that handle meat and poultry products after they leave the official establishment.  The information derived from this project can benefit all segments of the meat and poultry food production, distribution, and service industries.  The project will also allow FSIS to begin to gauge the effect of FSIS educational outreach at the state and local inspection levels. It will also allow FSIS to increase effective response at the retail level in case of an outbreak where product is in the market place.

These activities will assist the Agency in reaching its goal of having firms recognize and prevent hazards that may result in foodborne illness before product reaches the consumer.  This will be accomplished through cooperative agreements, partnerships, and information gathering and assessment.

We believe that a continuation of this effort is warranted and will bring us closer to our goal of becoming a more effective food safety regulatory agency using risk analysis principles to make determinations about managing our resources to protect the public health.

Appendix 1

In-Distribution Timeline of Activities:

HIMP | In-Distribution Inspection Project | Outreach | OCP Activities

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Last Modified: 01/22/2004