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History of HACCP-Based Inspection Models Project
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Background
The HACCP-Based Inspection Models Project (HIMP) was
developed by the Food Safety and Inspection Service (FSIS)
to produce a flexible, more efficient, fully integrated meat
and poultry inspection system. The HIMP system, in contrast
with the traditional inspection system, focuses more control
for food safety and other consumer protection activities on
the establishment with Agency personnel focusing on carcass
and verification system activities. FSIS expects this system
to yield increased food-safety and other benefits to
consumers, and will permit FSIS to deploy its in-plant
resources more effectively.
In 1997, FSIS, first announced plans in the "Pathogen
Reduction; Hazard Analysis and Critical Control Point
Systems" (PR/HACCP) final rule (61FR 38806; July 25, 1996)
to develop a project and test new models for inspecting
certain meat and poultry products. The HIMP project was
initiated in July 10, 1997 Federal Register
Notice, "HACCP-Based Meat and Poultry Inspection Concepts". The HIMP notice
requested public comment on the design and development of
new inspection models for the slaughter and processing of
young, healthy, uniform animals under HACCP systems.
There were also numerous public meetings held to solicit
public input and comment on the project.
Based on the responses to the Federal Register Notice and
input from public meetings, FSIS developed inspection models
for the selected market classes and made slaughter process
control an industry responsibility subject to FSIS carcass
and verification inspection. The models would enable FSIS
to:
- maintain and enhance the food safety and other consumer
protection benefits of the current carcass inspection
system;
- effectively and efficiently oversee, evaluate, and verify
industry implementation of the PR/HACCP regulations.
After outlining the objectives the Agency hoped to
accomplish with the project, FSIS solicited volunteer plants
to participate. FSIS only solicited volunteers from plants that slaughter market hogs and young
poultry (including young turkeys) since these classes of
animals are composed typically of young, healthy animals.
The paper "HACCP-Based Inspection Models Project: In-plant
Slaughter"
outlines the establishment process control responsibilities
and FSIS inspection activities that are carried out during
the in-plant phase of the project, and described the
microbial and organoleptic evaluation procedures which the
project team will carry out. Under the program, plant
employees conduct anatomical and pathological examinations
of carcasses, and FSIS inspectors oversee, evaluate, and
verify the effectiveness and reliability of the
establishments' slaughter process controls.
Project Design and Data Collection
T
he HACCP-Based Inspection Models Project is composed of two
phases: (1) the Baseline Phase; and (2) the Models Phase.
During the Baseline phase the Research Triangle Institute (RTI),
an independent consulting firm, collects organoleptic and
microbial data, which indicates the accomplishments of the
plant's current traditional inspection system. The Models
phase consists of a Transition period and a second data
collection period. At the end of the Transition period, when
both the volunteer plants and the Agency have made any
necessary adjustments to procedures, data are again
collected in order to evaluate the achievements of the
Models phase and the plants continue to operate under the
new procedures as Model plants.
Additional collected data is added to the existing data to
establish national performance standards for plants
slaughtering each of the market classes included in the
project.
The Research Triangle Institute (RTI) collected Baseline
data in 16 young chicken plants, 5 market hog plants, and 5
young turkey plants between 1998 and 2000. Over a six-week
period, 300 microbial samples were collected and analyzed
for Salmonella and for Generic E. Coli in each plant.
Similarly in each plant, 2000 carcasses were scored for a
variety of organoleptic defects, over a five week period.
FSIS developed and published performance standards on
November 2, 2000, for each species involved in the project
using the collected data. The performance standards specific
for each plant participating in the project provided a
scientifically valid measure by which changes in food safety
and other consumer protection data can be assessed.
The project involves new roles and responsibilities for
participating plants. Each plant must modify its HACCP plan
to include at least one critical control point addressing
food safety diseases and conditions. In addition, each plant
developed a process control plan to address other consumer
protection concerns that are not food safety related, such
as removing bruises and other quality defects.
New roles for FSIS inspectors have also been developed. To
meet these roles inspectors are given two weeks of HACCP
training and one week of carcass and verification training.
Supervisors are also trained in Statistical Process Control.
With HACCP and other process control programs in place,
plants will identify and remove from the slaughter
production process carcasses and parts of carcasses that are
unacceptable because they are diseased and unwholesome. When
volunteer plants assume these process control
responsibilities, the FSIS inspection team will be able to
implement new slaughter inspection procedures that verify
the effectiveness of the plant's modified HACCP and new
process control plans.
In pilot plants, slaughter inspection will consist of two
types of procedures: carcass inspection and verification
inspection.
Carcass inspection accomplishes post-mortem inspection of
each carcass after the plant has completed carcass sorting
activities. The carcass inspector is stationed on the line
at a fixed location and completes the critical determination
for application of the marks of inspection.
The verification inspector takes samples of products and
plant records and carefully examines them. Verification
inspection focuses on the HACCP and process control plans
and whether the plant is meeting relevant carcass
performance standards.
The Research Triangle Institute (RTI) collected data again
after the plants and FSIS had initiated the models phase.
RTI has collected microbial and organoleptic models data in
16 young chicken plants and 3 market hog plants from
September of 2000 to December of 2001.
FSIS has also collected verification data on the project
when a plant enters the model phase. As of this date, FSIS
has collected over 1 million samples in Food Safety and 350
thousand samples for the Other Consumer Protection
categories. All data collected shows improvement.
Currently the project has 19 Young Chicken plants, 3 Market
Hog Plants, and 2 Young Turkey Plant in the models phase of
the project. The pending list of Young Chicken plants to
enter the project has increased to over 30 plants. Also
another Market Hog plant as well as 2 more Young Turkey
plants will enter the project in early 2002.
Court Case
In September 2001 the American Federation of Government
Employees (AFGE) filed an appeal to the District Court
decision and a new panel of judges were appointed as panel
members for the case. The Agency and AFGE also filed briefs.
On Friday, January 11, 2002, the United States Court of
Appeals for the District Circuit heard oral arguments in the
case of the AFGE v. Ann Veneman, et al. (i.e., the
Department of Agriculture). A Justice Department attorney
represented FSIS arguing that the HIMP system has been
redesigned and is in compliance with the statutes and the
prior opinion of the court. The Agency is awaiting the
ruling of the court and has been advised that their decision
could be rendered within a few months.
Conclusion
FSIS is continuing the HACCP-Based Models Project because
the Agency believes that the project has been shown to
improve food safety and other consumer protections and
expects to publish a proposed rule. The new models
capitalize on the food safety and other consumer protection
gains garnered by the HIMP project thus far, while still
meeting the demands of the inspection laws. Under the Models
Project, FSIS is requiring improvements in the protections
that are currently achieved under the traditional
inspection. Data collected from this project show
significant improvements in both food safety and other
consumer protections.
Jan 15, 2002
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