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Food Safety and Inspection
Service United States Department of Agriculture Washington, D.C. 20250-3700 |
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Food Safety and Inspection
Service United States Department of Agriculture Washington, D.C. 20250-3700 |
Backgrounders
October 1999
FSIS is beginning the models phase of the HACCP-based inspection models project. The models phase has two parts--the transition phase and the data collection phase. Under the transition phase, participating plants will begin assuming their new responsibilities, and FSIS will begin new inspection procedures. Under the data collection phase, organoleptic and microbial data will be collected to determine the achievements of the new system.
Under the project, volunteer plants are extending their HACCP and other process control systems to cover certain activities conducted before and after slaughter that are not currently covered under HACCP. Plants will be responsible for preventing meat and poultry that are unsafe or unwholesome from entering the food supply. They will carry out these activities under FSIS oversight inspection and verification inspection and will be required to meet FSIS performance standards.
The project will improve food safety by allowing the Agency to use its inspection resources more efficiently and effectively to protect the public health. FSIS will be able to carry out additional food safety tasks within the plant, redeploy some inspectors to verify the safety and wholesomeness of meat and poultry products after they leave the plant, and to help fill existing inspection vacancies.
The project is a natural extension of the Agency’s implementation of HACCP in all meat and poultry plants. Under HACCP, plants identify and evaluate the food safety hazards that could affect the safety of their products and institute controls necessary to prevent those hazards from occurring or to keep them within acceptable limits. However, HACCP does not currently apply to all activities associated with the slaughter process; FSIS continues to use its slaughter inspection workforce in traditional ways. This means that during the traditional slaughter process, FSIS inspectors have assumed responsibility for identifying and removing defects, defining corrective actions, and solving production control problems. This contrasts with HACCP, under which plants assume their proper responsibilities for process control, and FSIS sets performance standards and verifies that they are meeting these and other regulatory requirements.
With inspectors in these slaughter plants no longer carrying out process control activities, which are the plant’s responsibility, FSIS can better focus on public health concerns and further implement its farm-to-table strategy. FSIS believes there are additional tasks within slaughter plants, such as verification of the zero tolerance standard for fecal contamination, sampling for pathogenic microorganisms, and verification of HACCP systems, that deserve more attention in all plants, not just those operating under the models. In addition, FSIS is concurrently developing an in-distribution inspection model under which some inspectors currently assigned to plants will be redeployed to verify the safety and wholesomeness of meat and poultry products after they leave the plant.
Only plants that slaughter market hogs and young poultry (including young turkeys) are participating in the project. These classes are composed of young, healthy animals. FSIS is not planning to extend this project to other classes of animals that may have more complex pathology or other problems to address. As of Sept. 17, 1999, 28 plants have volunteered for the project—3 hog, 5 turkey, and 20 chicken.
Baseline data are being collected in the pilot plants to document the accomplishments of the current inspection system, before the models are tested. FSIS has contracted with Research Triangle Institute (RTI), an independent consulting firm, to collect both microbiological and organoleptic data. As of Sept. 17, baseline data have been collected in 16 plants. As data are collected, they are added to existing data so that national performance standards can be established for plants slaughtering each of the market classes included in the project. FSIS has released two reports to document its progress with baseline data collection.
The project involves new roles and responsibilities for participating plants.
Before the models testing phase begins, 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 must develop a process control plan to address other consumer protection concerns that are not food safety related, such as removing bruises and other quality defects.
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 or unwholesome. FSIS has developed performance standards and will use them to determine plant compliance.
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: oversight inspection and verification inspection. The number of inspectors needed to perform these inspection procedures will vary according to factors such as market class of animal or bird slaughtered, plant size and complexity of its operations. The FSIS inspector-in-charge will determine how to allocate inspection resources in the plant to conduct oversight and verification procedures.
Oversight inspection involves an FSIS inspector making expert and informed observations of the company’s HACCP and process control systems. Unlike the current system, where slaughter inspectors are assigned to fixed points along the slaughter line, under the models, inspectors may be assigned to perform oversight inspection at any point in the slaughter process. Inspectors can make the decision, in concert with the inspector-in-charge, to move up and down the line as they see the need. For example, inspectors may perform oversight inspection at places where plant employees are monitoring critical control points, at points where critical equipment such as poultry eviscerators are operating, or at any point they may think requires attention. Every carcass will receive oversight inspection.
Verification inspection consists of inspectors taking samples of products and plant records and carefully examining them. Verification inspection procedures will be carried out by inspectors after the company’s process control systems have been completed.
During the transition to the new models, FSIS has set post-mortem organoleptic performance standards for young poultry that each participating plant must meet. For market hogs, post-mortem performance standards have not yet been developed because plants entering the transition phase are making changes only in antemortem controls at this time.
For young poultry, performance standards are set for seven categories of diseases and conditions detected at slaughter—two address food safety, and five address "other consumer protection" concerns. For the two "food safety" categories, the performance standards are set at "zero," meaning that no food safety diseases or conditions are permitted. For the five "other consumer protection" categories, FSIS set the performance standards according to the baseline data collected so far, which reflect the achievements of the current system.
As FSIS gathers more baseline line data, the "other consumer protection" performance standards may change. The food safety performance standards will not change. After data collection is complete, FSIS will go through rulemaking, with the opportunity for public input, to formalize the performance standards.
During the transition, each participating plant must ensure that its HACCP and other process control systems are working as intended to meet FSIS standards. Any product deemed by inspectors as adulterated will not pass inspection.
Concurrently, FSIS will ensure that its new inspection procedures are working so that it can verify that the plants are meeting these standards. FSIS will ensure that the food safety performance standards are met through oversight inspection and "hands-on" verification, where samples of products will be collected and examined by FSIS inspectors. The "other consumer protection" performance standards will be verified through "hands-on" product examinations as well as records review. In addition to these organoleptic verification tasks, FSIS will conduct Salmonella testing above what is required under HACCP.
During the transition period, FSIS will conduct additional verification tests and have additional inspection personnel in the plants to provide added assurance to consumers that products meet FSIS requirements.
When the plant HACCP and process control systems and FSIS inspection procedures are working as intended, RTI will again collect data in order to provide a "before" and "after" picture with regard to organoleptic and microbial data. The achievements of the new system must meet or exceed the achievements of the current system as reflected by the baseline data in order for FSIS to consider the system successful.
FSIS will take action if the plant exceeds the performance standards. The specific action taken will depend on whether the performance standard is related to a "food safety" or "other consumer protection" category, and the degree to which the performance standard has been exceeded. FSIS is taking a preventive approach by relying on the verification of plant HACCP and process control systems, and corrections to those systems, as the first line of defense against adulterated product. In addition, FSIS performance standards for the transition phase include levels for diseases and other conditions at which it will require plants to take action on products.
Under the HACCP-based inspection models project, the authority of inspection personnel to take action in plants operating under the models is the same as in plants operating under traditional inspection. Inspectors now have, and will continue to have, the authority to stop the line as appropriate, retain product that they believe is adulterated or misbranded, to withhold the marks of inspection, and to reject facilities, equipment, or any parts of the plant they determine are not in compliance with the regulations.
FSIS’ role at the in-distribution level is to focus on meat and poultry products that have been produced by federally inspected establishments to verify that they are not adulterated or misbranded as they move to the consumer. FSIS believes that the in-plant and in-distribution segments of the farm-to-table chain should be viewed as much as possible as a continuum—a seamless system. Thus, under the models, FSIS is testing the feasibility of deploying inspection resources more effectively within plants and between in-plant and in-distribution sites, consistent with farm-to-table food safety goals. By having inspectors carrying out both in-plant and in-distribution activities, compliance officers, who currently carry out some of the in-distribution activities, will be able to better focus on enforcement activities.
The in-distribution inspection models will run on a parallel track with the in-plant models in geographic locations near the first group of participating plants. Four states—Pennsylvania, Minnesota, Virginia, and Alabama—have been selected as the first sites to test the in-distribution models, and 11 "in-distribution" inspectors will be assigned to these locations. Testing of the in-distribution models is expected to begin in January 2000.
Under the pilot, FSIS will increase the frequency of certain tasks that are now performed outside of federally inspected plants. All tasks are consistent with FSIS’ current regulatory authority. For example, inspectors will conduct scheduled as well as unscheduled reviews of a wide range of diverse, commercial operations; conduct recall effectiveness checks; and conduct sampling to verify compliance with FSIS requirements. In addition, FSIS will explore whether screening, or market-basket, surveys outside the plant can be used to enforce "other consumer protection" requirements, such as economic adulteration. FSIS will not duplicate the work carried out by State and local agencies. FSIS’ goal is to determine how to best meet its food safety responsibilities in concert with State and local authorities.
FSIS has examined other occupational series that might be appropriate for classifying jobs within the Agency in light of current and future changes in inspection work and the types of skills and qualifications that will be needed in the workforce of the future. FSIS has established a new position—consumer safety inspector—that is similar to the food inspector position in that it is a "technician level" position. Food inspector positions in HACCP plants are being converted to consumer safety inspector positions, and consumer safety inspectors will be used to carry out both in-distribution and in-plant activities under the HACCP-based inspection models project.
In the future, FSIS will need to have a flexible, more highly educated workforce that can be assigned at any time, and to any industry operation, to perform inspection and determine regulatory compliance. The future workforce will include a variety of scientific disciplines.
The FSIS Steering Committee on the Workforce of the Future will serve as the umbrella group for coordinating and overseeing a variety of Agency initiatives to design, implement and support the workforce of the future.
The HACCP-based Inspection Models Project is being developed through an open public process that allows all interested constituents the opportunity to participate and provide input through public meetings and other means. FSIS has consulted closely with the National Advisory Committee on Meat and Poultry Inspection; the National Advisory Committee on Microbiological Criteria for Foods; numerous public health, industry, and consumer groups; and FSIS employee and supervisory groups, among others. Once FSIS has adequate data and public input, it will go through formal rulemaking procedures to make any changes to its regulations. The Agency hopes to publish a final rule on young chickens in fall 2000.
For Further Information Contact:
FSIS Congressional and Public Affairs Staff
Phone: (202) 720-3897
Fax: (202) 720-5704