Food Safety and Inspection Service United States Department of Agriculture Washington, D.C. 20250-3700

Backgrounders

July 1999
Slightly Revised

HACCP IMPLEMENTATION—Phase III for Very Small Plants

Summary

The Food Safety and Inspection Service (FSIS) is entering the third and final phase of implementation of the final rule on Pathogen Reduction; Hazard Analysis and Critical Control Point (HACCP) Systems. On January 25, 2000, all very small plants, defined as having fewer than 10 employees or less than $2.5 million in sales, must meet all requirements of the Pathogen Reduction; Hazard Analysis and Critical Control Point (HACCP) Systems final rule. Approximately 3,400 very small federally inspected plants and 2,300 state-inspected plants are expected to implement HACCP. FSIS has prepared extensively for implementation by providing technical assistance to plants. Approximately 300 large plants, those with 500 or more employees, were required to implement HACCP systems by January 1998. About 2,300 small plants, defined as having 10 or more but fewer than 500 employees, implemented HACCP in January 1999.

Background

FSIS is the Agency within the U.S. Department of Agriculture responsible for ensuring the safety, wholesomeness, and accurate labeling of meat, poultry, and egg products. FSIS issued its landmark rule, Pathogen Reduction; Hazard Analysis and Critical Control Point (HACCP) Systems, on July 25, 1996. The rule addresses the serious problem of foodborne illness in the United States associated with meat and poultry products by focusing more attention on the prevention and reduction of microbial pathogens on raw products that can cause illness. It also clarifies the roles of industry and government in food safety. Industry is responsible for producing safe food. Government is responsible for setting appropriate food safety standards, maintaining vigorous oversight to ensure those standards are met, and operating a strong enforcement program to deal with, among other things, plants that do not meet regulatory requirements.

The Pathogen Reduction and HACCP rule: (1) requires all meat and poultry plants to develop and implement written standard operating procedures for sanitation (SSOPs), (2) mandates that meat and poultry slaughter plants conduct microbial testing for generic E. coli to verify the adequacy of their process controls for the prevention of fecal contamination, (3) requires all meat and poultry plants to develop and implement a system of preventive controls, known as HACCP, to improve the safety of their products, and (4) sets pathogen reduction performance standards for Salmonella that slaughter plants and plants producing raw ground products must meet.

Schedule for Implementation

Implementation of the final rule began on January 27, 1997, and will be completed by January 25, 2000. On January 27, 1997, all plants, regardless of size, were required to have in place written SSOPs, and all slaughter plants were required to begin testing for generic E. coli. On January 26, 1998, the largest plants were required to have HACCP systems in place and to meet the performance standards for Salmonella. Small plants were required to meet these requirements by January 25, 1999. Very small establishments must implement HACCP and meet the Salmonella performance standards by January 25, 2000.

Assistance to Very Small Plants

As the Agency did with small plants, FSIS has prepared for the implementation of the final rule in very small plants by providing extensive technical assistance and guidance to help them in meeting these requirements. FSIS recognizes that very small plants have fewer resources to draw on and may not be familiar with HACCP. Many of the initiatives developed for small plants continue to be an avenue of assistance for very small establishments. FSIS continues to provide these same activities to assist very small plants. For example, FSIS has established:

• a National Coordinator for HACCP in Small and Very Small Plants to coordinate the Very Small Plant Outreach Initiative;

• a network of State HACCP Contacts and Coordinators, including the District of Columbia and U.S. territories who are disseminating information on HACCP and providing technical guidance to very small plants;

• a mentoring program in which large and small plants are asked to act as sponsors/mentors for very small plants to provide technical assistance, guidance, and industry-oriented advice;

• technical assistance workshops for very small plants in certain targeted geographical areas;

• language assistance (translators) for Asian-Pacific American and Hispanic plant owners and operators;

• generic HACCP models and a Guidebook for the Preparation of HACCP Plans to assist very small plant owners and operators in developing their own HACCP plan(s), tailored to their operations; and

• a HACCP Hotline (1-800-233-3935) at the FSIS Technical Service Center’s in Omaha, NE, to respond to HACCP technical and implementation questions and concerns from plant owners and managers, industry representatives, FSIS field inspection personnel and others.

In addition, the following activities have been specifically designed to assist very small plants to develop HACCP plans for meat and poultry:

• Grants have been awarded to five land grant universities, including one historically black university, utilizing meat and poultry laboratories or plants that are under inspection to serve as models for very small plants;

• A packet of information was sent to very small plants that included a letter from FSIS Administrator Thomas J. Billy, notifying very small plant owners/operators of the availability of assistance that has been specifically tailored to help very small plants develop HACCP plans for meat and poultry;

• The packet also included a list of suggested dates for completion of key milestones leading to a HACCP plan and a HACCP Systems Basic Compliance Checklist;

• A brochure with very small plant outreach information with an order form for the generic HACCP models, the Guidebook, videos of a HACCP Small Plant Implementation Meeting (available in English, Chinese, and Spanish), and other training material available from FSIS was also provided;

• Distance learning materials, developed by an independent contractor, are being distributed to each very small plant. These materials include: a "Self-Study Guide to Understanding How to Develop a HACCP Plan," and two videos—"HACCPWORKS," and "HACCP: The Hazard Analysis and Critical Control Point System." The study guide, which was created specifically to assist very small plants, provides step-by-step written instructions on the development of a HACCP plan and provides a means to have up to two draft copies of the plan submitted for review and comments by the contractor. (HACCP plans are not reviewed for approval.) Completion of the step-by-step program and submission of a letter of completion to the contractor will satisfy the HACCP training requirements found in 9 CFR 417.7; and

• A brochure and poster that review the seven principles of HACCP, preventive measures, and provide other useful information, are also part of the instructional packet that the Agency is providing to all very small plants.

As with large and small plants, additional assistance has been provided through the 18 FSIS District Managers around the country. The District Managers continue to be very proactive in their efforts to assist very small plants in their districts in preparing for the January 25, 2000 HACCP implementation date and are using a one-on-one or more "localized" approach. The District Managers will be working closely with the field supervisors who will be contacting very small plant owners within their areas to determine each plant’s HACCP readiness. The field supervisors will work with very small plants answering technical questions about HACCP and will be advising them where to obtain additional HACCP resources.

Industry and academic institutions have also made great efforts in providing assistance and training to their members and to plants. The very small plants themselves have indicated they are working hard in getting ready for January 25, 2000.

HACCP Implementation in Large and Small Plants

Implementation in large and small plants has been smooth thanks to the efforts of both government and industry. Large plants had a 92% compliance rate with the HACCP requirements for 1998. Where a few problems did occur, enforcement actions were implemented and plants responded by modifying and strengthening their HACCP plans. The new prevention-oriented meat and poultry inspection system is showing positive results. New data from the first year of testing in large plants show that the incidence of Salmonella in broilers, swine, and ground beef, and ground turkey was substantially lower after HACCP implementation. For these four product classes combined, 88% of large plants with completed sample sets are meeting the Salmonella standard.

Of approximately 2,300 small plants required to have HACCP in place by January 25, 1999, only a small number of plants received notices of suspension for failure to comply with the regulations. For plants willing to address the problems, the suspensions were held in abeyance for up to ninety (90) calendar days from the date of the letter notifying the plant of the suspension. Data on the prevalence of Salmonella in small plants are not available yet.

As with the large and small plants, FSIS remains committed to having each very small plant succeed in meeting the regulatory requirements of HACCP in a timely manner, and the Agency will continue to provide information on how to obtain the technical assistance to succeed.

For More Information:

For Further Information Contact:
FSIS Congressional and Public Affairs Staff
Phone: (202) 720-3897
Fax: (202) 720-5704

Backgrounders Menu | FSIS Home Page | USDA Home Page