|Food Safety and Inspection
United States Department of Agriculture
Washington, D.C. 20250-3700
April 21, 1998
Slightly Revised May 1998
Since January 26, 1998, USDA inspectors have been implementing a new science-based Hazard Analysis and Critical Control Point (HACCP) system to prevent foodborne illness in U.S. plants that produce 75 percent of the raw meat and poultry and 45 percent of processed products such as frozen dinners, wieners, or hams. Like implementation of Sanitation Standard Operating Procedures in 1997, the first 3 months of HACCP implementation has progressed relatively smoothly. Available data indicate that the plants have a 92 percent compliance rate with HACCP regulations. Since January, FSIS has taken enforcement actions to address systems failures in 13 HACCP plants. Corrective and preventive actions in each of these plants have allowed operations to resume under FSIS monitoring.
To ensure open communication during the transition and adjustment to the revolutionary new HACCP system, FSIS has been holding weekly meetings with industry representatives to address implementation issues.
As FSIS works with the plants now operating under HACCP regulations and prepares for the second stage of implementation in more than 3,000 plants in January 1999, the Agency is refining its HACCP implementation strategy in 6 specific areas: 1) formation of a team of on-call experts managed from the FSIS Technical Center to help FSIS make quick decisions on complex issues regarding a plants HACCP system; 2) further enhancing the knowledge of supervisory inspectors in systems concepts relating to HACCP; 3) expanding the cadre of FSIS HACCP experts providing ongoing advice and guidance on HACCP-related issues; 4) improving notification to plants of findings that a plants HACCP system is failing; 5) specifying the steps in the appeals process; and 6) more involvement of the National Advisory Committee on Microbiological Criteria for Foods in the development of guidelines.
FSIS plans to carry out these supplementary activities as follows:
1) Technical Advisory Committee. FSIS has organized a Technical Advisory Committee (TAC) to act as an added Agency resource in providing reliable and speedy assistance to Agency inspection personnel on public health and food safety issues. The TAC will be available as needed and will be convened to address complex public health and food safety issues. The committee will be designed to provide field supervisory personnel with timely scientific and technical guidance necessary for making sound and accurate decisions in accordance with relevant science, Agency policies, and regulatory requirements.
2) Further Education in the Systems Approach. As part of the phasing in of HACCP, the Agency is planning a continuous education program for supervisors at the circuit and district levels that will further enhance their understanding of the systems approach, and the rationale for taking regulatory action on process deficiencies. Additional education in systems approach concepts will help supervisors communicate more effectively with inspection personnel and plant managers as everyone adjusts to the changed inspection environment with its new concepts of systems and processes. To foster the effective handling of appeals in a professional, businesslike way, the role of appeals as a non-adversarial part of the process of managing the effective provision of inspection services also will be stressed. Emphasis will be placed on business relationship principles in conducting productive weekly meetings they have with plant inspectors and managers to discuss trends at the plant and the adequacy of plant measures in addressing and correcting system inadequacies and potential problems. In addition, FSIS is adding expanded HACCP training for new circuit supervisors at its training center in College Station, Texas.
3) Expand FSIS Cadre of HACCP Experts. FSIS is planning a HACCP educational program for additional headquarters personnel that will focus on HACCP principles and implementation. Courses at the Agencys training center in College Station, Texas, will provide the Agency with the depth of necessary expertise to address questions about the application of HACCP regulations in the expanded environment of thousands of plants.
4) Notice on Plant Notification. To clarify notification procedures, a new FSIS notice outlines the step-by-step process for FSIS inspection personnel to follow to notify establishments of intended enforcement actions. The notice lays out the process to ensure establishments are given sufficient advance notice of Agency regulatory actions. The FSIS notice explicitly covers discussion of developing trends at weekly meetings FSIS supervisors have with plant management, and explains how the Agency will inform management of the industrys opportunity to respond to repetitive deficiencies that do not involve adulterated products leaving the plant. Inspectors act immediately to address adulterated products. This document adds interim procedures while final Rules of Practice are underway.
5) Appeals Process. In addition, two new documents, a notice to inspectors and a letter to plants, explain FSIS policy on the appeal of inspection findings and decisions. Open communication is encouraged; the chain of command is defined, while speedy resolution and timely appeals are stressed. FSIS has also established the Industry Appeals Tracking System (IATS) report, which will document and track information on appeals to help monitor and improve the process.
6) Collaboration with the National Advisory Committee for Microbiological Criteria for Foods. FSIS continues to seek outside scientific advice and expertise in the implementation of its pathogen reduction and HACCP inspection rules. In 1995, FSIS urged NACMCF to establish a subcommittee to assist in its planned ongoing evaluation of HACCP. The microbiological committee is a valuable resource for ensuring that the regulatory application of microbiological requirements for plants is scientifically valid. FSIS may ask the committee for further technical guidance on systems failures under HACCP.
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