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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 |
Pathogen Reduction/HACCP & HACCP Implementation
Based on a content analysis of calls to the Technical Service Center's HACCP Implementation Hotline, following are answers to questions most often asked by industry inquirers. Questions are phrased as generally asked by industry callers. FSIS plans to maintain the HACCP Implementation Hotline service as long as there is a need for it.
If the establishment disagrees with inspection personnel’s decisions, the decision can be appealed through the chain of command. That is, Inspector In Charge (IIC), Circuit Supervisor, District Office, and Headquarters.
Regulation 417.5(b) states: Each entry on a record maintained under the HACCP plan shall be made at the time the specific event occurs and include the date and time recorded, and shall be signed or initialed by the establishment employee making the entry.
Regulation 417.5(c) states that prior to shipping product, the establishment shall review the records associated with the production of that product to ensure that all critical limits were met and, if appropriate, corrective actions were taken, including the proper disposition of product. Where practicable, this review shall be conducted, dated, and signed by an individual who did not produce the record(s).
[No, it is not necessary.] It is acceptable for slaughter and simple processing to be covered with the same plan.
It is also considered acceptable for these to be covered by separate plans.
[Not necessarily.] If fecal contamination is found by off-line inspection personnel after the final rail in red meat plants or on poultry carcasses at the entrance of the chiller or beyond through the performance of FSIS verification procedures, this is considered a deviation from a critical limit. This is documented as monitoring noncompliance, but is not considered a system failure at this point. The inspector would then verify corrective actions as per 417.3(a).
All of the product back to the last acceptable check must be held. According to 417.3(a), the cause of the deviation must be identified and eliminated. The CCP must be under control after the corrective action is taken. Measures must be taken to prevent recurrence and to ensure no product that is injurious to health enters commerce.
This means that all product after the last acceptable fecal check is considered potentially contaminated and the establishment must take actions to assure that the contaminated product does not enter commerce. Such product should be free of visible feces and the cross contamination issue should be addressed.
Directive 6150.1, "Poultry Postmortem Inspection and Reinspection," does not apply in HACCP establishments. The directive is being amended for application in HACCP plants. However, inspection personnel in HACCP plants do perform two (2) 10-bird checks per line per shift for fecal contamination.
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The FSIS Technical Service Center's HACCP Hotline is staffed by a team trained specifically to address HACCP technical and implementation questions and concerns. They'll answer telephone, electronic mail, and FAX inquiries. Industry may CALL 1-800-233-3935 (Press "2" after the voicemail message to be connected to the HACCP Hotline); FAX 1-800-221-7438 or E-MAIL questions to Tech.Center@USDA.gov. (The HACCP Hotline will NOT handle industry appeals of inspection related decisions. Such appeals must be directed to the appropriate FSIS District Office for response.)
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