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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 |
Issue Papers
December 1997
As indicated in the policy Notice published in the Federal Register November 28, 1997, FSIS regards its requirements for no visible feces on either livestock or poultry carcasses as food safety performance standards, which oblige companies implementing HACCP to include in their plans, CCPs designed to assure the standard is met. Further, the agency signaled its intent to continue to perform its verification checks in these establishments at the point in the process and with the frequency they are currently being performed; however, in plants which have implemented HACCP, the consequences of failure will be consistent with other HACCP noncompliance findings. The agency believes this is a prudent, although conservative, approach.
One reason the agency decided on this approach is because the zero tolerance verification checks are considered a part of post mortem inspection. Another reason is because the agency believes that the consuming public would be unwilling to accept that the government was reducing its verification efforts with respect to this food safety performance standard unless there was a body of data which indicated that those government resources could be better utilized in some other food safety verifications.
Therefore, after HACCP implementation has stabilized in large slaughter establishments, perhaps in six months, FSIS is planning to carry out a special survey and data collection effort to look at this issue. FSIS will seek data on how well the slaughter establishments which have implemented HACCP are performing with respect to the zero tolerance standard. The agency will also collect data relevant to the question of how well these establishments are performing with respect to other food safety standards, such as the Salmonella performance standard, or even such criteria as the patterns revealed by establishment generic E. coli testing results. FSIS could decide to collect some generic E. coli samples of its own in such establishments and analyze the resulting data.
FSIS would also welcome other data from slaughter establishments that have met HACCP regulatory requirements.
Following this exercise, if there is a body of data which supports a change in the frequency with which inspection personnel perform zero tolerance verifications, FSIS will make that information available to the public as part of its decision-making process on any appropriate changes. If there is information which suggests that the point at which verification checks are performed or the manner in which they are accomplished should be changed, that too would be publicly discussed, although in poultry there is a specific regulatory requirement that the zero tolerance standard be achieved before birds enter the chiller.
The agency is beginning its efforts to design the special survey described above, and is also considering how data relevant to this issue might be gathered through the HACCP Inspection Models Project.
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