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

Pathogen Reduction/HACCP

February 13, 1998

Memorandum to all Field In-Plant Personnel

I am pleased with the progress made in implementing HACCP systems in meat and poultry plants throughout the country. In large part, our success is because of your efforts and professionalism. Thank you for your work on the front lines as we revolutionize the manner in which meat and poultry is regulated and inspected in the United States.

As we continue implementation of the Pathogen Reduction and Hazard Analysis and Critical Control Point (HACCP) systems final rule, in-plant personnel have an essential role in monitoring and verifying industry's maintenance of effective process control systems. In plants operating under HACCP systems, the work of inspectors is critical to protecting the public health from food-borne illness.

Because of an apparent misunderstanding among some industry representatives and inspection personnel, however, it is necessary to re-emphasize the respective responsibilities of industry and in-plant inspectors in meat and poultry plants operating under HACCP. It is the responsibility of industry to identify potential hazards, to develop a HACCP plan containing controls to prevent, eliminate, or reduce hazards to an acceptable level, to monitor the performance of controls, and to maintain required records. The primary responsibility of in-plant inspectors is to evaluate the implementation and maintenance of a HACCP plan's process controls. It is not the responsibility of in-plant inspectors to determine whether the form and content of a HACCP plan is adequate. Instead, it is the responsibility of the Technical Service Center to answer questions and resolve issues regarding the adequacy of the form and content of the HACCP plans. Accordingly, in-plant inspectors should contact the Technical Service Center as soon as possible when such questions arise.

In a recent letter to certain establishments operating under HACCP, FSIS district managers explained that the use of good manufacturing practices and sanitation standard operating procedures may not substitute for CCP's and the critical limits that are established for them. It appears that industry representatives and inspectors may have misinterpreted the letter to mean that in-plant inspection personnel have the authority to make determinations on the adequacy or number of CCP's in a HACCP plan. As I have explained, this is not the responsibility of in-plant inspection personnel, but rather the staff of the Technical Service Center.

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