|Food Safety and Inspection
United States Department of Agriculture
Washington, D.C. 20250-3700
Pathogen Reduction/HACCP & HACCP Implementation
October 05, 2001
|To:||All District Managers|
|From:||Mark T. Mina
Office of Field Operations
|Subject:||Responsibility for FSIS Personnel Concerning Sanitary Operations, Employee Hygiene and Cross Contamination of Products and Processes in Federally Inspected Meat, Poultry and Egg Products Establishments.|
Recently we received inquires from several industry representatives regarding inspection personnel's questionable employee hygiene and failure to follow industry's in-plant sanitary procedures. The purpose of this memo is to re-emphasize the importance of proper hygiene by Agency employees and the importance of following sanitary practices especially in the raw/ready to eat and slaughter/processing environment.
Sanitary handling procedures and hygiene are basic principles upon which the Pathogen Reduction (PR), Hazard Analysis Critical Control Point systems (HACCP) and Sanitation Operating Procedures (SOP's) are based. Without these basic building blocks of food safety, wholesome and unadulterated meat, poultry and egg products cannot be manufactured in a sanitary environment. As a food safety agency, we must ensure that regulations pertaining to sanitary operations and proper food handling practices are strictly adhered to so that potential contamination of meat, poultry or egg products with Salmonella, Staphylococcus aureas, or Escherichia coli, and after post process lethality by Listeria monocytogenes as well as other pathogens of concern, does not occur.
The Code of Federal Regulations makes no distinction between plant employees and FSIS personnel regarding sanitary operations, equipment or hygiene. FSIS personnel must comply with 9 CFR Part 416.4 as well as 9 CFR Part 416.5 with regard to any food product contact surfaces we utilize in the performance of our duties. This includes how we handle edible products and our sanitary hygienic practices. The utmost care should be taken to ensure that, while performing our duties, FSIS personnel follow the plant's handling procedures so that contamination does not occur between products or process areas, particularly between raw and fully cooked or heat-treated products areas, as well as ante-mortem, slaughter and processing departments. Inspection personnel must follow the procedures the establishment has set for traffic patterns or product flow between rooms and/or processes. Pathogens, such as Listeria, Salmonella, and E. coli, may be transferred onto boots, outer garments and hands when FSIS personnel perform ante-mortem inspection. Cross contamination, either directly or indirectly, can occur when proper cleaning and/or sanitizing is not performed before entering other areas of the establishment. Additionally, equipment, thermometers, knives, scabbards, etc., used by FSIS personnel must be cleaned and sanitized in accordance with 9 CFR 416.4. In this manner we will be able to work with the establishment to maintain sanitary conditions and equipment and thereby further protect the consumers of the products which we regulate.
Safe food handling is important for any person working in a food environment. As a food safety agency, we must lead the way by example.
For Further Information Contact:
Pathogen Reduction/HACCP Page | FSIS Home Page | USDA Home Page