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

Pathogen Reduction/HACCP & HACCP Implementation

September 1999

Small Plant HACCP Update

FSIS Administrator Updates Very Small Plants on Agency HACCP Implementation Initiatives

On September 10, FSIS Administrator Thomas J. Billy issued the third of several letters to very small plant owners/operators. The letter focused on identifying critical limits that must be met at the critical control points (CCPs). CCPs were identified through the initial hazard analysis that is conducted in developing a HACCP plan. Mr. Billy emphasized that there will be no change in the deadline for implementation of HACCP on January 25, 2000, and reminded very small plant owners/operators of the Agency’s outreach initiatives to assist them with HACCP implementation. Included with the letter was an updated listing of the HACCP contact/coordinator network in all 50 states, Washington, D.C., Puerto Rico, and the Virgin Islands; a suggested timetable for completing key milestones leading to a HACCP plan; and HACCP tips for critical control points and critical limits. Very small plants were also encouraged to contact their FSIS field supervisor, District Office, and the Office of the National HACCP Small and Very Small Plant Coordinator for additional resources, clarification, or technical assistance.

FSIS is committed to seeing all very small establishments successfully meet regulatory requirements in a timely manner and the Agency stands ready to assist all very small plants in preparing to successfully implement HACCP on January 25, 2000.

Microbiological Hazard Identification Guide for Meat and Poultry Components of Products Produced by Very Small Plants Available

As part of its continuing efforts to assist very small plants in making a smooth transition to the regulatory requirements of HACCP in January 2000, FSIS is making available a DRAFT copy of the "FSIS Microbiological Hazard Identification Guide for Meat and Poultry Components of Products Produced by Very Small Plants." This document was developed in consultation with the Meat and Poultry Subcommittee of the National Advisory Committee on Microbiological Criteria for Foods. The DRAFT guide contains useful guidance to assist very small plants in conducting a hazard analysis for the development of a HACCP plan. For technical information, contact: Mary Cutshall, National HACCP Small and Very Small Plant Coordinator, at (202) 205-0619.

The availability of the DRAFT guide was previously announced in the September 10 FSIS Constituent Update. Copies of the guide are available on the FSIS Web site: www.fsis.usda.gov, access "HACCP Implementation," or by faxing requests to the FSIS Constituent Affairs office at (202) 720-5704.

Key Milestone for September 1999 in Preparing for HACCP Implementation—Phase III

September 1999: Identify critical limits for critical control points (CCPs). Critical limits should be an exact number, time, or temperature; for example, do not use ranges. Establish corrective actions to take when a critical limit is not met at a CCP. If there is a food safety regulatory requirement that must be met or exceeded, be sure to include all the requirements for corrective action that are listed in regulation 417.3. Using the example for temperature in a product cooler, you would want to set a specific maximum temperature. The temperature you select can be for the cooler itself or the product stored in the cooler, as long as the method ensures that the biological food safety hazard you identified--growth of pathogenic microorganisms--does not occur or is kept under control. Remember that your critical limit should be based on food safety and not quality considerations. You can also use existing regulatory standards as a critical limit. An example is the time temperature combinations in regulation 318.17 for cooked beef or performance standards from FSIS Directive 7111.1. When establishing corrective actions, remember to address all the parts of 417.3 (a). These are to ensure that:

• The cause of the deviation is identified and eliminated. Examples include how product disposition will be made, such as hold, reject, or condemn; determine the cause, such as equipment failure or monitoring was not conducted as written in the plan.

• The CCP will be under control after the corrective action is taken. Ensure that what you do will ensure that control can be reestablished at the CCP using the methods described in your corrective actions.

• Measures to prevent recurrence are established. Ensure that you will keep the deviation from happening again by using maintenance, assessing equipment condition, or increasing the frequency of the monitoring, for example.

• No product that is injurious to health or otherwise adulterated as a result of the deviation enters commerce. Review the pre-shipment review to determine that no product affected by the deviation was shipped and that all affected product produced is on hold, rejected, condemned, or under control.

September-October 1999: (1) Prepare a recordkeeping system for monitoring your CCPs. Be sure that your forms contain space to include the date, the result of the monitoring or verification, and the signature or initials of the person performing the measurement. (2) Select verification procedures. Identify those steps that your plant will take and the records for pre-shipment review.

HACCP Tips for Critical Control Points and Critical Limits

 When determining the best place for a critical control point be sure you can control the hazard at that point with a specific action and set a limit that is a specific point, number, or other quantifiable value.

For example if metal contamination from clips on chub packs is a problem, a good place to set a critical control point may be after packaging. If the metal contamination in your product is broken needles from an injection process, then setting your critical control point after injection and prior to packaging or cooking, if the product is cooked, may be more effective.

For More Information:

For Further Information Contact:
FSIS Constituent Affairs Program
Phone: (202) 720-8594
Fax: (202) 720-5704

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