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

Pathogen Reduction/HACCP & HACCP Implementation

January 1999

Small Plant HACCP Update

FSIS Prepared for HACCP Implementation—Phase II for Small Plants

The second phase of implementation of the final rule on Pathogen Reduction; Hazard Analysis and Critical Control Point (HACCP) systems for small plants went into effect on Monday, January 25, 1999. Recognizing that small plants have fewer resources to draw on than large plants, FSIS has prepared extensively for small plant HACCP implementation by providing extensive technical assistance to these plants.

At a January 21 press conference in Washington, DC, Under Secretary for Food Safety Catherine Woteki and FSIS Administrator Thomas J. Billy congratulated large plants on an excellent first year of HACCP implementation and discussed the Agency’s readiness for HACCP Implementation--Phase II in small plants on January 25, 1999. In his remarks, Mr. Billy recapped the activities carried out by FSIS in preparing small plants for the transition to HACCP and for meeting the performance standards for Salmonella. For example, FSIS has:

• Appointed a National HACCP Small Plant Coordinator to coordinate the various activities underway to assist small plants.
• Established a network of contacts and state coordinators around the country to disseminate information on HACCP and provide technical guidance to small plants.
• Conducted small plant technical assistance workshops throughout the country to provide guidance and technical assistance to small plants.
• Asked large plants to act as sponsors for small plants to provide technical assistance, guidance, and industry-oriented advice.
• Held a series of 20 nation-wide public HACCP implementation meetings to answer any questions.
• Provided language assistance (translators) to Asian Pacific owned plants, and provided some technical assistance in Spanish.
• Developed generic HACCP models for a variety of processes to assist plant in developing their own HACCP plans.
• Established a HACCP hotline (1-800-233-3935) at the FSIS Technical Service Center in Omaha, Nebraska, to answer questions from industry and inspectors.
• Issued a series of letters to small plants to remind them of key preparation tasks and provide advice on when these should be accomplished.

In addition, the 18 FSIS District Managers have been very proactive in their efforts to assist small plants within their districts in preparing for the January 25, 1999 HACCP implementation date. Prior to January 25, all small plants within each district were contacted by a representative from the District Office about their HACCP readiness and provided with a list of HACCP resources for technical assistance. During the week of January 11, the fourth in a series of letters from Mr. Billy was hand delivered to each small plant. Mr. Billy reiterated the Agency’s commitment to having every single small plant succeed in meeting the regulatory requirements in a timely manner, and again provided information on how to obtain technical assistance.

With more than 2800 small plants required to have HACCP systems in place on Monday, Under Secretary Woteki and Mr. Billy also acknowledged the efforts of industry and academic institutions in providing assistance and training to their members and to plants. Small plants themselves were recognized for their hard work in getting ready.

Role of Inspectors in HACCP Plants

FSIS inspectors have received extensive training for their roles in HACCP plants. Inspectors have the same authority under HACCP as under past inspection methods to ensure that the public receives a meat and poultry supply that is safe, wholesome and not adulterated or misbranded. The inspectors will exercise the following regulatory oversight responsibilities: determine if a facility meets the basic requirements with its HACCP plan; determine if the facility is following the plan; document failures; and take enforcement actions when appropriate.

Second Progress Report on Salmonella Testing Data Indicates Positive Trend

The Pathogen Reduction/HACCP rule not only mandated HACCP in all plants that slaughter and process meat and poultry, but it set performance standards for Salmonella that plants must meet. The requirements to implement HACCP and meet Salmonella performance standards are being implemented in stages based on plant size. Large plants met these requirements last year on January 26, 1998. Small plants were required to meet them effective January 25, 1999, and very small plants must comply by January 25, 2000. The new data, based on the first 9 months of testing in large plants, show that the prevalence of Salmonella on broilers, swine, and ground beef, was substantially lower after HACCP implementation than in baseline studies conducted before implementation. About 90 percent of large plants with completed sample sets are meeting the Salmonella standard. The Agency is confident that one year from now the testing data from the small plants will also reflect a decrease in the incidence of Salmonella, that small plants are meeting the Salmonella performance standards, and that the small plants are in compliance with the requirements of the rule.

Basic Compliance Guidance for Phase II—Day One

FSIS continues to be committed to having every single small establishment succeed in meeting the regulatory requirements of the Pathogen Reduction/HACCP rule. Prior to the implementation deadline of January 25, 1999, if a plant owner felt that the deadline could not be met, he was instructed to notify the District Manager. If the plant had made a good faith effort to develop and implement a plan, but had not been fully successful, the District Manager would continue to work to assist in making that establishment a priority among the network of HACCP resources. Now that HACCP implementation for small plants is in affect, FSIS has provided some basic guidance to the District Managers for dealing with those small establishments who are not in compliance with the requirements of CFR 417.2 on January 25, 1999, but want to come into compliance. Essentially, the assignment of inspectors at the establishment would be suspended. But based on the efforts of the establishment to date to comply with the regulations, FSIS will hold the suspension in abeyance and allow inspected operations to continue. The suspension will be held in abeyance for up to a ninety- (90) calendar day period from the date of the letter notifying the plant of the suspension and notice of abeyance. The letter will delineate the specific conditions of the abeyance and a timeframe for compliance. Failure of the establishment to meet the conditions of the abeyance by the end of the abeyance period may result in FSIS immediately effecting the suspension of inspection at that plant.

Reminder—HACCP Assistance Only a Phone Call Away

The FSIS Technical Service Center’s HACCP Hotline has increased its staff of technical experts to address HACCP technical and implementation questions and concerns from 6:00 a.m. to 6:00 p.m., CST. The Hotline number is 1-800-233-3935. Included with the December Small Plant HACCP Update was a listing of the after-hours emergency contact numbers (24-hour, seven days a week phone coverage) for the 18 District Offices and for Headquarters. Some of the industry associations are also providing hotlines and 24-hour phone assistance to their members and to plants. Additional information may be found on the individual Web sites for the various organizations.

For More Information:

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

Pathogen Reduction/HACCP Page | FSIS Home Page | USDA Home Page