This IKE addresses what inspection program personnel should consider when verifying compliance with 9 CFR 416.2(d), Ventilation. It applies the instructions in FSIS Directive 5000.1 to this situation.
Situation: You are a Consumer Safety Inspector (CSI) in a processing facility that produces a variety of fully cooked meat and poultry products. The establishment utilizes freezers to store both raw ingredients and finished products.
Today's PBIS schedule indicates that you are to perform Sanitation Performance Standard (SPS) procedure 06D01. You have elected to verify regulatory compliance with 9 CFR 416.2(d) throughout the facility. You proceed to walk through multiple areas of the facility to observe whether the ventilation is adequate to control odors, vapors, and condensation to the extent necessary to prevent the adulteration of product and the creation of insanitary conditions. You evaluate each of the cooked product production areas and decide to observe the raw product storage freezer.
Upon entering the freezer, you observe frost (i.e. frozen condensate) on the overhead doorframe of the freezer entrance. Further investigation reveals that the interior wall of the freezer has a thin layer of frost directly above the doorframe. There are no indications that frost has contacted any packages of product. You are aware that opening and closing the door throughout the production day allows warm air from outside the freezer to contact the cold doorframe, creating frost on the door and interior wall surfaces. In addition, you know that only packaged products are stored in this particular freezer.
You ask yourself whether the presence of the frost has created an insanitary condition, and whether the frost is an indication of inadequate ventilation. Based on your knowledge of the regulations and the plants operations, you evaluate the conditions that you have observed.
Discussion: You are aware that (a) the establishment inspects and cleans this doorframe regularly to ensure that there is not an excessive build-up of frost, and (b) that the establishment has elected to document its inspection. You review the establishment's inspection documents and observe that the establishment had cleaned and inspected the doorframe during the sanitation shift the previous night. You conclude that, in this situation, if the frost that formed came into contact with product packages, it should not have a significant effect on the product. You conclude that, in this situation, an insanitary condition has not been created.
Next, in order to verify compliance related to the establishment's control of condensation, you evaluate the control measures that the establishment has in place. This facility has elected to place a wall fan outside, and immediately above, the freezer door in order to reduce the amount of warm air that enters the freezer when the door is opened. You observe that the fan is operational. It appears that the establishment is adequately controlling the formation of condensate, specifically frozen condensate/frost.
Resolution: Based on your determinations that the frost is not creating an insanitary condition and that the establishment has initiated an effective measure to control condensation, you conclude that the establishment is in compliance with 9 CFR 416.2(d). You document the 06D01 procedure as "performed" in PBIS.
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