Contingency Plan For Import Reinspections When The Public Health Information System (PHIS) Is Not Available - Revision 1
I. PURPOSE
This directive addresses how inspection program personnel (IPP) are to obtain reinspection assignments for imported meat, poultry, and egg products in the event that the Public Health Information System (PHIS) is not available. FSIS is reissuing this directive to address additional changes associated with the reorganization of import inspection personnel into the Office of Field Operations (OFO). This directive also updates instructions for when IPP are to implement the contingency plan, as well as instructions for the contingency plan when foreign inspection certificate data is electronically transmitted to PHIS.
KEY POINTS:
- How to conduct import reinspection when PHIS is not available
- How to document reinspection assignments when PHIS is not connected
- How to update reinspection assignments when PHIS connectivity is restored
II. CANCELLATION
FSIS Directive 9500.1 Contingency Plan for Import Reinspections When the Public Health Information System (PHIS) is Not Available, 11/3/15
III. REINSPECTION CATEGORIES
A. Assignment is the reinspection type of inspection (TOI) for a specific lot of imported meat, poultry, or egg products.
B. Level of Reinspection is the intensity of reinspection assigned to an imported lot based on the compliance history of the foreign establishment and the country for a specific TOI and product. There are three levels of reinspection that PHIS will assign:
- Normal is a level of reinspection where randomly selected lots are assigned a TOI based on the FSIS annual sampling plan. Under normal level of sampling, the importer of record is required to maintain control of product tested for adulterants by FSIS and is not to allow such product to enter commerce until negative results are received;
- Increased is a level of reinspection above the normal level that is directed by an FSIS management decision. Under increased reinspection, FSIS may hold, on a case-by-case basis, lots of imported meat, poultry, or egg products pending receipt of a laboratory result. If FSIS does not place the product on hold, the importer of record is required to hold product tested for adulterants by FSIS and is not to allow such product to enter commerce until negative results are received; or
- Intensified is a level of reinspection that is implemented automatically by PHIS when a TOI is reported as “Fail.” Under intensified reinspection, FSIS holds the sampled lot pending receipt of the laboratory result. The sampled lot is not allowed to move off-site to be held.
NOTE: Shipments from Canada are to be off-loaded and presented in their entirety when assigned an intensified level of reinspection for any TOI.
IV. INFORMATION TO BE MAINTAINED FOR OBTAINING ASSIGNMENTS DURING PHIS OUTAGES
A. In order to perform the appropriate reinspections when PHIS is unable to generate the assignment, IPP are to obtain the import information listed in B. below as a reference.
B. During a PHIS outage, IPP are to access the OFO Recall Management and Technical Analysis Division (RMTAD) Import Operations SharePoint site and the FSIS Web site to obtain documents 1-6 listed below. The information in these documents is updated daily or as needed. Documents 2, 3, 4, and 5 are posted on the SharePoint site and documents 1 and 6 are located on the FSIS Web site. The documents include:
- A list of foreign countries and establishments certified for export to the United States;
- A list of foreign countries or certified foreign establishments on increased reinspection;
- A list of certified foreign establishments on intensified reinspection;
- The Animal and Plant Health Inspection Service (APHIS) animal disease table (listings of eligible countries and the types of products eligible for import);
- The Foreign Country Contingency Sampling Table, which contains the interval for selecting lots for reinspection (product examinations) when PHIS is not available; and
- A list of official import inspection establishments with contact information including telephone and fax numbers.
V. CONNECTIVITY
A. When PHIS is not available, IPP are to contact the FSIS Help Desk at 800-473-9135 to determine whether the outage is scheduled maintenance, a local connectivity problem (e.g., internet access or VPN access), or a nationwide outage. Based on this information, IPP are to notify their Frontline Supervisor (FLS) and RMTAD via e-mail: foimports@fsis.usda.gov. The FLS will instruct IPP whether to implement contingency plans and follow instructions in VI. A, B, or C below. B. When IPP are unable to verify the status of a shipment based on the contingency documents in IV.
B., they are to hold the shipment and notify their FLS and RMTAD.
VI. OBTAINING ASSIGNMENTS WHEN PHIS IS NOT AVAILABLE AND IPP ARE INSTRUCTED TO IMPLEMENT THE CONTINGENCY PLAN
A. When IPP receive notification that PHIS will not be available because of scheduled maintenance (Outlook-FSIS User Information e-mail), IPP scheduled to work during the outage are to obtain reinspection assignments from PHIS in advance of the outage. Reinspection assignments obtained from PHIS are to be kept under control until the shipment is presented for reinspection.
B. When PHIS is not available because of a local connection problem (e.g., computer/modem or internet malfunction), IPP are to refer to the list of official import inspection establishments where IPP are available to assist with obtaining assignments. IPP at an official import inspection establishment that does have connectivity are to:
- Assist with entering data for shipments presented at an official import establishment where PHIS connectivity has been interrupted when asked to do so by either IPP without PHIS connectivity, RMTAD, or the FLS; and
- Provide the reinspection assignments to any IPP that do not have PHIS connectivity.
C. If the problem with PHIS connectivity is nationwide (e.g., the network is down) and a reinspection assignment cannot be obtained from PHIS, IPP are to use the materials in Section IV. B. as a reference and:
- Verify that shipments presented for reinspection are from an equivalent foreign country and a certified establishment by comparing the foreign inspection certificate to the list of eligible foreign countries and certified establishments that can export to the United States;
- NOTE: If a hard copy of the inspection certificate has not been provided because certificate data has been transferred to PHIS from eCERT, IPP cannot perform the reinspection and are to wait until the issues with PHIS are resolved.
- Determine whether the products and species presented are from foreign countries with animal disease restrictions (e.g., infectious diseases such as Rinderpest or Foot-and-Mouth Disease) by using the APHIS Disease Table. When shipments include meat products from countries with animal disease restrictions for Rinderpest or Foot-and-Mouth Disease, IPP are to follow the instructions in FSIS Directive 9900.7, Physical Examinations of Cooked Meat from Regions Where Rinderpest or Foot and Mouth Disease Exists;
- Reinspect shipments according to rates outlined in the Foreign Country Contingency Sampling Table in Section IV.B. IPP are to use the random number generator located on their computers to generate physical reinspection assignments based on the rates of reinspection in the table. To access and use the Random Number Generator:
- a. Left click on “Windows Start,” then “All Programs,” then “FSIS Applications,” then “Tools” and “Random Number Generator”; and
- b. After selecting the necessary random numbers, click “export” to save them to a “.txt” file. Follow the prompts to select a location (e.g., desktop); give the file a name using the PHIS application/lot number and date. Print a copy for the case file;
- Follow any additional guidance for laboratory sampling that is provided during the outage by FSIS management;
- For foreign establishments on the intensified or increased reinspection list referenced in IV.B. above, perform the TOIs identified (e.g., product examination and appropriate sampling). Any samples collected are to be held until PHIS is restored;
- Maintain a list that identifies all TOIs performed under the contingency plan for lots presented. This list is to include the country, inspection certificate number, and the level of the reinspection (Normal, Increased or Intensified); and
- Report inspection results for any intensified, increased, or failed TOIs, except certification and label verification, to RMTAD as soon as practical.
E. RMTAD is to maintain a record of intensified, increased, or failed TOIs and update the applicable list as necessary.
VII. WHEN PHIS CONNECTION IS RESTORED
When PHIS becomes available, IPP are to:
- Retrieve and complete the application in PHIS, receive the lots, and request reinspection assignments;
- Ensure any samples collected and held while the contingency plan is in place, as instructed in section VI, are processed in PHIS and sent to the laboratory for analysis;
- Enter the inspection results for all TOIs performed on lots while the system was not available. If the TOIs that were performed were not scheduled by PHIS, IPP are to add these as unscheduled, selecting Contingency Plan as the Justification; and
- For any TOI assigned by PHIS but not performed under the contingency plan, Select Contingency Plan as the Reason Not Performed.
VIII. QUESTIONS
A. IPP having problems with PHIS are to contact the FSIS Help Desk at 800-473-9135.
B. Refer questions regarding this directive to the Import and Export Policy Development Staff through askFSIS or by telephone at 202-690-4354. When submitting a question, use the Submit a Question tab, and enter the following information in the fields provided:
- Subject Field: Enter Directive 9500.1.
- Question Field: Enter question with as much detail as possible.
- Product Field: Select Import from the drop-down menu.
- Category Field: Select Basic Import Answers from the drop-down menu.
- Policy Arena: Select International (Import/Export) from the drop-down menu.
When all fields are complete, press Continue and at the next screen press Finish Submitting Question.
NOTE: Refer to FSIS Directive 5620.1, Using askFSIS, for additional information on submitting questions.