Source:  Rita Jane Gabbett, MEATINGPLACE.COM, 3/23/10

When further processors use supplier prerequisite programs as part of their HACCP system, they are going to have to validate the effectiveness of that prerequisite program along with their critical control point validation, according to USDA's Food Safety and Inspection Service Administrator Alfred Almanza.

In a March 19 letter to nine meat industry organizations in response to a Sept. 22, 2009 letter they sent USDA seeking clarification, Almanza detailed USDA's view on a number of Hazard Analysis and Critical Control Point (HACCP) validation-related issues.

Almanza confirmed that HACCP validation includes both scientific and other supporting documents that demonstrate a facility's HACCP processes should work as outlined at the intended critical control points and evidence demonstrating that those processes actually can be implemented as designed and have the intended effect on this particular facility.

He went on to say, "More than CCPs must be validated. Increasingly, establishments use prerequisite programs as part of their HACCP, particularly as support for why the establishment considers a food safety hazard to be not reasonably likely to occur. It is essential that the on-going effectiveness of these prerequisite programs be part of the overall food safety system controls that are validated."

USDA has also issued a draft compliance guide on HACCP systems validation on which it is seeking comments from the industry.

Problematic for small processors

Those proposed verification standards for CCPs could put some small meat processors out of business or at least cause them to get out of the slaughter business or slim down their product lines, American Association of Meat Processors Executive Director Jay Wenther told Meatingplace.

He said the cost for a small business to test and validate its CCPs for the large number of unique products many produce could be unmanageable for many.

"What they are asking is extremely disconcerting," said Wenther. "And it goes completely against the administration's 'know your farmer, know your food' initiative," which is meant to support small, local food producers.

Comments sought


USDA has made Almanza's letter, along with draft compliance guidelines and the Sept. 22 letter Almanza is responding to on its Web site. 

Interested parties should submit their comments to DraftValidationGuideComments@fsis.usda.gov or mail comments to the Docket Clerk, USDA, FSIS, Room 2-2127, 5601 Sunnyside Avenue, Beltsville, MD 20705.

After April 19, FSIS will review the comments and begin deciding how it will proceed with respect to the validation of HACCP systems.

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