Source: Michael Fielding, MEATINGPLACE, 3/7/16


The nation's small and very small federally inspected facilities have just one month to finalize their plans to comply with revised validation requirements.

USDA’s Food Safety and Inspection Service (FSIS) will begin verifying validation requirements at small and very small facilities on April 4. FSIS began verification in January on large plants.

A final revision of the “Compliance Guideline for Hazard Analysis Critical Control Point (HACCP)” systems validation was issued in May 2015. The guideline provided small and very small establishments 11 months to gather initial in-plant validation data that was no longer be applicable to their systems.

Still confusing
FSIS began enforcing the use of HACCP in federally regulated meat processing plants 17 years ago, and both inspectors and plant operators are still trying to get it right. While most plants have gathered the scientific documents to theoretically support the justification of their systems, many — as exemplified by a series of recalls in the last eight years or so — haven’t completed the other major task: Gather in-plant data to prove that HACCP actually works as intended in the plant.

Despite the years of back-and-forth it took to produce the latest iteration of the validation guidelines, and what experts see as vast improvements in them, there are sometimes gaps between the regulators and the regulated with regard to their understanding of how things work on paper and how things work in actual meat processing plants.

"The current scientific literature may not be easily applied by the industry at this point,” Barb Masters, who works for Washington, D.C.-based OFW Law as a senior policy advisor primarily helping the meat and poultry industry comply with federal regulations, told Meatingplace.

How to prepare for an FSA
Once processors are notified that a food safety assessment (FSA), the government audit of a food safety system, has been scheduled at their facility, there still are a few things they can do proactively before the process starts.

The auditor typically will ask for 60 to 90 days of records related to the implementation of the various food safety systems, so it makes sense to conduct an in-house review of that same block of data. Collect at least the past 90 days of HACCP, SSOP, prerequisite programs and any other records related to the implementation of the facility's food safety systems.

Then review them – line by line. If there are any issues, such as missing initials or time related to a monitoring or verification entry, operators should identify them, document the correction and follow up with the personnel involved to prevent recurrence.
To be clear, operators cannot change the records to recreate the record to appear to have been compliant from the start. It is essential to identify what was lacking and demonstrate that the issue was both identified and corrected.

The fact that an error or omission was found should remain apparent to avoid any misunderstanding by FSIS personnel. By reviewing those records and addressing the issues that were identified, operators may avoid unexpected findings from the FSA of recordkeeping issues.

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