Meat Industry INSIGHTS Newsletter

970601 FSIS Going too Far With SSOP "Corrective Actions"?

Sanitation Standard Operation Procedures (SSOPs) addresses the prevention of direct product contamination. Section CFR 416.15(a) of the regulation mandates corrective actions when either the plant's or the inspector's findings indicate a condition which could or is resulting in direct product contamination. CFR 416.15 (b) states that, "Corrective actions include procedures to ensure appropriate disposition of product(s) that may be contaminated, restore sanitary conditions, and prevent the recurrence of direct product contamination or adulteration of product(s), including appropriate reevaluation and modification of the SSOPs and the procedures specified therein."

Recently a number of National Meat Association members have indicated to the association's Director of Regualtory Issues Ken Mastracchio that FSIS inspection personnel are requiring plants to comply with CFR 416.15(b) in Instances Where Direct Product Contamination Is Not An Issue. For example, when plant personnel documents a piece of paper towel on the floor of a processing room, assigned inspection personnel are instructing plant management to document "corrective" and "preventive" actions. According to FSIS, corrective and preventive actions should be assigned to instances where product contamination is a risk factor. A source at FSIS also indicated that situations of a non-critical nature could be documented by stating the immediate action or scheduled time of completion. This information is contained in a FSIS Guideline that was distributed to field supervisors in April of this year. The guideline pertains to in-plant SSOP verification, documentation and enforcement activities.

NMA also learned that FSIS will hold correlation meetings in order to address any disparities or misinterpretations associated with the verification phase of SSOPs. Initial preparation for training the correlators will take place this month and FSIS intends to hold the meeting on the job site. This may afford the opportunity for employees directly involved to participate. u

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