Webinar-DIRECTIVE-6410-3 - The National Chicken Council

Report
United States Department of Agriculture
Food Safety and Inspection Service
FSIS DIRECTIVE 6410.3
VERIFYING SANITARY DRESSING AND PROCESS
CONTROL PROCEDURES BY OFF-LINE INSPECTION
PROGRAM PERSONNEL (IPP) IN POULTRY
SLAUGHTER OPERATIONS
A Systems Approach
OPPD Policy Development Division
Omaha, Nebraska
1
United States Department of Agriculture
Food Safety and Inspection Service
OBJECTIVES
• Discuss a ‘system’ as it relates to sanitary
dressing and process control
• Role of sanitary dressing and process control as
a part of the establishment’s food safety system
• Directive 6410.3
– Locations in the slaughter process where carcass
contamination is most likely to occur
– Verification
– Establishment Interventions
– Determining compliance
OPPD Policy Development Division
Omaha, Nebraska
2
United States Department of Agriculture
Food Safety and Inspection Service
BACKGROUND
• Effective sanitary dressing and process
control procedures are crucial to an
establishment’s ability to produce a clean,
safe, and wholesome product.
• Carcass contamination is a vehicle for the
transfer of pathogens. As set out in 9 CFR
381.65(e), poultry carcasses contaminated
with visible fecal material must be
prevented from entering the chilling tank.
OPPD Policy Development Division
Omaha, Nebraska
3
United States Department of Agriculture
Food Safety and Inspection Service
KEY POINT
Sanitary dressing noncompliances are
determined based on cumulative information
reflecting the food safety system
Sanitary Dressing noncompliance is not
documented in regard to one point in the
process.
Sanitary Dressing noncompliance is not
documented in regard to one contamination
incident.
OPPD Policy Development Division
Omaha, Nebraska
4
United States Department of Agriculture
Food Safety and Inspection Service
FOOD SAFETY SYSTEM
• A food safety system includes all aspects of
the operation
• For example:
–
–
–
–
–
–
Slaughter
Fabrication and Grinding
Product storage
Product Testing
Control Programs
Customer feedback
OPPD Policy Development Division
Omaha, Nebraska
5
What is an example of a
system?
• Building a house
• Flying an airplane
• Making bread
• Sewing a dress
• Slaughtering cattle
What is the key to making the
system work?
• Follow the blueprints
• Complete a pre-flight
check and follow the
flight plan
• Follow the recipe
• Follow the pattern
• Follow Sanitary Dressing
& Process Control
Procedures
OPPD Policy Development Division
6
Omaha, Nebraska
OPPD Policy Development Division
Omaha, Nebraska
7
United States Department of Agriculture
Food Safety and Inspection Service
SYSTEM APPROACH
• It is the expectation that each time IPP evaluate
the sanitary dressing & process control
procedures, they look at the entire slaughter
system, and beyond , not at just one point in
the process
NOTE: When determining compliance, IPP
should consider what they are seeing at that
time regarding the system, but are to also
consider what has been occurring historically
in the operation (i.e., consider cumulative
information)
OPPD Policy Development Division
Omaha, Nebraska
8
United States Department of Agriculture
Food Safety and Inspection Service
All steps in
Slaughter
operations
including
waivers
Salmonella
Category
OPPD Policy Development Division
Omaha, Nebraska
9
United States Department of Agriculture
Food Safety and Inspection Service
SYSTEM APPROACH
FSIS’ role is to think about all the available
information to see how the pieces interact
with each other and ultimately fit together
OPPD Policy Development Division
Omaha, Nebraska
10
United States Department of Agriculture
Food Safety and Inspection Service
NOTE
IPP have an opportunity to gather
information about the system
every time
they walk out onto the slaughter floor
regardless of whether or not they are
conducting the PHIS Poultry Sanitary
Dressing task
OPPD Policy Development Division
Omaha, Nebraska
11
United States Department of Agriculture
Food Safety and Inspection Service
Role of sanitary dressing and
process control as a part of the
establishment’s food safety
system
OPPD Policy Development Division
Omaha, Nebraska
12
United States Department of Agriculture
Food Safety and Inspection Service
SANITARY DRESSING
• Practice of handling carcasses and parts
by establishment employees and
machinery, throughout the slaughter
process, in a manner that produces a
clean, safe, wholesome poultry product in
a sanitary environment.
OPPD Policy Development Division
Omaha, Nebraska
13
United States Department of Agriculture
Food Safety and Inspection Service
Process Control Procedures
• A defined procedure or set of procedures
designed by an establishment to provide
control of those operating conditions that are
necessary for the production of safe,
wholesome food.
• Process Control Procedures put in place by
establishments typically include:
– observing or measuring system performance
– analyzing the results to develop measures to ensure the
process remains under control
– taking action when necessary to ensure that the system
continues to perform within the control criteria
– planned measures taken by the establishment in
response to any loss of process control
OPPD Policy Development Division
Omaha, Nebraska
14
United States Department of Agriculture
Food Safety and Inspection Service
NOTE
The point of sanitary dressing and process
control is to reduce contamination and to
ensure that poultry carcasses are as clean
as possible throughout the entire slaughter
operation.
The establishment should not be waiting
until just before the birds falls into the
chiller to take care of contamination
OPPD Policy Development Division
Omaha, Nebraska
15
United States Department of Agriculture
Food Safety and Inspection Service
NOTE
Contamination events on
carcasses should be prevented
throughout the slaughter process to
in order to prevent the creation of
insanitary conditions
OPPD Policy Development Division
Omaha, Nebraska
16
United States Department of Agriculture
Food Safety and Inspection Service
WHY IT’S IMPORTANT
• Preventing carcass contamination is
essential to ensuring that decontamination
practices and validated antimicrobial
interventions are effective to reduce
Salmonella and generic E.coli
• Being proactive is better for food safety
than being reactive
OPPD Policy Development Division
Omaha, Nebraska
17
FSIS DIRECTIVE 6410.3
OPPD Policy Development Division
Omaha, Nebraska
18
United States Department of Agriculture
Food Safety and Inspection Service
FSIS DIRECTIVE 6410.3
• Provides definitions for such terms as
Process Control, Sanitary Dressing,
Contamination of Carcasses and Parts,
and Food safety System.
• Describes points in the slaughter process
where carcass contamination with
foodborne pathogens, such as Salmonella
and Campylobacter, is most likely to
occur
OPPD Policy Development Division
Omaha, Nebraska
19
United States Department of Agriculture
Food Safety and Inspection Service
FSIS DIRECTIVE 6410.3
• Explains how IPP are to gather and
assess information about the slaughter
operation when verifying that the
establishment’s sanitary dressing and
process control procedures are effectively
ensuring sanitary conditions
• Addresses supervisory responsibilities
associated with IPP verification activities
OPPD Policy Development Division
Omaha, Nebraska
20
United States Department of Agriculture
Food Safety and Inspection Service
DEFINITIONS
• Contamination of Carcasses and Parts:
Carcasses and parts that, based on
organoleptic inspection, have been
prepared, packed, or held under insanitary
conditions that may have caused them to
come into contact with filth, or that may
have caused them to be injurious to
health, and are condemnable unless they
can be effectively reprocessed.
OPPD Policy Development Division
Omaha, Nebraska
21
United States Department of Agriculture
Food Safety and Inspection Service
NOTE
Not all contamination is directly associated
with food safety.
Sound judgment must be used when determining
whether the conditions observed during the
slaughter process are part of the slaughter
process or are present as an unavoidable
consequence of the slaughter process.
OPPD Policy Development Division
Omaha, Nebraska
22
United States Department of Agriculture
Food Safety and Inspection Service
DEFINITIONS
• Food Safety System: A systematic approach
implemented to prevent foodborne illness.
The food safety system includes the
development and implementation of a Hazard
Analysis and Critical Control Point (HACCP)
Plan in accordance with 9 CFR 417 and a
Sanitation Standard Operating Procedure
(SOP) in accordance with 9 CFR 416.
OPPD Policy Development Division
Omaha, Nebraska
23
United States Department of Agriculture
Food Safety and Inspection Service
ADDITIONAL DEFINITIONS
• Poultry Chiller Makeup Water
• Free Available Chlorine
• Reuse Water
OPPD Policy Development Division
Omaha, Nebraska
24
United States Department of Agriculture
Food Safety and Inspection Service
POTENTIAL CONTAMINATION POINTS
•
•
•
•
•
•
•
•
•
Live receiving and hanging
Stunning and Bleeding
Scalding
Feather removal and Picking
Evisceration
On-line reprocessing
Off-line reprocessing
Product reconditioning
Chilling
OPPD Policy Development Division
Omaha, Nebraska
25
United States Department of Agriculture
Food Safety and Inspection Service
LIVE RECEIVING & HANGING
• Poultry arrive at the
establishment in transport
cages, are unloaded, and
are hung on shackles
before stunning and
bleeding
• Potential for
contamination with enteric
pathogens because of the
presence of these
pathogens on the
feathers, skin, crop, and
cloaca & in the feces
OPPD Policy Development Division
Omaha, Nebraska
26
United States Department of Agriculture
Food Safety and Inspection Service
STUNNING & BLEEDING
• Point in the slaughter
process where the bird is
stunned, cut, & bled
• Stunning methods used
typically used include
electrical, mechanical, or
chemical
• Bleeding ensures death
by slaughter and ensures
that poultry have stopped
breathing before going
into the scalder
OPPD Policy Development Division
Omaha, Nebraska
27
United States Department of Agriculture
Food Safety and Inspection Service
SCALDING
• Point in the slaughter
process where the
birds are placed in hot
water in order to
facilitate feather
removal
• Salmonella and
Campylobacter
contamination
consistently decrease
when scalding is well
controlled
OPPD Policy Development Division
Omaha, Nebraska
28
United States Department of Agriculture
Food Safety and Inspection Service
FEATHER REMOVAL & PICKING
• Point in the slaughter
process designed to
remove feathers and, in
most cases, the
uppermost layer of skin
before evisceration
• Feather removal (i.e.,
picking) frequently
results in increased
microbial contamination
of poultry carcasses
OPPD Policy Development Division
Omaha, Nebraska
29
United States Department of Agriculture
Food Safety and Inspection Service
EVISCERATION
• Point in the process
where removal of the
internal organs, and of
any processing defects,
from the poultry
carcasses occurs
• Evisceration includes
multiple processes. It
begins at the transfer
point (i.e., re-hang) and
ends when the carcass
enters the chiller.
OPPD Policy Development Division
Omaha, Nebraska
30
United States Department of Agriculture
Food Safety and Inspection Service
ON-LINE REPROCESSING
• Point in the slaughter
process where
contaminated
eviscerated carcasses
are reprocessed on-line
following the provisions
of a waiver granted in
accordance with 9 CFR
381.3(b)
OPPD Policy Development Division
Omaha, Nebraska
31
United States Department of Agriculture
Food Safety and Inspection Service
NOTE
Establishments need to have requested to
participate in the Salmonella Initiative
Program (SIP) or have a SIP letter (i.e. a
No Objection letter) on file that addresses
the alternative procedures or criteria that
the establishment must adhere to in order
to maintain its waiver.
See FSIS Directive 5020.1
OPPD Policy Development Division
Omaha, Nebraska
32
United States Department of Agriculture
Food Safety and Inspection Service
OFF-LINE REPROCESSING
• This is the point in
the evisceration
process where
internally
contaminated
carcasses are
reprocessed off-line
according to 9 CFR
381.91(b)(1) and
(b)(2)
OPPD Policy Development Division
Omaha, Nebraska
33
United States Department of Agriculture
Food Safety and Inspection Service
PRODUCT RECONDITIONING
• Point in slaughter and
further processing
where contaminated
eviscerated carcasses
& parts that have
fallen on the floor, or
otherwise have
become contaminated
off-line, are
reconditioned in order
to restore sanitary
conditions.
OPPD Policy Development Division
Omaha, Nebraska
34
United States Department of Agriculture
Food Safety and Inspection Service
CARCASS CHILLING
• Point when eviscerated
carcasses are chilled in
order to inhibit microbial
growth and meet the
regulatory requirements of
9 CFR 381.66(b)(1)
• There are two types of
chilling systems: immersion
and air
• Cross-contamination may
occur when sanitary
conditions are not
maintained in the chiller, or
when carcasses entering
the chiller carry high levels
of pathogens
OPPD Policy Development Division
Omaha, Nebraska
35
United States Department of Agriculture
Food Safety and Inspection Service
GIBLET CHILLING
• Cross-contamination may occur when sanitary
conditions are not maintained in the giblet
chiller, or when parts entering the chiller carry
high levels of contamination
OPPD Policy Development Division
Omaha, Nebraska
36
United States Department of Agriculture
Food Safety and Inspection Service
PHIS SANITARY DRESSING TASK
• PHIS requires that each task have a “start”
and “end” date
• IPP are not limited to conducting the Poultry
Sanitary Dressing task all in one day
• Can be spread out over a period of days, if
necessary, in order to gather as much
available information so that IPP can make a
sound regulatory decision about the system
OPPD Policy Development Division
Omaha, Nebraska
37
United States Department of Agriculture
Food Safety and Inspection Service
FSIS VERIFICATION
• The verification activities addressed in the directive
are to be used in conjunction with, and can be
conducted simultaneously with, those addressed in
the following directives:
– FSIS PHIS Directive 5000.1, Verifying and
Establishment’s
– FSIS Directive 6100.3 Ante-mortem and Post-mortem
Poultry Inspection
– FSIS 6420.2, Verification of Procedures for Controlling
Fecal Material, Ingesta and Milk in Slaughter Operations
– FSIS Directive 7000.1, Verification of Non-food Safety
Consumer Protection Regulatory Requirements,
Part IV, G
OPPD Policy Development Division
Omaha, Nebraska
38
United States Department of Agriculture
Food Safety and Inspection Service
FSIS VERIFICATION
• IPP need to verify, in off-line activities, that
preventive steps are taken to ensure
carcasses and parts, including giblets, are
not contaminated, and that contamination
events are rare.
• In addition, before the carcasses enter the
chiller, IPP conduct zero tolerance checks
to verify that there is no visible fecal
contamination on the carcasses.
OPPD Policy Development Division
Omaha, Nebraska
39
United States Department of Agriculture
Food Safety and Inspection Service
FSIS VERIFICATION
• IPP verify compliance with 9 CFR 381.65(e)
by determining whether the establishment's
sanitary dressing and process control
procedures are adequate to ensure that
carcasses entering the chiller are not
contaminated with fecal material.
OPPD Policy Development Division
Omaha, Nebraska
40
United States Department of Agriculture
Food Safety and Inspection Service
FSIS VERIFICATION
• IPP that perform off-line slaughter verification
duties are to perform the PHIS Poultry
Sanitary Dressing task to verify that
insanitary conditions are not being created.
– Evaluate the sanitary dressing and process
control procedures as they relate to the
establishment’s food safety system; and not just
as a single aspect of the slaughter process.
– Verify that the sanitary dressing, and process
control procedures, are sufficient to prevent the
contamination of carcasses during slaughter
operations.
OPPD Policy Development Division
Omaha, Nebraska
41
United States Department of Agriculture
Food Safety and Inspection Service
FSIS VERIFICATION
• Conditions that could affect the sanitary
dressing and process control system,
include but are not limited to, the following:
– An increased number of positive
establishment or FSIS Salmonella or
Campylobacter test results;
– An increased number of establishment
generic E.coli or indicator organism test
results that exceed either the establishment’s
or regulatory control limits;
OPPD Policy Development Division
Omaha, Nebraska
42
United States Department of Agriculture
Food Safety and Inspection Service
FSIS VERIFICATION
– An increase in fecal zero tolerance
noncompliances;
– Documented evidence of carcass
contamination that demonstrates a repeated
or on-going loss of process control (e.g.,
incidental contamination documented under
SPS, or zero tolerance noncompliances).
OPPD Policy Development Division
Omaha, Nebraska
43
United States Department of Agriculture
Food Safety and Inspection Service
FSIS VERIFICATION
• IPP are to gather information using the
questions in the directive to determine
whether an establishment’s slaughter
operation meets the requirements of 9 CFR
416 or is creating insanitary conditions that
may result in product contamination.
• The questions provided at each point in the
directive may vary depending on the type of
slaughter operation being conducted (e.g., a
highly automated line vs. traditional hand
operated line).
OPPD Policy Development Division
Omaha, Nebraska
44
United States Department of Agriculture
Food Safety and Inspection Service
NOTE
The questions in the directive are not
to be considered to be a checklist and
are not all-inclusive but are to be
considered when gathering
information about the establishment’s
food safety system.
OPPD Policy Development Division
Omaha, Nebraska
45
United States Department of Agriculture
Food Safety and Inspection Service
NOTE
A negative response to one of the questions in
the directive is not an automatic indication of
regulatory noncompliance or of a system failure.
A negative response may simply mean that
additional consideration is needed or other
considerations apply.
When making determinations of regulatory
compliance, IPP performing off-line duties are
to consider how all the information they have
gathered relates to the food safety system.
OPPD Policy Development Division
Omaha, Nebraska
46
United States Department of Agriculture
Food Safety and Inspection Service
FSIS VERIFICATION
• This evaluation could include, but is not limited
to, considering the following information:
– Information regarding sanitary dressing and process
control procedures, and decontamination and
antimicrobial intervention treatments;
– Feedback from further processing operations to the
slaughter operation
– Observations of the plant employees performance of
their assigned duties at particular points in the
process.
OPPD Policy Development Division
Omaha, Nebraska
47
United States Department of Agriculture
Food Safety and Inspection Service
NOTE
When the information gathered
suggests that the establishment has
lost control of its process, IPP are to
consider whether they should increase the
frequency of their verification of sanitary
dressing and process control procedures.
They are to consult their immediate
supervisor if they need guidance.
OPPD Policy Development Division
Omaha, Nebraska
48
United States Department of Agriculture
Food Safety and Inspection Service
Establishment Interventions
OPPD Policy Development Division
Omaha, Nebraska
49
United States Department of Agriculture
Food Safety and Inspection Service
ESTABLISHMENT INTERVENTIONS
• Interventions typically are able to reduce
bacteria at a given rate (e.g., a 2 log
reduction)
• If the bacteria is present at a 5 log level,
the intervention won’t be able to address
all the bacteria (i.e. the intervention is
overwhelmed)
OPPD Policy Development Division
Omaha, Nebraska
50
United States Department of Agriculture
Food Safety and Inspection Service
ESTABLISHMENT INTERVENTIONS
• Measures need to be taken from the
beginning of slaughter process, including at
receiving, to minimize contamination so that
the interventions will work appropriately
• Without effective sanitary dressing and
process control procedures, carcasses
could become excessively contaminated,
and thereby overwhelming any interventions
OPPD Policy Development Division
Omaha, Nebraska
51
United States Department of Agriculture
Food Safety and Inspection Service
OVERWHELM AN INTERVENTION
There is so much contamination on
the bird, or the carcass, that the
establishment’s intervention(s)
aren’t capable of working as
designed and therefore not able to
achieve a desired level of
pathogen reduction
OPPD Policy Development Division
Omaha, Nebraska
52
United States Department of Agriculture
Food Safety and Inspection Service
OVERWHELM AN INTERVENTION
• When contamination overwhelms the
decontamination practices and antimicrobial
interventions, the establishment may no
longer be able to reduce Salmonella and
Campylobacter to the levels expected by
the HACCP plan
• It is essential that slaughter operations also
have interventions that are integrated with
sanitary dressing and process control
procedures in order to reduce pathogens
OPPD Policy Development Division
Omaha, Nebraska
53
United States Department of Agriculture
Food Safety and Inspection Service
Determining Compliance
OPPD Policy Development Division
Omaha, Nebraska
54
United States Department of Agriculture
Food Safety and Inspection Service
BEFORE WE PROCEED….
• An issue that needs to be addressed is
how incidental contamination that is
determined to create an insanitary
condition is to be documented in PHIS
OPPD Policy Development Division
Omaha, Nebraska
55
United States Department of Agriculture
Food Safety and Inspection Service
INCIDENTAL CONTAMINATION
• Incidental contamination (e.g., ingesta, feces,
UFM, rail dust) does not automatically
represent an insanitary condition.
• Even if there are observations of
contamination on carcasses during the
slaughter process, the establishment still has
the opportunity to implement measures that
will address the contamination before the
carcasses enter the chiller.
OPPD Policy Development Division
Omaha, Nebraska
56
ALL THE SLAUGHTER STEPS &
INTERVENTIONS ALONG THE WAY
OPPD Policy Development Division
Omaha, Nebraska
57
What do FSIS Personnel
Need to Do to Determine Compliance ?
Information
the Information
Compliance or
noncompliance
OPPD Policy Development Division
Omaha, Nebraska
58
GATHER
• Gather as much information
as possible
– In-plant Observations
• Your own
• On-line IPP
• PHV/SPHV
– Historical information
• NRs
• MOIs
OPPD Policy Development Division
Omaha, Nebraska
– Test Results
• Establishment
Results
• FSIS Results
– Communication with
other inspectors
59
COMMUNICATION
EST A
Slaughter
There have been problems with
sanitary dressing and several zero
tolerance noncompliances
OPPD Policy Development Division
Omaha, Nebraska
Fabrication
Thanks…That might explain the
recent positive test result of
ground poultry
60
COMMUNICATION
EST A
Slaughter
Fabrication
There has been a
positive test result in
the trim
Thanks…We will check the
sanitary dressing and zero
tolerance
OPPD Policy Development Division
Omaha, Nebraska
61
COMMUNICATION
EST B
EST A
There was a positive
test result in the
ground poultry
Thanks…We will check the
sanitary dressing and zero
tolerance
OPPD Policy Development Division
Omaha, Nebraska
62
United States Department of Agriculture
Food Safety and Inspection Service
ASSESS
• Sanitation is the foundation of a food
safety system
• Sanitary Dressing and Process control is a
part of that sanitation foundation
• Decisions made by the establishment to
control enteric pathogens such as
Salmonella will be affected by what the
establishment does in regard to sanitary
dressing and process control
OPPD Policy Development Division
Omaha, Nebraska
63
United States Department of Agriculture
Food Safety and Inspection Service
REGULATORY BASIS
• Establishments are expected to slaughter
and process poultry in a manner designed
to prevent contamination of carcasses
– 9 CFR 416.1 requires that establishments be
operated such that they do not create
insanitary conditions or contaminate product
– 9 CFR 381.65(e) requires prevention of
carcass contamination
OPPD Policy Development Division
Omaha, Nebraska
64
United States Department of Agriculture
Food Safety and Inspection Service
REGULATORY BASIS
• Other regulations can be integral to
sanitary dressing and process control if
procedures related to those regulations
have been included in the SSOP, HACCP
plan or a prerequisite program
–9 CFR 416
–9 CFR 417
OPPD Policy Development Division
Omaha, Nebraska
65
United States Department of Agriculture
Food Safety and Inspection Service
DETERMINE
Any determination of
noncompliance must be
based on all the pieces of
information that has been
gathered regarding the
system
OPPD Policy Development Division
Omaha, Nebraska
66
United States Department of Agriculture
Food Safety and Inspection Service
DETERMINING COMPLIANCE
• Determining compliance involves deciding
if, overall, sanitary dressing operation and
process control procedures that are in
place, are effective to prevent the creation
of insanitary conditions and thereby
prevent contamination of carcasses
OPPD Policy Development Division
Omaha, Nebraska
67
United States Department of Agriculture
Food Safety and Inspection Service
DETERMINING COMPLIANCE
• The thought process for determining compliance
of the sanitary dressing and process control
procedures is different because it is about a
system
• A single, specific event of finding contamination
on a carcass may not be significant as it relates
to the system
OPPD Policy Development Division
Omaha, Nebraska
68
United States Department of Agriculture
Food Safety and Inspection Service
INCIDENTAL CONTAMINATION
KEY POINT
If IPP find that
insanitary conditions exist as a result of
incidental contamination,
they are to document their findings using the
PHIS SPS Verification task citing 9 CFR
381.65(a) and the appropriate SPS
regulations related to incident
OPPD Policy Development Division
Omaha, Nebraska
69
United States Department of Agriculture
Food Safety and Inspection Service
NOTE
A finding of incidental contamination that
demonstrates the creation of an insanitary
condition is to be addressed as
a specific SPS incident
(e.g., SPS/employee hygiene)
HOWEVER, one specific incident will not
normally be documented as a failure of the
sanitary dressing or process control
procedures
(i.e., is not a failure of the system)
OPPD Policy Development Division
Omaha, Nebraska
70
United States Department of Agriculture
Food Safety and Inspection Service
DETERMINING NONCOMPLIANCE
• Use the information gathered while
performing verification procedures to
determine compliance
Remember: A series of questions that IPP
can ask in order to assist in the
determination of compliance are
provided in the directive
OPPD Policy Development Division
Omaha, Nebraska
71
United States Department of Agriculture
Food Safety and Inspection Service
DOCUMENTING NONCOMPLIANCE
• Document the creation of the insanitary
condition using the Poultry Sanitary
Dressing task on a Noncompliance Record
(NR) (9 CFR 416.1 and 381.65(a))
– Cite 9 CFR 381.65(a) to address the contamination of
carcasses
– Cite the appropriate SPS regulations to address the
creation of the insanitary condition.
• Example: cite 9 CFR 416.5(a) if improper employee hygiene
practices have resulted in contamination of the carcass
OPPD Policy Development Division
Omaha, Nebraska
72
United States Department of Agriculture
Food Safety and Inspection Service
DOCUMENTING NONCOMPLIANCE
• Review available NRs to determine if a
trend is developing. NRs can be
associated as necessary in accordance
with the instructions in FSIS PHIS
Directive 5000.1, Chapter 5, VII to
document that a trend of noncompliance is
occurring.
OPPD Policy Development Division
Omaha, Nebraska
73
SUPERVISORY RESPONSIBILITY
OPPD Policy Development Division
Omaha, Nebraska
74
United States Department of Agriculture
Food Safety and Inspection Service
SUPERVISORY RESPONSIBILITY
• NOTE: “Supervisory personnel” refers to any
Office of Field Operations (OFO) personnel
that supervise IPP who conduct off-line
verification activities in poultry slaughter
operations.
• FSIS supervisory personnel are to discuss
the key points addressed in the directive with
IPP.
OPPD Policy Development Division
Omaha, Nebraska
75
United States Department of Agriculture
Food Safety and Inspection Service
SUPERVISORY RESPONSIBILITY
• Supervisory personnel are to discuss the
potential contamination points in the
slaughter process addressed in this directive
to ensure that IPP understand their role in
verifying whether the establishment is
initiating measures designed to prevent the
creation of insanitary conditions by
preventing the contamination of carcasses.
OPPD Policy Development Division
Omaha, Nebraska
76
United States Department of Agriculture
Food Safety and Inspection Service
SUPERVISORY RESPONSIBILITY
• FSIS supervisory personnel are to emphasize
that IPP are to verify that establishments
have documentation, in accordance with 9
CFR 417.5(a)(1), sufficient to support any
food safety decisions that they make based
on the implementation of sanitary dressing
and process control procedures.
OPPD Policy Development Division
Omaha, Nebraska
77
United States Department of Agriculture
Food Safety and Inspection Service
SUPERVISORY RESPONSIBILITY
• Supervisors are to discuss how sanitary dressing and
process control procedures have an impact on
pathogens such as Salmonella and Campylobacter
testing results or raw ground poultry.
• Supervisors are to emphasize that IPP in the slaughter
areas are to conduct a purposeful evaluation of the
establishment’s sanitary dressing and process control
procedures.
• Supervisors are to correlate with IPP in processing
areas whenever poor implementation of the
procedures could lead to positive results in Salmonella
set sampling and in raw ground poultry testing.
OPPD Policy Development Division
Omaha, Nebraska
78
United States Department of Agriculture
Food Safety and Inspection Service
SUPERVISORY RESPONSIBILITY
• Supervisory personnel are to ensure that IPP are
correctly applying the inspection methodology, are
making informed decisions, are properly
documenting findings, and are taking the
appropriate enforcement actions as instructed in
this directive.
• Supervisory personnel are to refer to the current
version of the FSIS Guide for conducting In-Plant
Performance System Assessments (IPPS) for
additional guidance and instructions.
OPPD Policy Development Division
Omaha, Nebraska
79
United States Department of Agriculture
Food Safety and Inspection Service
Summary
• The slaughter process is a system
• Sanitary dressing and process control
procedures are key to preventing insanitary
conditions and carcass contamination
• Reducing Salmonella is a regulatory
requirement & is essential to ensuring food
safety
OPPD Policy Development Division
Omaha, Nebraska
80
United States Department of Agriculture
Food Safety and Inspection Service
Summary
(Continued)
• Interventions need to be capable of reducing
or eliminating a food safety hazard and not
be overwhelmed by the amount of
contamination or number of pathogens on
the carcass
OPPD Policy Development Division
Omaha, Nebraska
81
United States Department of Agriculture
Food Safety and Inspection Service
Summary
(Continued)
• Incidental contamination that creates an
insanitary condition is documented as SPS
noncompliance
OPPD Policy Development Division
Omaha, Nebraska
82
United States Department of Agriculture
Food Safety and Inspection Service
Summary
(Continued)
Sanitary dressing noncompliances are
determined based on cumulative information
reflecting the food safety system
Sanitary Dressing noncompliance is not
documented in regard to one point in the
process.
Sanitary Dressing noncompliance is not
documented in regard to one contamination
incident.
OPPD Policy Development Division
Omaha, Nebraska
83
Incidental
contamination
NRs
Positive sample
results (e.g.,
generic e-coli,
Salmonella)
Employee
Hygiene
NRs
Weekly
Meeting MOIs
Failure to
implement
prerequisite
programs
Zero
Tolerance
NRs
OPPD Policy Development Division
Omaha, Nebraska
84
United States Department of Agriculture
Food Safety and Inspection Service
OPPD Policy Development Division
Omaha, Nebraska
85

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