FSIS has indicated that based on some recent “negative events;” they will be increasing verification activities. Increased verification should not mean increased noncompliance. We should do what we say we are going to do and document that we did it—each and every time.
That said, we all know life isn’t always perfect. Therefore, I would encourage everyone to use this opportunity to “dust off” and get ahead of the increased verification activity.
It is important to rotate, and use a different person to do verification. You may rotate between departments or, if you have more than one location, rotate between locations. Different eyes see different things.
Use the FSIS food safety assessment tools as a “checklist” to measure against. See FSIS Directive 5100.1.
Be certain that your team is implementing the food safety programs as intended. But also use this as an opportunity to look at the design of the programs. Are the programs still doing today what you originally designed them for? Have you changed ingredients or processes that may impact your hazard analysis?
Have supervisory personnel come in during pre-op? Is the cleaning crew adequately covering the surface of equipment with sanitizer? Are they overspraying with high pressure hoses after areas have been cleaned? Is there cross traffic between raw and ready to eat – equipment or people? Remember, pre-op is as important as operations!
If you slaughter animals and receive them at odd hours, supervisory personnel should also randomly visit during these times as well. Is animal handling as expected? If you have cameras for remote auditing, have you changed the areas for review so no one becomes comfortable with where the cameras are reviewing?
Use the results of these “mock FSAs” and supervisory visits to see if there are any vulnerabilities in your system that need to be addressed. If so, these should be addressed as soon as possible.
By conducting a “tune up,” you will be ready for the additional verification activities that FSIS will be conducting.
About “Dr. Doom”
Mixed in with the attorneys at OFW Law is the former USDA Food Safety Inspection Service’s (FSIS) Administrator, Dr. Barbara Masters. Dr. Masters is a veterinarian who spent eighteen years with FSIS – the final three years as Acting Administrator and Administrator. During her rise to the Administrator’s position, Dr. Masters served as the Deputy Assistant Administrator for Office of Field Operations. While in these key leadership positions at FSIS, Dr. Masters’ primary focus was on the implementation of science-based policies for the protection of public health. Dr. Masters issued the initial Federal Register Notices for a systematic approach to humane treatment of livestock and poultry.
Dr. Masters was involved in the drafting of the training of inspection personnel on the Hazard analysis and critical control points (HACCP) and Sanitation Standard Operating Procedures (SSOP) regulations. She was the lead of the FSIS HACCP Hotline. In addition, Dr. Masters provided technical review for establishment’s hazard analysis, HACCP plans and supporting documentation. She started her career at FSIS as a public health veterinarian that had responsibilities for ante-mortem inspection, sanitation inspection and all post-mortem inspection responsibilities. She has a good understanding of what happens at the in-plant location, because she has spent many of long days working there.