Meat and Poultry:

Improved Oversight and Training Will Strengthen New Food Safety System

RCED-00-16: Published: Dec 8, 1999. Publicly Released: Dec 8, 1999.

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Pursuant to a legislative requirement, GAO reviewed the Department of Agriculture's (USDA) efforts to improve the safety of meat and poultry products, focusing on whether: (1) the system adopted by USDA in its regulations is consistent with the seven Hazard Analysis and Critical Control Point (HACCP) principles endorsed by the National Advisory Committee on Microbiological Criteria for Foods; (2) the HACCP training program for USDA inspectors is adequate and science-based; and (3) there is an adequate dispute resolution (appeals) process between plants and USDA under the new HACCP inspection system.

GAO noted that: (1) USDA's HACCP regulations are consistent with the 7 principles endorsed by the Advisory Committee; (2) the 32 plants GAO visited have HACCP plans, however, some plant managers excluded certain hazards because they believed that existing quality control programs or good manufacturing practices effectively controlled them; (3) to ensure appropriate verification and oversight by USDA inspection personnel, the regulations state plants must identify all hazards reasonably likely to occur in their HACCP plans and control those hazards through their HACCP programs; (4) USDA regulations preclude the use of non-HACCP programs to control hazards reasonably likely to occur because USDA's inspectors focus on ensuring compliance with HACCP regulations and have limited oversight over non-HACCP programs; (5) inspectors received the training needed to oversee plants' implementation of HACCP programs, but many inspectors responding to GAO's nationwide survey reported they would benefit from refresher courses; (6) USDA's training program provided a basic introduction to HACCP's science-based principles while emphasizing the compliance aspects of the inspectors' HACCP duties; (7) however, GAO's review of USDA's HACCP training curriculum and the results of GAO's survey found several aspects of the training program needed to be clarified and reinforced to provide inspectors with the tools needed to conduct consistent and effective inspections of plants' compliance with HACCP requirements; (8) many survey responses suggested that the training was unclear about: (a) inspectors' authority to request that plants make changes to their HACCP plans; (b) the correct frequency for microbial testing for salmonella; (c) the actions inspectors can take if they become aware of microbial contamination that a plant has identified as a hazard through programs that are outside its HACCP plan; and (d) situations where it is appropriate for inspectors to issue noncompliance notices; (9) USDA's dispute resolution process provides industry with an appropriate mechanism to appeal inspectors' enforcement actions; (10) managers said they appeal noncompliance notices that appear inaccurate; (11) repeated notices can result in a Food Safety and Inspection Service (FSIS) determination that the plant's HACCP system failed, however, USDA regulations fail to explicitly state the number or type of noncompliance notices that can result in that determination; and (12) GAO could not verify the accuracy of managers concerns as USDA's new appeals tracking system contains incomplete and inconsistent information.

Status Legend:

More Info
  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: To ensure the consistent inspection of HACCP programs, the Secretary of Agriculture should direct the Administrator, FSIS, to provide clarification and additional training for inspectors regarding inspectors' responsibilities for how and when to file noncompliance notices and how to select the correct trend indicators.

    Agency Affected: Department of Agriculture

    Status: Closed - Implemented

    Comments: FSIS has conducted three conferences across the nation to address, among other things, inspectors' responsibilities for how and when to file noncompliance notices and how to select the correct trend indicators. In addition, the agency is developing a computer-based training program for use on all Field Automation Information Management computers. Their goal is to complete this program by the end of October 2000. The agency will continue with supervisory personnel meetings to cover these topics.

    Recommendation: To ensure the consistent inspection of HACCP programs, the Secretary of Agriculture should direct the Administrator, FSIS, to provide clarification and additional training regarding inspectors' responsibilities for microbial sampling and the frequency of salmonella testing.

    Agency Affected: Department of Agriculture

    Status: Closed - Implemented

    Comments: FSIS, through its Field Operations Office, conducted three conferences across the nation to address, among other things, inspectors' responsibilities for microbial sampling and the frequency of salmonella testing. In addition, FSIS is revising two Directives -- Enforcement Instructions for the Salmonella Performance Standards and Microbial Sampling of Ready-to-Eat Products by Establishments Operating Under a HACCP System. The revised directives will provide inspection personnel with additional information regarding sampling techniques.

    Recommendation: To ensure the consistent inspection of HACCP programs, the Secretary of Agriculture should direct the Administrator, FSIS, to provide clarification and additional training regarding inspectors' roles, responsibilities, and authorities for reviewing and verifying HACCP plans.

    Agency Affected: Department of Agriculture

    Status: Closed - Implemented

    Comments: FSIS conducted three national conferences to provide further training to inspection personnel on their roles,responsibilities and authorities for reviewing and verifying HACCP plans. Some 195 field officials were in attendance along with 71 employee organization and union officials and 17 heads of the regional inspection programs. FSIS has begun surveying field employees about the clarity and usefulness of directives dealing with these topics and will issue a Notice to the Field providing necessary clarifications on how to verify establishments' compliance with hazard analysis and HACCP Plan requirements.

    Recommendation: To enable USDA to oversee all aspects of food safety at meat and poultry plants, the Secretary of Agriculture should direct the Administrator, FSIS, to review all HACCP plans to verify that plants are identifying and controlling food safety hazards that are reasonably likely to occur through their HACCP programs. This review will ensure USDA appropriately oversees the HACCP system.

    Agency Affected: Department of Agriculture

    Status: Closed - Implemented

    Comments: Between February and June 2000 FSIS conducted three National Supervisory Conferences that focused on verification that HACCP requirements are met. Also, FSIS is conducting Food Safety Systems Correlation Team Activities in each district to address verification activities that ensure that HACCP plans identify and control food safety hazards likely to occur. Since April 2000, FSIS has conducted in-depth verification reviews of the adequacy of over 30 HACCP plans in addressing critical hazards and plans to conduct additional reviews in the future.

    Recommendation: To ensure that FSIS has complete and accurate information for analyzing industry appeals of noncompliance actions under the HACCP system, the Secretary of Agriculture should direct the Administrator, FSIS, to: (1) issue instructions to FSIS' district offices clearly stating that inspectors must provide complete, accurate, timely, and consistent appeals data for the automated appeals tracking system; and (2) periodically review the accuracy and completeness of the data in the appeals tracking system.

    Agency Affected: Department of Agriculture

    Status: Closed - Implemented

    Comments: FSIS agreed with the recommendations and issued a memorandum in April 2000 to all field managers and supervisors emphasizing the importance of accurate, timely, and consistent data. In July 2000, FSIS approved an audit procedure to conduct quarterly audits of the automated appeals database system to verify that the appeals data is accurate and complete.

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