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| IKE Scenario 07-07: FSIS Directive 12, 600.2 – Determining
When Inspection Coverage Is Required and Overtime Is Charged
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Purpose: This IKE is issued in support of FSIS Directive 12,600.2
and provides one example of when inspection coverage is required, and inspection personnel are to charge the
establishment for their overtime service.
Situation: You are a relief GS-8 inspector
assigned to a small hog slaughter establishment that also
performs simple processing and smoked pork processing. Both
your tour of duty and the establishment’s approved work
schedule are 0700 hours to 1530 hours, Monday through
Friday. The establishment’s practice is to begin its
operations promptly at 0700. Slaughter operations are
coordinated so that the last hog carcass of the production
day leaves the evisceration department and enters the
carcass cooler by 1530 hours. Carcass breaking/ cutting and
packaging/ labeling activities are completed at 1630 hours.
In the processing department, the smoke house is fully
loaded by 0800 hours, and the product remains in the
smokehouse until 1400 hours. At that time, the product is
transferred to the cooler where it is held until 1700 hours
to stabilize.
Discussion: Based on the PBIS procedures
scheduled for today’s operations, you will perform the 01B02
(pre-operational sanitation) procedure. You have determined
that you will perform the Review and Observation component
of that procedure and will conduct a pre-operational
inspection of the slaughter facility beginning at 0630 hours
since the establishment chooses to start its slaughter
operation promptly at 0700. You will charge for the time
that you spend conducting the pre-operational inspection as
it will occur before the start of your tour of duty.
This establishment’s HACCP plan contains a Critical Control
Point (CCP) for smoked pork stabilization temperatures.
According to the written monitoring procedure,
cooling/stabilization temperatures of product on racks
transferred from the smoke house into a cooler will be
monitored using a hand held thermometer. The HACCP plan also
states that an ongoing verification procedure is performed
once per week, involving direct observation of the employee
performing the final smoked product stabilization
temperature check. The plant manager has informed you that
this weekly direct observation activity will occur today at
1700 hours.
As a critical thinker, you consider whether inspection
coverage is required, and whether you should charge overtime
for the times when: 1) the establishment finishes carcass
breaking and packing/ labeling activities, and 2) when the
establishment performs a direct observation verification
activity at the end of that specific day.
Resolution: You review FSIS Directive
12,600.2, Section VII, and note that all of the
establishment’s pack-out activities will require inspection
coverage because the establishment will be labeling product.
In addition, coverage is required in order for you
to verify the establishment’s CCP direct observation
verification activity. Therefore, for today’s operations,
you are to charge overtime to the establishment for the
pre-operational inspection as well as the production and
HACCP activities that occur after the end of your tour of
duty. You are to charge the reimbursable overtime to the
establishment in accordance with the guidance provided in
the attachments to FSIS Directive 12,600.1, Revision 1,
Amendment 1, dated 1/08/07. |
Last Modified: December 13, 2007 |
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