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| Commonly Asked Questions from Small and Very Small Plants on Corrective
Actions (1) |
Q1: Am I required to document SSOP and HACCP corrective actions on the NR, or do
I have to write them on my company record?
A1: The requirement in 9 CFR 416.16 and 417.3(c) is that you document
Sanitation SOP and HACCP corrective actions. The establishment can document these corrective actions
on its records or on the NR. If the documentation is on the NR, the NR becomes part of the HACCP or
Sanitation SOP records and is required to meet the recordkeeping requirements of those regulations.
Q2: If I find a noncompliance and take appropriate
corrective actions, would the inspection program personnel also complete an NR?
A2:
No. If the establishment finds noncompliance and brings itself into compliance with
the regulatory requirements, inspection program personnel should not issue an NR.
Q3: If I write that I will retrain employees as my preventive
measure in response to a NR that was written as a result of my SSOP failing to prevent direct contamination
or adulteration of product, will all NRs with this preventive measure be linked?
A3: A thorough process should be carried out to determine
the cause of each noncompliance. If the establishment determines the cause
of the subsequent sanitation noncompliance is lack of, or insufficient, employee
training, the NRs should be linked as they are issued and discussed with establishment
management at the weekly meetings. These criteria are listed in the answer to
Question 3 of the Commonly Asked Questions from Small and Very Small Plants
Regarding Noncompliance Records (NR) (1) posted at the following link:
https://webarchive.library.unt.edu/eot2008/20081017102542/http://www.fsis.usda.gov/Help/FAQs_TSC_NR/index.asp.
Q4: Do inspection program personnel have
to agree with SSOP corrective actions before removing the retain/rejected tag?
A4: Inspection program personnel have been trained not to remove
the regulatory control action until the establishment proposes corrective actions
that meet the regulatory requirements of 9 CFR 416.15. Inspection program personnel
have also been trained that the same preventive measure proposed on a previous NR may
not be an effective preventive measure, since it was not effective in preventing the
noncompliance from recurring.
Q5: Can I use employee training multiple times on my Sanitation SOP records
as a preventive measure to meet the requirements of 9 CFR 416.15?
A5: The establishment may document employee training multiple times
as a preventive measure on its Sanitation SOP records. If the establishment documents
employee training as a preventive measure, the training should also be documented
when it occurs. However, if after repeated employee training has occurred, inspection
program personnel find the Sanitation SOP failed to prevent direct contamination or
adulteration of product, employee training may not be accepted as an effective
preventive measure by inspection program personnel.
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Last Modified: October 20, 2006 |
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