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| Commonly Asked Questions from Small and Very Small Plants on Sanitation
Standard Operating Procedures (2) |
Q1: If the SSOP monitoring frequency is daily, and a plant does not
operate on a particular day, is it recordkeeping noncompliance if records are not generated for
that day?
A1: No. 9 CFR 416.16(a) requires that an establishment have daily records to document the
implementation and monitoring of its Sanitation SOP. However, 9 CFR 416.12(a) states that the SOPs
are to describe “…all procedures that an official establishment will conduct daily, before and
during operations….” Thus, there is no documentation requirement for days or times when it is not
operating.
Q2: Is an icehouse considered a food contact surface that must be addressed in
the SSOP?
A2:
A food contact surface is any surface that may come in direct contact with exposed product.
Examples of food contact surfaces include conveyor belts, table tops, saw blades, augers, and
stuffers. If the interior surfaces of an ice house do not directly contact product, the
establishment would not be required to address them in the SSOP. Regardless, FSIS verifies SPS
regulatory compliance. FSIS expects the establishment will prevent the creation of insanitary
conditions within the icehouse that could result in product contamination with filth or that may
render the product injurious to health.
Q3: Must an establishment document that it has re-evaluated and
maintained its SSOP in accordance with 9 CFR 416.14?
A3: No, there is no regulatory requirement that establishments document the
re-evaluation of the effectiveness of the SSOP. However, the establishment is required to revise
the SSOP and the procedures therein as necessary to keep them effective and current.
Q4: Can “as needed” be used as a frequency for an SSOP procedure?
A4: Under 9 CFR 416.12(d), establishments are to specify the frequency with which
each procedure in the SSOP is to be conducted. Therefore, establishments need to select a minimum
frequency (e.g., daily, every 4 hours), in conjunction with “as needed.” For example, the SSOP may
state, “on an as needed basis, but no less than once every three days.” The CSI will verify that
the establishment maintains sanitary conditions. The Agency will not question the frequency that
the establishment specifies unless there is evidence that the frequency is not sufficient to
prevent the creation of insanitary conditions.
Q5: If a plant includes wall surfaces in its SSOP, does SSOP
noncompliance exist if product is found by FSIS inspection program personnel on the walls when
performing 01B02, preoperational sanitation?
A5: The CSI needs to consider whether the establishment’s failure to implement
its SSOP for cleaning the wall resulted in an insanitary condition whereby product may become
contaminated or may be rendered injurious to health. If so, then 01B02/SSOP noncompliance exists,
under 9 CFR 416.13(a) and (b).
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Last Modified: May 22, 2008 |
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