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FSIS Workforce: Introduction of the Consumer Safety Officer
The Food Safety and Inspection Service has introduced the Consumer Safety Officer (CSO) occupational series into its workforce. The CSO series reflects the Agency's increasing reliance on science and technology and the continuing need for employees with this knowledge in the inspection environment. The CSO occupation is a valuable and essential addition to the Agency's front line team of food inspectors, consumer safety inspectors, and veterinary medical officers.

Background
The mission of the Food Safety and Inspection Service (FSIS) is to ensure that meat, poultry and egg products are safe, wholesome, and correctly labeled and packaged. Prior to 1996, the method of inspection relied largely on organoleptic (sensory) methods, which were appropriate when the first meat inspection law was passed in 1906.

Despite the success of the traditional food inspection system in eliminating diseased animals, there was a critical gap in its ability to protect public health. Studies by FSIS, the National Academy of Sciences and the General Accounting Office consistently recommended that the Agency shift to a prevention-oriented inspection system based on risk assessment, and re-deploy its resources to better protect the public from foodborne disease.

In July 1996 USDA announced the Pathogen Reduction/Hazard Analysis and Critical Control Point (PR/HACCP) rule. This rule modernized the 90-year-old inspection system and resulted in a sweeping reform of federal food safety rules for meat and poultry.

HACCP is a science-based prevention oriented food safety system that requires meat and poultry slaughter and processing establishments to target and reduce harmful bacteria on their products. Establishments must implement Sanitation Standard Operating Procedures (SSOP) and HACCP plans, meet pathogen reduction performance standards for Salmonella, and verify process control through generic E. coli testing.

The PR/HACCP rule represented a change in regulatory philosophy, changing the focus, tasks, and priorities of FSIS employees &150; particularly front line employees and supervisors.

Evolving Workforce
The food inspector and veterinary medical officer have served as the primary regulatory presence in meat and poultry establishments since 1906. As PR/HACCP implementation began, these two occupations continued to be the Agency's main front line regulatory presence.

In 1999, following HACCP implementation in large and small meat and poultry establishments, the Agency began converting off-line food inspector positions in HACCP establishments to Consumer Safety Inspector (CSI) positions, to reflect the strengthened regulatory enforcement role of inspection program personnel. The role of the CSI is to ensure that establishments execute their food safety systems in accordance with PR/HACCP requirements.

Food inspectors and consumer safety inspectors, however, are not required to make scientific assessments under PR/HACCP. Studies by the National Academy of Sciences, the General Accounting Office, and FSIS established the need for fundamental change in the inspection program to improve its public health effectiveness. Among the changes identified in the studies was the need to redeploy Agency resources in a manner that better protects the public from foodborne disease. Therefore, to further ensure the safety of public health in the PR/HACCP environment, FSIS needs front line employees with a scientific background, able to assess and verify the design of food safety systems.

The Agency identified the Consumer Safety Officer (CSO) occupational series as the position to fill this need. CSOs must have at least 30 semester hours of related science course work, and those without a bachelor's degree must have one year of specialized experience. The educational background and job experience requirements provide a basis for making scientific assessments of processes and systems.

The CSO series reflects the Agency's increasing reliance on science and technology and the continuing need for employees with this knowledge in the plant environment.

Introduction of the CSO Occupation
In May 1999, FSIS introduced the CSO as a scientific generalist position that would be utilized in various capacities across the front line workforce and throughout the organization. The Agency reclassified the professional processing inspection coordinator (PIC) in each of its 17 district offices from occupational series GS-1382, food technologist, to occupational series GS-0696, consumer safety officer.

In October 2001, 35 Consumer Safety Officers were added to the FSIS workforce -- three in the Albany district and two in each of the remaining districts. The CSO positions were filled from the Agency's existing workforce.

FSIS plans to establish 50 additional CSO positions during FY 2002, and gradually increase the number of CSOs in its workforce over the next few years. CSO positions will be filled through competitive selection from current inspectors with the requisite qualifications and through external recruitment as attrition permits.

All candidates selected for CSO positions must complete a rigorous four-week education program, which includes scientific and regulatory information in areas such as food microbiology, statistics, analyzing scientific and investigative information, and pathogen reduction and HACCP regulations.

Duties of the CSO
The CSO series gives the Agency more flexibility in assigning its workforce in areas where there is a greater demand for scientific knowledge and judgment. CSOs are part of the District Office staff and report to the Assistant District Manager for Enforcement (ADME), although the supervisory chain may be adjusted as more CSOs and other positions are added. CSOs work in plants, but do not have a fixed plant assignment, or geographic area.

CSO duties include, but are not limited to, the following major areas:
  • Assist with activities associated with the Small Business Regulatory Enforcement Fairness Act (SBREFA), which supports in-plant safety inspection activities and helps small and very small establishments.
  • Assess and verify the design of HACCP plans, SSOPs, and E. coli monitoring plans.
  • Participate in in-depth verification reviews, investigations, and other Agency reviews to assess the effectiveness of establishment food safety control systems.
  • Define strategies to verify corrective actions implemented by establishments.
  • Conduct data analysis and trend assessment of Agency information and regulatory data.

During a plant visit, if there are scientific questions concerning the design of the food safety systems, the CSO will issue a 30-day reassessment letter. If non-compliance is found during the CSO's assessment and verification of the design of an establishment's food safety system, some type of enforcement action will be taken in cooperation with the District Office. This action could be either a Notification of Intended Enforcement Action (NOIE) or suspension. In those cases where an enforcement action is taken, a letter of deferral, with a specified time frame, can be issued to the establishment once they have defined how they will come back into regulatory compliance. In all cases, the CSO will assist the establishment in finding the technical resources necessary to achieve compliance, and develop an action plan to be used by in-plant inspection personnel to verify establishment compliance.

The CSO is a valuable and essential addition to the Agency's front line team of food inspectors, consumer safety inspectors, veterinary medical officers, and compliance officers. The CSO significantly enhances the Agency's workforce. FSIS will continually monitor the effectiveness of its front line team and make adjustments as needed.

May 2002

 

 

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