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An Overview of the HACCP-Based Inspection Models Project
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Introduction
The Food Safety and Inspection Service (FSIS) protects the public
health by ensuring the safety of the meat and poultry supply. As
part of these efforts, FSIS continues to reevaluate and make
improvements to the HACCP-Based Inspection Models Project (HIMP).
The inspection procedures employed in the project appear to improve
food safety and other consumer protections.
Because data collection is only complete in young chicken plants,
this species will be the first considered for a regulatory change.
In order to implement any nationwide changes based on the models
pilot project, a change in the poultry regulations will be required.
FSIS is drafting a proposed rule to make these regulatory changes
.
Background
The Food Safety and Inspection Service (FSIS) is committed to
continually improving the system that safeguards the meat and
poultry supply. An essential first step in achieving that goal
was accomplished with publication in the July 25, 1996 Federal
Register of the final rule on Pathogen Reduction and Hazard
Analysis and Critical Control Point (HACCP) Systems. The rule
required plants to implement science-based process control
systems as a means of preventing food safety hazards, set
certain food safety performance standards, and established
testing programs to ensure that those standards are met.
Inspectors have been assigned new tasks that enable them
to ensure that regulatory performance standards are met.
Under HACCP, plants identify and evaluate the food safety hazards
that could affect the safety of their products and institute controls
necessary to prevent those hazards from occurring or to keep them within acceptable
limits. However, HACCP inspection is not applied to the slaughter process.
HACCP-Based Inspection Models Project
HIMP is an effort to determine how FSIS can improve the use of its
online slaughter inspectors and continue to ensure the reduction
and/or elimination of defects that pass through traditional
inspection.
FSIS has developed three slaughter models – one for young poultry
(including turkeys), one for market hogs, and one for fed cattle
(steers/heifers). These classes of animals were selected because
they tend to be young, healthy, and uniform. The project applies
only to plants that slaughter these healthy, young animals. The
models describe the baseline data collection phase and the steps
in the project through which plants will demonstrate their ability
to match the achievements of the current system.
In the pilot phase, up to 25 plants that slaughter young chickens,
turkeys, and hogs are currently participating in the project,
although all are not yet testing models at this time. The majority
of participating plants are young chicken plants. A complete
listing of participating plants
is available.
Study Design:
The study design for the HIMP pilot was established to measure the
accomplishments of the traditional inspection system and the
accomplishments of the models inspection system. Realizing the
impracticality of using a truly random sample for this pilot
inspection system, FSIS instead opted to use volunteers. Any
plant already operating under HACCP that slaughtered young,
healthy, uniform animals was invited to volunteer for this pilot
project. The volunteer plants participating in the HIMP study are
representative of the industry. These volunteer plants represent
diversity in geography, corporate structure, management styles,
numbers of processing lines, product distribution patterns,
inspection systems in use prior to the pilot, and other
variables.
Under this project, FSIS has established performance standards
for food safety (FS) and non-food safety defects (also known
as "other consumer protections" or OCP) found in young chickens,
hogs, and turkeys. A complete listing of performance
standards is available.
The food safety performance standards are set at zero to protect
consumers from conditions that may be harmful. The OCP performance
standards were developed by evaluating the achievements under the
traditional system. Based on these evaluations, more stringent
criterion, requiring improved plant performance, were developed.
The OCP performance standards have been set at the 75th percentile
of what is achieved under the current, traditional method of
inspection; thus, 25 percent of the plants in each category have
to improve upon their baseline results in order to meet the more
stringent standards. Participating plants must revise their HACCP
systems to meet these food safety performance standards and establish
process control systems to address the OCP concerns.
No food safety or non-food safety defects are acceptable to FSIS.
While no system is perfect, the models project is an effort to
reduce and eliminate defects that pass through traditional inspection.
Under this project, FSIS conducts inspection of each carcass with
increased verification to ensure that performance standards are met.
FSIS inspectors also check for fecal contamination and other
organoleptic food safety defects four times more frequently under
the models project than under the traditional system.
Baseline Phase:
To ensure that the new system performs in a manner equivalent to the
current system, in August 1998, FSIS began collecting microbial and
organoleptic baseline data on the traditional system to provide a
picture of plant performance before the models were tested. FSIS
contracted with Research Triangle Institute (RTI), an independent
consulting firm, for baseline data collection.
Models Phase:
In October 1999, FSIS began the models phase of HIMP. The models
phase consists of two parts – the transition phase and the data
collection phase. Under the transition phase, participating plants
began assuming their new responsibilities, and FSIS began new
inspection procedures. Under the data collection phase, organoleptic
and microbial data are collected to determine the achievements of the
new system. FSIS has also contracted with RTI for data collection
under the models phase. RTI concluded its data collection and
presented it to the National Advisory Committee on Meat and Poultry
Inspection in June 2002.
Inspection Procedures under the Models Project
Under the revised design, FSIS has placed a carcass inspector at a
fixed point. This inspector conducts an examination to make a
critical appraisal on each carcass. FSIS continues to have an
off-line verification inspector to ensure that plant personnel
are appropriately handling any defects and to ensure that the
overall design and execution of all of the establishment’s
HACCP and process control procedures are meeting the performance
standards.
Public Process
HIMP is being developed through an open public process that allows
all interested constituents – including FSIS inspectors and
veterinarians, industry, and the general public – the opportunity
to participate and provide input through public meetings and other
means. FSIS has consulted closely with the National Advisory
Committee on Meat and Poultry Inspection; the National Advisory
Committee on Microbiological Criteria for Foods; numerous public
health, industry, and consumer groups; and FSIS employee and
supervisory groups, among others.
HIMP is still in a pilot phase and FSIS continues to evaluate and
make improvements to the project. Regulatory changes will only be
made when full sets of data have been collected and evaluated, and
the data provide a reason for change. Notice and comment rulemaking
for each species, with opportunity for open public comment, will be
conducted before any changes are made. Young chickens are expected
to be the first for which this new inspection program is proposed.
Future Initiatives
FSIS will seek an independent, third party review of the RTI data
that was presented at the June 2002 meeting.
This year, USDA will propose regulations in the Federal Register for
plants that slaughter young chickens.
It is the intent that proposals for young turkeys and hogs will
follow. The proposal for young chickens will include the following
improvements:
- Mandating formalized training for plant personnel that participate in HIMP.
- Increasing participation in the HIMP program by allowing plants to volunteer for the project.
Participants would be required to adhere to specific criteria set by FSIS.
FSIS employees have provided valuable comments and suggestions during
the course of the pilot program, particularly inspectors working in
HIMP plants. In addition, USDA will continue to seek input from all
interested parties – including public health, industry, and consumer
groups as well as the general public – to strengthen the program.
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