try products in sanitary conditions. CSIs inspect companies and observe how they maintain general sanitation as mandated in the SPS. They inspect equipment, facili- ties, and building structures, and observe employee hygiene practices. They inspect the inside and outside of the company building for evidence and harborage of pests and to review that condemned and inedible materials are properly identified as such and segregated so that they do not contaminate products that have passed inspection for human consumption (Sanitation, 2023b). CSIs review company files to check that there are letters of guarantee from the sup- pliers of packaging and food ingredients, such as spices, stating that there is no prod- uct adulteration. Hazard Analysis Critical Control Point Procedures Federally inspected meat and poultry produc- ing companies are required to have a written HACCP system in place. In this system, each processing step undergoes an analysis for hazards (e.g., biological, chemical, physical). The HAACP system also includes preven- tive measures that will eliminate or reduce those hazards to acceptable levels. A justifica- tion must be provided for why or why not a potential hazard is reasonably likely to occur at each step. If a potential hazard is reason- ably likely to be discovered at a specific pro- cess step, the hazard must be controlled at a point called the critical control point (CCP), which can be either at that step or in a sub- sequent step in the process (Hazard Analysis and Critical Control Point [HACCP] Systems, 2023). For instance, E. coli O157:H7 is intro- duced in raw beef products at the receiving step but is controlled at a subsequent step, such as cooking. CCPs must include the following (Hazard Analysis and Critical Control Point [HACCP] Systems, 2023): • List of hazards to be controlled at each step. • The critical limits, which are the minimum or maximum values used to control the hazards (e.g., time and temperature, pH, water activity). • A procedure and an eective frequency for monitoring the CCPs. •Corrective actions and preventive mea- sures to ensure that adulterated product is not shipped.
• Ongoing verification that includes calibra- tion of measuring instruments, verification of the monitoring by direct observation, and records review. •The recordkeeping system that results from this monitoring and verification. The CCPs must be supported by academic science, in-plant testing, and sound reason- ing. FSIS regulations and FSIS publications can also be used to support decisions made in the hazard analysis and HACCP plan (Hazard Analysis and Critical Control Point [HACCP] Systems, 2023). During the first 90 days of implementing a HACCP plan, a company is required to per- form initial validations to show scientifically that the HACCP plan is working as intended. Once the initial validations are completed, the company generates records clearly docu- menting the activities as written in the HAC- CP plan; these records are to be authenticated by initials or signatures. The ongoing records serve as documents proving that a company’s activities result in safe food production. A preshipment review is conducted daily for all records generated. The company then routinely evaluates and validates the HACCP plan to ensure food safety. CSIs observe company employees to deter- mine if they are following what is written in the company’s HACCP plan and are perform- ing their duties in accordance with the regu- lations. Examples of how this determination can be accomplished are by checking ambient and product temperatures, checking continu- ous monitoring cook charts, and comparing results found by the CSI to results generated by the company. When CSIs observe a non- compliance, they document it in noncompli- ance records. Mostly, the hazards identified are patho- gens specific to the species of meat or poul- try produced. At times, FSIS will find data regarding pathogens in the Public Health Inspection System, which prompt FSIS to re- quire a special eort by the companies. FSIS will then develop a directive or a notice stat- ing what additional eorts are to be conduct- ed by a company in their HACCP plan, which FSIS will then monitor. An example is bovine spongiform encepha- lopathy (BSE), commonly known as mad cow disease. When the first case in a bovine ap- peared in the U.S., slaughter companies were directed to segregate cattle ≥30 months from
younger cattle. Now all nonambulatory bovine livestock found in the pens are condemned and no longer can be slaughtered for food. Companies that produce beef are required to have procedures in place after slaughter to remove and properly dispose of specific neu- ral tissues in older bovine carcasses where BSE accumulates. These neural tissues are called “specified risk materials.” Slaughter plants are required to provide guarantee let- ters to fabrication companies that state they have performed these BSE requirements. These procedures are to be included in the HACCP or SSOP plans (Specified Risk Mate- rials From Cattle, 2023). Where FSIS requires extra eorts to address specific hazards, CSIs (while inspecting) and enforcement investigation and analysis of- ficers (while assessing the companies that process these products) are to ensure that companies have written control measures designed and executed to eectively address these hazards in accordance with the regula- tions and supporting documentation. FSIS inspects product samples after slaughter processing and during fabrication process- ing. Some products require inspection using statistically based procedures and criteria for acceptance or rejection before further pro- cessing. These reinspections are conducted daily to determine a company’s ability to pro- duce wholesome products with an acceptable limit of defects. Inspectors need a flashlight, a ruler to measure some defects (because deeper or larger defects have more weight or a higher numerical value compared with smaller ones), and a worksheet that lists and tabulates the defects with their weighted val- ues (Reinspection, Retention, and Disposal of Meat, 2023). Statistically Based Product Reinspection Programs
Finished Product Standards for Raw Poultry
For poultry slaughter facilities that request reinspection to increase line speed and pro- duction, there are two o-line inspection sta- tions where CSIs conduct reinspection of the poultry carcasses that have been inspected on the line. One station is the prechill and is located prior to the chilling systems of the facility. The other station is the postchill located after the chilling systems and prior to
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July/August 2023 • <B?;.9 <3 ;C6?<;:2;A.9 2.9A5
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