The Food Safety and Inspection Service (FSIS) has issued a directive that provides instructions to personnel conducting meat and poultry inspections regarding how to perform the Hazard Analysis Verification (HAV) required under section 417.4 of USDA regulations. 9 C.F.R. 417.4(a)(2). FSIS will initially implement the directive with regard to establishments producing comminuted poultry products, citing the “recent illness outbreaks related to Salmonella contamination in raw ground turkey products” as evidence of the need to prioritize thorough and effective HAV procedures in those facilities as a starting point. Implementation at 30 establishments producing comminuted poultry products will begin in October and FSIS will subsequently assess the effectiveness of the procedures in order to determine whether any changes to the directive should be made.
While the directive does not legally alter any rights or obligations of meat and poultry establishments, it may in practice impact whether their food safety systems pass inspection by FSIS personnel because the directive instructs personnel to engage in a specifically defined, nine-step process to conduct a HAV. Under USDA regulations implementing the Federal Meat Inspection Act (FMIA) and the Poultry Products Inspection Act (PPIA), establishments producing meat and poultry products must develop and maintain Hazard Analysis and Critical Control Point (HAACP) plans and Sanitation Standard Operating Procedures (SOP) to ensure that establishments protect against foodborne illness.
According to the directive, routine HAV inspection tasks will be generated by the Public Health Information System (PHIS) on a quarterly basis for establishments that demonstrate good process control. In other cases, PHIS may schedule additional “directed” HAV tasks to verify compliance with regulatory requirements if, for example, an establishment has a history of noncompliance determinations.
The nine-step process – which is set out succinctly in a table and flow chart in Attachments 1 and 2 in the directive – is designed to verify that an establishment has effectively developed a HAACP plan, including by determining whether an establishment has reasonably assessed which hazards may or may not occur in their specific food safety system. The directive confirms that the prevention of foodborne illness remains a top priority for FSIS and that new procedures and policies may be considered even without new legislative authority.