HACCP AND MEAT AND POULTRY INSPECTION



experimentation with new models for in-plant slaughter inspection. These
models will provide the same level of protection, but allow some inspection
resources to be reallocated to food safety tasks off-line in slaughter plants,
to new food safety tasks in processing plants, and during the distribution of
meat and poultry products once they leave the plant.

The HACCP-based Inspection Models Project will describe for slaughter and
slaughter processing plants that have implemented HACCP, what alternative
inspection models FSIS could use that would enhance food safety
accountability and maintain the other consumer protection accomplishments
of the present system. Today, plants must develop HACCP systems around
our ante and post mortem inspection stations. Plants participating in this
project will be able to develop HACCP through all aspects of the production
system, including those presently constrained by our inspection activities.
In other words, we would still perform carcass-by-carcass examinations, but
how we do the examinations may differ.

Second, we are interested in systematically focusing on conditions and
practices during distribution that may contribute to the growth of pathogens.
"In-distribution" aspects of food safety include transportation, out-of-plant
locations, storage, commercial kitchens, retail stores, restaurants, hotels, and
other institutions. These are vital links in the farm-to-table food safety
continuum. With regard to transportation and storage of meat and poultry
products after they leave the FSIS inspected plant, we believe the federal
government has a responsibility to set standards regarding such inspection
matters, and we have been working with FDA on this issue.

Regulatory requirements for in-distribution food safety may focus on
meeting time and temperature requirements. These, combined with in-plant
regulatory requirements for zero fecal contamination, form the foundation of
a system that produces safe and wholesome food. We are currently
examining the relationship between in-plant and in-distribution regulatory
requirements and enforcement locations, to see how we can most efficiently
and effectively redeploy our resources from areas of other consumer
protection, to focus on food safety, ensure standards are met, and to assure
that the public gets the maximum return from its investment in food safety.

Third, we are concerned that small and very small companies that are
scheduled to implement HACCP in 1999 and 2000 have the necessary
technical guidance to help them prepare for implementation. As part of our
Small Plant Demonstration Project, we have recently announced the
availability of thirteen generic HACCP models to serve as guides in
developing plant-specific

HACCP plans at the lowest possible cost. These models are roadmaps for
developing HACCP plans.

In addition, we're in the process of revising two publications: "Guidebook for



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