Food Safety and Inspection Followup on the 2007 and 2008 Audit Initiatives

Assess whether the new FSA review process, in Directive 5100.4, requires that (1) all establishments are considered for the selection process for a PHRE risk assessment, and (2) a timeframe is included for completing a food safety assessment after an establishment is determined to be at high-risk.

Implement a process that requires FSIS inspectors to receive annual recertification on humane handling requirements. This process should require specific ongoing training to all staff including front line supervisors on current and new program requirements and the applicable directives, including examples of how to apply those requirements at the district and establishment levels. This recertification training should also include guidance on issuing the various disciplinary tools (e.g., noncompliance records and notice of intended enforcement (NOIE)).

Require district offices to enhance their controls to ensure front-line supervisors routinely assess each employee’s knowledge and practical application of program requirements during the performance of their duties as it relates to humane handling. These controls should provide for
the retraining of those employees who do not demonstrate minimal knowledge, skills, and abilities

Issue immediate appropriate communication to FSIS personnel to emphasize the importance of and requirements for issuing noncompliance records and linking those noncompliance records, if applicable, when regulatory violations occur. In addition, develop and implement specific policy that provides examples detailing when noncompliance records should be written for noncompliance with food safety requirements.

Issue guidance to clarify that FSIS inspectors are to remove contaminated product in accordance with the principles of HACCP for product that is allowed to pass the critical control point, or the inspector observes adulteration and the establishment has failed to observe it or act on it