Until a few years ago, there were still a number of federal meat establishments that had not yet experienced a comprehensive Food Safety Assessment (FSA). Today, the numbers are dwindling as the Food Safety Inspection Service (FSIS) is now far more aggressive in performing both “routine” and “for cause” FSAs.
FSIS uses the FSA process, which typically lasts a few weeks, to determine whether a meat harvest or processing establishment is meeting basic federal food-safety requirements. During this process, numerous FSIS officers will inspect, observe and also scrutinize almost every aspect of a facility’s food-safety programs, record-keeping systems and overall operations.
An FSA can be triggered for many reasons. Most FSAs performed by the agency are routine. Although FSIS maintains a daily presence in meat establishments, the agency nevertheless will periodically perform FSAs to more carefully and systematically review operations. A routine FSA is generally triggered because the establishment was selected randomly by FSIS.
The second type of FSA is generally referred to as a “for cause” FSA. FSIS will typically perform this type of FSA: (1) if a facility is having trouble controlling pathogenic bacteria in its products; (2) if the establishment appears more often than others as the supplier of raw trim used to process positive ground beef samples; or (3) if the company’s products have been epidemiologically (or microbiologically) associated with an emerging outbreak.
Regardless of the type of FSA being performed, the consequences for the company can be the significant. If FSIS determines that there is a problem or observes something it does not like, FSIS will in many cases issues an Notice of Intended Enforcement (NOIE) threatening to shut the company down. Although FSIS may hold the threatened suspension “in abeyance,” it will not lift the NOIE until any problems have been remedied to the satisfaction of agency.
Because an FSA that goes poorly can have a significant impact on the operations of your company, you should prepare now for your next FSA before it happens. You should prepare an FSA response plan, and train your management and employees about what to expect during the FSA process. This will help make sure that everyone in your organization understands the FSA protocols, appreciates the reasons why the FSA is being conducted, appropriately manages the expectations of the FSIS officers when they arrive, and prepares for the types of questions USDA will ask and the areas upon which it will focus on most. You should also make sure you understand what the law permits FSIS to request and the scope of your own rights as well.
Whether it happens next week or next year, FSIS will be knocking on your door to perform its next FSA. Start managing your internal expectations today so that you can better manage the agency’s expectations tomorrow.
