Sanitation Standard Operating Procedures (SSoP) Reference Guide
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Table of contents Table of Contents NOTE: The blocks" listed below and illustrated in the flow diagram on Block 15 FSiS continues official control action the preceding pag Each block discussion ad FSIS inspector at tha ocess. When applicable, sections Block 16 lIC contacts Area office in cases of from the regulatory quoted and/or other regulatory Block 17 lC and Co review plant situation Block 1 Start Block 2 Plant develops Sanitation SOP Block 19 llC provides documentation to IMP Block 3 tion soP does not meet regulatory Block 20 IMP and FOD prepare and provide Block 4 Plant complies NOTE: The following appendices are provided as additional Block 5 FSIS removes suspension Block 6 FSIS per Guidelines for Developing a SOP spendⅸA Block 7 Fsis determines if deficiencies exist Model of a soP for Sanitation Appendix B Block 8 FSIS classifies deficiencies using the Block 9 FSiS cial control action Selection and Verification of Establishment Appendix E Block 10 Plant defines and implements peace Appendix F Block 11 Fsis determines if plant actions Block 12 FSIS advises plant of consequences failure to implement effective Block 13 FSiS determines if there are repeated ted failures Block 14 FSiS removes official control action if failure is not 36
BLOCK 1-Start BLOCK 1. Start daily basis in individual establishments, but at a relatively large public PREAMBLE ost because it encouraged establishments to shift accountability for Plant Responsibilities inspectors have taken responsibility for slaughter establishment before it begins daily processing. In extreme The proposed requirements for Sanitation SOPs were the result of cases, inspectors have led daily bucket brigades"of slaughter many years of observations by FSIS of establishment sanitation and leanup. In these circumstances, FSIs has, in effect, taken me meat and poultry establishments was documented in the"1,000 sponsibility for establishment sanitation conditions Plant Review, "conducted by FSIS between September 1993 and Although ority of meat and poultry adequate sanitary conditions, some establishments have deficiencies noted. More than 60 percent of all deficiencies documented sanitation problems that can be resolved only through more clearl by the review involved establishment sanitation. The distribution of ning establishment wever. uniform in ibility and accountability for the daily percent of the sanitation deficiencies. Data collected through FSIS's clear that responsibility for identifying and conducting procedures needed to maintain sanitary conditions rests with the establishment, not Based Inspection System similarty documents that on is the most frequent deficiency noted by inspection personnel Finally, the Sanitation SOPs requirements of this final rule are set out Through analysis of this information, Fsis determined that the hese provisions are formatted differe Ifference between establishments with consistently sanitary conditions and those with chronic sanitation deficiencies is often that the better organize, and recodify the meat and poultry regulations. This performing establishments have effective qua lity control and sanitation regulatory reform project is well underway, and will, among other things programs, including written Sanitation SOP's, while the marginal eliminate unneeded regulations by combining, to the extent possible, the currently separate meat and poultry regulation ors Substantial evidence exists that insanitary facilities or equipment, poor improper personal hygiene, and similar insanitary contaminated with microorganisms, including pathogens. While commenters expressed concem that during inspection inspectors would some indiidual establishments still have difficulty getting their facilities soiety on record reviews instead of actually observing establishment and equipment ready to start operations each day and keeping conditions. Other commenters expressed concerns that Sanitation SOPs would merely provide FSIS s with more latitude to make nditions sanitary during establishment operations. FSIS affirms that intrusive and arbitrary decisions. FSIS strongly disagrees with this and a fundamental requirement of the inspection laws that the Agency inspection personnel, Industrys responsibility for producing safe meat and poultry and FSis responsibility for regulatory oversight are st, FSIS has enforced the sanitation requirements primar through a combination of prescriptive sanitation regulations, detailed Santation SOPs are the establishment s commitment to fsis that the guidance materials, and direct, hands-on involvement by inspectors in nsistently provide a sanitary FSIS inspectors will not be tasked with directing an establishment's day-to-day pre-operational and operational sanitation procedures in sanitation procedures, inspected establishments. This system achieved sanitation goals on a Sanitation SOPs. They will, however, verify that the Sanitation SOP's
BLOCK sTart BLOCK1· Start hat a rejected item, compartment or room is not related to other re being implemented and that they are effective in preventing direct withheld in rooms, depar produced. However, inspection would be processes or products production of contaminated or adulterated products where the Oversight of Sanitation SOP's will become an increasingly important establishment can not show FSIS that they have isolated the cause of the contamination or adulteration and have taken appropriate action to will occur less frequenty Periodic inspection tasks will include verifying event further co similar ve that Sanitation SOP's meet the regulation's requirements, are being he occurence of a sanitation problem that is effectively abated. These conditions. FSIS inspectors oversight will include review of the Sanitation SOPs and required records, direct observation of the if an establishment fails to identify and correct insanitary condtions. If ementation and monitoring of the Sanitation SOPs, and visual the establishment takes proper corrective action, they argued, t should observation of sanitary conditions in the production areas of the ewed as evidence that the Sanitation SOP's is being adequatel ented. FSIS agrees. Establishments that identify and correct sanitary conditions in a timely manner and make proper disposition of SIS expects that establishments will rely less on inspectors to direct any affected product will be considered to be in compliance with the them in maintaining sanitary conditions as establishments rely more on adherence to their own Sanitation SOPs, The max of inspector tasks that comprise sanitation inspection also will change. As establishments Although FSIS fully expects that the clarification of establishme adopt and successfully implement Sanitation SOPs, and consistently animation responsibilities will lead to better and more consistent suning that basic sanitation requirements are being met. Conversely. comply with the requirements in this final rule for Sanitation SOPs will SOPs and consistently achieve good sanitation, FSIs inspectors will be subject to appropriate compliance and regulatory action that be obliged to intensify ther focus on actual establishment conditions and when necessary, include suspension or withdrawal of inspection itiate appropriate enforcement actions. Ensuring establishments Further, as noted in the proposal, anyone who intentionally falsifies berate under sanitary conditions should be made easier for ins well as establishments, focus their attention on those aspects of ACTIONS establishment sanitation that pose the most risk of causing product BLOCK 1 latively low probability of is sanita Preparation is essential for success. Before performing any task for thereby consistenty preventing, or as appropriate, correcting, conditions at cause direct product contamination or adulteration. Some egulatory enforcement of Sanitation SOPs, FSIS inspection personnel will be ommenters were concerned about the effect on orcing the Sanitation SOPs requirements, reject one piece of equipment, utensiL, room or know the regulatory requirements for Sanitation SOPs impartment as insanitary. As previously stated, inspectors will take prompt action in cases where there is a finding of insanitation or have the equipment, supplies, and references needed to perform and document inspection findings and likelihood of product contamination or adulteration. The type and intensity of this response will vary. For example, establishme have access to pertinent plant records or documentation