AMI Comments on FSIS Compliance Guideline HACCP System Validation, Offers Implementation Recommendations

(American Meat Institute)

AMI submitted comments today on the Food Safety and Inspection Service’s (FSIS) Compliance Guideline HACCP Systems Validation, stating that it has been significantly improved and will provide tools to support establishments in completing and meeting validation requirements.  AMI comments offered several recommendations for implementation to help achieve a seamless transition, including determining how non-critical control points should be validated.

The comments state, “Whether to validate CCPs [Critical Control Points], prerequisite programs, or both is a decision that could impact the effectiveness of food safety programs. It may also have an economic impact on the cost of inspection personnel reviewing documents and programs that do not impact food safety.  Establishments could have prerequisite programs to address environmental issues such as pest control, employee hygiene and sanitation practices, among others. Programs of this nature should not be subject to validation requirements.  However, in the absence of a CCP, prerequisite programs referenced in the process flow chart should be validated.”

AMI also recommended that the self-assessment contained in the Guideline be used to confirm whether the establishment’s HACCP program is validated, as well as additional self-assessment questions that could be added to the Guideline to aid in the review of validation program.  The comments also offered recommendations for updating the validation worksheet examples.

The comments are available here: http://www.meatami.com/ht/a/GetDocumentAction/i/80162

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