More on validation of CCP’s and prerequisite programs

This article below appeared in the Meatingplace.com blogs a few days ago.  It addresses various concerns and questions about validation of CCP’s and prerequisite programs and provides a different viewpoint than the previous post about this topic.

We’ve learned today that the comment period has been expanded for 2 additional months.

Safety Zone
By: James Marsden

Validation of CCP’s and prerequisite programs

(The views and opinions expressed in this blog are strictly those of the author.)
In a recent letter to nine meat industry organizations, FSIS Administrator Al Almanza explained the position of USDA on the issue of validation of HACCP critical control points and prerequisite programs. He explained that the agency wants supporting documentation to demonstrate that food safety systems have been properly implemented and are working as intended.

Originally it was thought that the validation requirements would be limited to HACCP critical control points. However, Mr. Almanza explained that prerequisite programs will also be included because “Increasingly, establishments use prerequisite programs as part of their HACCP, particularly as support for why the establishment considers a food safety hazard to be not reasonably likely to occur.”

USDA’s initiative to require widespread validation has caused a stir in the industry and concern about how small processors can meet these new requirements.

Here are my thoughts on the subject:

1.       USDA has a right to expect that CCP’s and prerequisite programs are both scientifically valid and effective at controlling hazards at the plant level. USDA also has to be careful not to punish companies that try to do the right thing by investing in interventions to improve food safety. Too much bureaucratic oversight will discourage food safety improvements.

2.       The most efficient way to provide scientific validation is to conduct challenge studies by product and process category and then make that information available to all processors. These studies could be funded by industry groups or possibly by USDA.

3.       In plant validation would then consist of:

a.       Verifying that the parameters validated in scientific studies are being replicated at the plant.

b.       Conducting simple in-plant studies to document reductions in microbiological populations associated with the identified CCP or prerequisite program. This can be done using total aerobic plate count or indicator organisms. It would require a “validation report” that could be generated by plant personnel or an outside HACCP advisor.

c.       Plants could use on-going microbiological test results to support the effectiveness of CCP’s and prerequisite programs. This would require that data be collected, analyzed and put into a report form that could be accessed by FSIS inspectors.

It is becoming increasingly clear that running a food safety system in a federally inspected plant is a complex business. Most plants will require outside assistance in order to meet the new FSIS validation requirements and other regulatory programs. That support can come from a variety of places, including trade associations, universities, private companies and even FSIS.

While it may appear on the surface that small plants are at a disadvantage, there is a silver lining to this initiative. The validation requirements will probably result in microbiologically cleaner meat and poultry carcasses that are less likely to be contaminated with E. coli O157:H7 and other pathogens. This will make it easier for small processors to meet regulatory requirements and lower their risk of being involved in foodborne disease cases and outbreaks and resulting recalls.

USDA has the mission to assure that meat and poultry products are safe for consumers. That mission applies to all meat and poultry products whether they are produced by the largest company or the smallest company. All food companies must produce safe products.

Not only is this a regulatory requirement, but retailers and consumers expect nothing less.

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