When asked to visit an establishment to assess compliance, my first step is always to ask for data. Establishment food safety data, laboratory results, regulatory data, audits…. What story is being told? Is there a trend in the making? Upward trend? Downward trend?
It is important for establishments that are regulated by the Food Safety and Inspection Service (FSIS) to recognize that the Public Health Information System (PHIS) provides a tool for the Inspection Personnel to understand what (using data) is happening on a day to day basis at our facilities:
- Lab data
- HACCP compliance/non compliance
- Sanitation compliance/non compliance.
In the past, FSIS relied on managers to generate “alerts” or flag data trends in the PHIS. However, there is now enough data in PHIS that the system will “send” alerts to inspection program personnel when the data suggest a trend is developing at an establishment that warrants further review.
For example, the Agency focuses on data related to public health NRs for HACCP and sanitation non-compliances. The Agency has indicated that for 2015, the “cut point” for public health NRs in processing establishments will be 6.55% and in combination (or pure slaughter) establishments, it will be 9.37%. Establishments that experience higher noncompliance rates than these can expect that the inspection personnel will receive “alerts” within PHIS indicating the need for additional verification.
FSIS also is using the PHIS data to schedule Food Safety Assessments and Hazard Analysis Verification tasks.
As FSIS supervisors are “looking into the system” and gaining a better understanding of what is happening at establishments based on our data, are we doing the same?
- Are we reviewing our own data?
- Do we track trends and take actions based on the findings?
- Have we signed up for PHIS-industry access?
- A report for public health NRs will be available beginning November 16th.
- Do we know where we are relative to the FSIS “cut points” for public health NRs?
- What is our HACCP compliance rate?
- SSOP compliance rate?
- If we have had failures, have they been for a specific area, e.g., failing to maintain records?
- Do we have similar findings in our own data?
I encourage you not only to maintain the necessary records, but to review them and use the data to improve your processes. The only thing worse than having information and not using it, is having the regulatory agency use it “for” you.
About “Dr. Doom”
Mixed in with the attorneys at OFW Law is the former USDA Food Safety Inspection Service’s (FSIS) Administrator, Dr. Barbara Masters. Dr. Masters is a veterinarian who spent eighteen years with FSIS – the final three years as Acting Administrator and Administrator. During her rise to the Administrator’s position, Dr. Masters served as the Deputy Assistant Administrator for Office of Field Operations. While in these key leadership positions at FSIS, Dr. Masters’ primary focus was on the implementation of science-based policies for the protection of public health. Dr. Masters issued the initial Federal Register Notices for a systematic approach to humane treatment of livestock and poultry.
Dr. Masters was involved in the drafting of the training of inspection personnel on the Hazard analysis and critical control points (HACCP) and Sanitation Standard Operating Procedures (SSOP) regulations. She was the lead of the FSIS HACCP Hotline. In addition, Dr. Masters provided technical review for establishment’s hazard analysis, HACCP plans and supporting documentation. She started her career at FSIS as a public health veterinarian that had responsibilities for ante-mortem inspection, sanitation inspection and all post-mortem inspection responsibilities. She has a good understanding of what happens at the in-plant location, because she has spent many of long days working there.