Limitations of Current Inspection Systems Under
Existing Regulations and Need for Improvement Traditional inspection
The existing poultry slaughter inspection
systems were designed before FSIS issued its HACCP regulations and began
targeting its resources to address public health risks associated with
foodborne pathogens. The existing systems were developed when visually
detectable animal diseases were more prevalent and considered to be more of a concern
than they are today. The line speed limits prescribed in SIS, NELS, and NTIS
reflect the Agency's previous focus on the detection of visible defects and
animal diseases and do not give establishments the flexibility to develop new
technologies that would allow for a more efficient approach to address these
conditions. For example, while FSIS inspectors are required to inspect and
condemn carcasses for visual defects at one point in the slaughter process,
poultry slaughter establishments could be given more flexibility to develop
procedures to identify and condemn unacceptable carcasses and parts earlier and
at various points in the slaughter and production process. An inspection system
that provides flexibility for establishments to detect and remove visible
defects and animal at point in the process before the carcasses are presented
to the FSIS inspector would permit establishments to operate at faster line
speeds if they are able to maintain process control.
Another limitation with SIS, NELS, and NTIS
is that they focus substantial FSIS inspection resources on detecting visible
trim and dressing defects that are less important to food safety, particularly in
light of what is now known about the role microbial contamination plays in causing
foodborne human illness. These inspection models need to be updated in light of
the significant advances that have been made in the control or eradication of
many animal diseases that were more prevalent and were considered to present a
greater concern when the existing inspection systems were designed,
particularly in generally healthy classes of animals such as young chickens.
Moreover, the analysis in the risk
assessment conducted by FSIS suggests a significant correlation between increased
unscheduled offline inspection services and lower levels of Salmonella and Campylobacter in young chicken and
turkey slaughter establishments.
This
analysis indicates that reallocating inspection resources currently dedicated
to online inspection under the existing inspection systems to offline, food
safety related inspection activities, such as increased HACCP verification,
sanitation SOP verification, pathogen sampling, and Food Safety Assessments,
could potentially reduce pathogen levels. Additionally, FSIS could devote more
resources to inspection activities that focus on the areas of greatest risk in
the poultry production system if establishments were required to assume greater
responsibility for monitoring compliance with trim and dressing performance
standards.
Source: http://www.fsis.usda.gov/wps/portal/fsis/topics/regulatory-compliance/haccp/haccp-based-inspection-models-project/himp-study-plans-resources/poultry-slaughter-inspection
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