Meat and Poultry

To reduce foodborne illnesses and improve the safety of meat and poultry products, the Department of Agriculture (USDA) issued regulations requiring that all meat and poultry plants adopt a science-based production control system, known as Hazard Analysis and Critical Control Point (HACCP), by January 2000. The HACCP approach, which was recommended by USDA's National Advisory Committee on Microbiological Criteria for Foods and endorsed by the scientific community, is based on seven guiding principles. These principles center around the identification of biological, physical, and chemical hazards that are likely to occur in meat and poultry plants and the establishment of critical points in the production process where controls can be applied to prevent or reduce those hazards. This report (1) determines whether the system adopted by USDA in its regulations is consistent with the seven HACCP principles endorsed by the Advisory Committee, (2) evaluates whether the HACCP training program for USDA inspectors is adequate and science-based, and (3) determines if there is an adequate dispute resolution process between plants and USDA under the new inspection system. GAO found that USDA's HACCP regulations, along with guidance, are consistent with the seven HACCP principles endorsed by the Advisory Committee. Generally, inspectors received the training needed to oversee plants' implementation of HACCP programs, although many inspectors reported that they would benefit from refresher courses. In GAO's view, USDA's dispute resolution process provides industry with an appropriate mechanism to appeal inspectors' enforcement actions.

GAO noted that: (1) USDA's HACCP regulations are consistent with the 7 principles endorsed by the Advisory Committee; (2) the 32 plants GAO visited have HACCP plans, however, some plant managers excluded certain hazards because they believed that existing quality control programs or good manufacturing practices effectively controlled them; (3) to ensure appropriate verification and oversight by USDA inspection personnel, the regulations state plants must identify all hazards reasonably likely to occur in their HACCP plans and control those hazards through their HACCP programs; (4) USDA regulations preclude the use of non-HACCP programs to control hazards reasonably likely to occur because USDA's inspectors focus on ensuring compliance with HACCP regulations and have limited oversight over non-HACCP programs; (5) inspectors received the training needed to oversee plants' implementation of HACCP programs, but many inspectors responding to GAO's nationwide survey reported they would benefit from refresher courses; (6) USDA's training program provided a basic introduction to HACCP's science-based principles while emphasizing the compliance aspects of the inspectors' HACCP duties; (7) however, GAO's review of USDA's HACCP training curriculum and the results of GAO's survey found several aspects of the training program needed to be clarified and reinforced to provide inspectors with the tools needed to conduct consistent and effective inspections of plants' compliance with HACCP requirements; (8) many survey responses suggested that the training was unclear about: (a) inspectors' authority to request that plants make changes to their HACCP plans; (b) the correct frequency for microbial testing for salmonella; (c) the actions inspectors can take if they become aware of microbial contamination that a plant has identified as a hazard through programs that are outside its HACCP plan; and (d) situations where it is appropriate for inspectors to issue noncompliance notices; (9) USDA's dispute resolution process provides industry with an appropriate mechanism to appeal inspectors' enforcement actions; (10) managers said they appeal noncompliance notices that appear inaccurate; (11) repeated notices can result in a Food Safety and Inspection Service (FSIS) determination that the plant's HACCP system failed, however, USDA regulations fail to explicitly state the number or type of noncompliance notices that can result in that determination; and (12) GAO could not verify the accuracy of managers concerns as USDA's new appeals tracking system contains incomplete and inconsistent information.

Recommendations

Our recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.

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