Illnesses stemming from contaminated meat and poultry are responsible for an unknown portion of these illnesses and deaths. In January 1998, FSIS began phasing in HACCP regulatory requirements for meat and poultry slaughter and processing plants. FSIS Is Not Ensuring that Plants’ HACCP Plans Meet Regulatory Requirements

According to FSIS’s food safety systems correlation reviews, inspectors are not consistently identifying and documenting failures of plants’ HACCP plans to meet regulatory requirements. Furthermore, FSIS does not expect its inspectors to determine whether HACCP plans are based on sound science—the cornerstone of an effective plan. The in-depth verification reviews also showed that some plants may have a fundamental misunderstanding of what constitutes a hazard that is reasonably likely to occur. FSIS’s Lack of Consistent Identification and Documentation of Repetitive HACCP Violations Weakens Enforcement

According to our review of 1,180 noncompliance records from 16 plants for fiscal year 2001, plant inspectors have not consistently identified and documented repetitive violations of HACCP requirements. The lack of consistency occurs, in part, because FSIS has not established specific, uniform criteria for identifying repetitive violations. Moreover, even at the district level, officials’ understanding of the factors that should be considered in determining repetitive violations varied. The longer that FSIS allows plants to remain out of compliance with regulatory requirements, the greater the risk that unsafe food will be produced and enter the marketplace. Recommendations for Executive Action

To ensure that all HACCP plans fully meet regulatory requirements, we recommend that the Secretary of Agriculture direct FSIS to   provide inspectors with additional training on their roles and responsibilities under the HACCP system and use data, such as the results from the food safety system correlation reviews, to help target training to address specific weaknesses;   develop procedures for its field supervisors and district managers to use to monitor inspector activities, including, among other things, ensuring that FSIS inspectors are consistently applying HACCP requirements;   develop a risk-based strategy and time frames for consumer safety officers to complete their reviews of HACCP plans at all plants; and   develop a strategy for its supervisors, managers, and officials to systematically use data, including annual data on noncompliance records by districts, to help oversee plants’ compliance with HACCP requirements. To ensure that plants take prompt actions to correct violations, we recommend that the Secretary of Agriculture direct FSIS to   establish clear, consistent criteria for inspectors to use when considering whether to recommend suspension because of repetitive violations; require its inspectors to document the basis for their decision on whether or not to recommend further enforcement action based upon documented repetitive violations;   develop guidance with specific time frames for actions to be taken at plants that fail a second set of Salmonella tests, including time frames for FSIS to initiate an in-depth verification review, report the results of the review, and initiate a third set of tests;   establish, and document in enforcement case files, time frames for plants with suspensions in abeyance to implement and verify the necessary corrective actions; and   document in the enforcement case file how and when the district office determined that the plant had completed its corrective actions and, if the suspension is allowed to remain in abeyance for more than 90 days, the reason for the extension. Appendix I: Scope and Methodology

Our review of the Food Safety and Inspection Service’s (FSIS) enforcement of the Hazard Analysis and Critical Control Point (HACCP) requirements focused exclusively on domestic meat and poultry slaughter and processing plants subject to federal oversight. GAO’s Comments

1. We are recommending that FSIS do so.
Why GAO Did This Study

Every year, some meat and poultry products are contaminated with microbial pathogens--such as Salmonella and E. coli--that cause foodborne illnesses and deaths. To improve the safety of meat and poultry products, the U.S. Department of Agriculture's (USDA) Food Safety and Inspection Service (FSIS) introduced additional regulatory requirements for meat and poultry plants. These requirements are intended to ensure that plants operate food safety systems that are prevention-oriented and science-based. These systems, called Hazard Analysis and Critical Control Point (HACCP) systems, were phased in from January 1998 through January 2000 at all meat and poultry slaughter and processing plants. As the foundation of the HACCP system, plants are responsible for developing HACCP plans that, among other things, identify all of the contamination hazards that are reasonably likely to occur in a plant's particular production environment, establish all of the necessary steps to control these hazards, and have valid scientific evidence to support their decisions.

What GAO Found

GAO found that FSIS is not ensuring that all plants' HACCP plans meet regulatory requirements. As a result, consumers may be unnecessarily exposed to unsafe foods that can cause foodborne illnesses. In particular, FSIS's inspectors have not consistently identified and documented failures of plants' HACCP plans to comply with requirements. In addition, although sound science is the cornerstone of an effective HACCP plan, FSIS does not expect its inspectors to determine whether HACCP plans are based on sound science because inspectors lack the expertise to do so. FSIS is not consistently identifying repetitive violations, according to GAO's review of 1,180 noncompliance records for fiscal year 2001. This has occurred, in part, because FSIS has not established specific, uniform, and clearly defined criteria for its inspectors to use in determining when a violation is repetitive. Furthermore, at the district level, FSIS officials' understanding of the criteria to consider in determining if a violation is repetitive varied. Also, in several instances, inspectors have not fully documented the basis for their decisions about repetitive violations on noncompliance records. FSIS is not ensuring that plants take prompt and effective action to return to compliance after a HACCP violation has been identified. The longer that FSIS allows plants to remain out of compliance with regulatory requirements, the greater the risk that unsafe food will be produced and marketed.