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pdf“AT LEAST EQUAL TO” GUIDELINE FOR STATE
MEAT AND POULTRY
INSPECTION PROGRAMS
November 2016
United States Department of Agriculture
Food Safety and Inspection Service
State-Federal Cooperation
Page 1
What if I still have questions after I read this guideline?
If the desired information cannot be found within the Guideline, FSIS recommends
users search the publicly posted Questions & Answers (Q&As) in the AskFSIS database
or submit questions through AskFSIS. Documenting these questions helps FSIS
improve and refine present and future versions of the Compliance Guideline and
associated issuances.
When submitting a question, use the Submit a Question tab, and enter the following
information in the fields provided:
Subject Field: Compliance Guideline for State Meat and Poultry Inspection Programs.
Question Field: Enter question with as much detail as possible.
Product Field: Select General Inspection Policy from the drop-down menu.
Category Field: Select Cooperative State Inspection Programs from the drop-down
menu.
Policy Arena: Select Domestic (U.S.) Only from the drop-down menu.
When all fields are complete, press Continue and at the next screen press Finish
Submitting Question.
NOTE: Refer to FSIS Directive 5620.1, Using AskFSIS, for additional information on
submitting questions.
Page 2
“AT LEAST EQUAL TO” GUIDELINE FOR STATE MEAT AND POULTRY
INSPECTION PROGRAMS
Table of Contents
I.
“At Least Equal To” Definition
4
II.
Purpose
5
III.
Background
5
IV.
Annual Self-Assessment
6-10
V.
Onsite Review
11-13
VI.
Determination Process
13-14
VII.
Appeal Process
14-15
VIII.
FSIS Reports
15
IX.
Nine Program Components
X.
Component 1: Statutory Authority and Food Safety
Regulations
15-25
Component 2: Inspection
26-44
Component 3: Sampling Programs
45-51
Component 4: Staffing, Training, and Supervision
52-60
Component 5: Humane Handling
61-63
Component 6: Compliance
64-70
Component 7: Laboratory Methods and Quality Assurance
Program
71-75
Component 8: Civil Rights
75-80
Component 9: Financial Accountability
81-85
Additional Resources
Reference Table of Related FSIS Policy Documents
85-99
100-111
Page 3
KEY DEFINITION AND
STATE MPI PROGRAM
REQUIREMENT
“At Least Equal To”
The “at least equal to” standard requires
State MPI programs operate in a manner
that is not less effective than those
standards adopted for the Federal
inspection program.
The standard does not require the States
operate their MPI programs in a manner
that is the same as or identical to FSIS’s
inspection program, nor does it prohibit
the State MPI programs from establishing
safeguards they believe to be more
effective than those employed by FSIS.
Page 4
SIGNIFICANT
CHANGES
I.
This guideline replaces the previous
version, issued July 2008. FSIS
updated the guideline to consolidate
components, add new components
and resource information, and to
revise tables. The most notable
changes are as follows:
The date for the States’ annual
self-assessment submission has
changed from November 15th to
November 1st of each year.
Component 1 - Statutory Authority
and Food Safety Regulations has a new
table titled “Statutory Side-by-Side
Comparison Table”
Component 2 - Inspection
includes:
•
Former Component 6 – NonFood Safety Consumer
Protection is added in its
entirety;
•
The Quarterly New Issuance
Review process is a new
section added to this
component; and
•
The guideline titled, “At least
equal to data system
requirements for State
Cooperative Meat and Poultry
Inspection (MPI) programs
electing not to use FSIS’s
Public Health Information
System (PHIS)” published in
January 2015 is added at the
end of Component 2.
Component 3 – Sampling Programs
(formerly known as “Product Sampling”)
has been retitled.
PURPOSE
This guideline provides information to State Cooperative
Inspection programs on the criteria that the Food Safety
and Inspection Service (FSIS) uses to determine each
year whether State Meat and Poultry Inspection (MPI)
programs are operating verifiably in accordance with
requirements that are “at least equal to” the Federal
inspection requirements. The guideline contains
information that State MPI programs need to establish and
maintain such programs.
II.
BACKGROUND
The Federal Meat Inspection Act (FMIA) (21 U.S.C. 661)
and the Poultry Products Inspection Act (PPIA) (21 U.S.C.
454) authorize FSIS to cooperate with State agencies in
developing and administering their own Meat and Poultry
Inspection (MPI) programs. Individual State MPI
programs are required to operate under authorities that
are “at least equal to” the provisions for ante-mortem and
post-mortem inspection, reinspection, sanitation,
recordkeeping, and enforcement in the FMIA and PPIA
and implementing regulations. State MPI programs are
also expected to ensure livestock are treated humanely by
assuring the methods of handling livestock are “at least
equal to” those outlined in the Humane Methods of
Slaughter Act of 1978 (HMSA)(7 U.S.C. 1901-906).
The FMIA (21 U.S.C. 661(b)) and the PPIA (21 U.S.C. 454
(b)) authorize FSIS to cooperate with a single State
agency and subordinate governmental unit primarily
responsible for the coordination of a State MPI program.
In matters concerning the State MPI program, FSIS will
communicate and coordinate with designated State
employees assigned to the single State agency identified
by the State as responsible for ensuring that all
applicable inspection and compliance activities outlined in
these guidelines comply with specified laws, regulations
and policies. The activities include those conducted by
State or contract laboratories, public health departments,
law enforcement agencies, State human resource
departments, budget departments and other State
regulatory agencies.
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Component 6 – Compliance (formerly
known as “Component 7 – Compliance”) has
been retitled and includes a new table titled
“Summary of Statutory Authority per Business
Type.”
Component 7 – Laboratory Methods and
Quality Assurance Program is a new
component for laboratory methods and quality
assurance criteria. This information was
previously published in June 2014 as a
separate guideline titled “At Least Equal To
Compliance Guideline for State Meat and
Poultry Inspection (MPI) Programs for
Laboratory Methods” and has been updated
and added as a component.
The following Tables have been updated to
better reflect the information needed by
FSIS in the evaluation of State MPI program
operations:
Component 3 – State MPI Program
III.
ANNUAL SELF-ASSESSMENT
FSIS expects the State MPI programs to submit their
annual self-assessment documents to FSIS’s FederalState Audit Branch (FSAB) on or before November 1st of
each year. Each State MPI program should start its annual
self-assessment with a review of the prior-year selfassessment. Each component of the annual selfassessment should include a written narrative statement
and documentation demonstrating the program
continuously meets the criteria to be “at least equal to” the
Federal program. The self-assessment should identify any
program changes in the previous 12 months and include
documentation which will support the State’s ability to
maintain its program for the next 12 months. State MPI
programs should also submit sufficient documentation to
demonstrate the State MPI program has stayed current
with FSIS statutes, regulations, applicable FSIS Directives
and Notices, and has implemented any changes necessary
to maintain its “at least equal to” status.
Sampling Activity Table.
Component 4 – State MPI Program
Establishment Count and the State MPI
Program Employee Primary Roles.
Component 6 – Compliance Activity
Report.
Additional Resources is a new
section added at the end of the
guideline to provide State MPI program
Directors with reference material that
may be needed to perform business
processes related to budget
submissions, training and Federal
resource information, cooperation
between State and Federal Compliance
programs, and information on internal
controls. The section also includes a
Reference Table of Related FSIS Policy
Documents, which is a reference guide
to FSIS policy documents relevant to
the implementation of the nine program
components.
The annual self-assessment submission should also
include one or more narratives describing internal controls
used by the State MPI program that:
•
Provide assurances that internal controls can
measure the effectiveness of the program under the “at
least equal to” criteria;
•
Demonstrate how nonconformances will be
addressed by corrective actions; and
•
Demonstrate how the State MPI program will be
maintained throughout the next 12 months.
These internal controls should provide an objective
assessment of the State MPI program’s operations and
processes to determine whether:
• Financial and operating information is accurate
and reliable;
• Operational risks are appropriately identified and
managed;
• Applicable regulations and internal policies and
procedures are followed; and
• The “at least equal to” standard is maintained.
Page 6
Ultimately, State MPI programs need to operate in a manner that protects the health
and welfare of consumers within their State by ensuring the meat and poultry products
distributed by the program establishments are wholesome, not adulterated, and properly
marked, labeled, and packaged.
More specifically, the annual self-assessment should also address each of the following
nine program components so as to demonstrate the State’s MPI program is
administered in a manner that is “at least equal to” the Federal inspection requirements
and describe how it will maintain this status for the following 12 months. FSIS Directive
5720.3, Methodology for Performing Scheduled and Targeted Reviews of State Meat
and Poultry Inspection Programs, provides the FSIS review methodology and criteria for
each component.
The Nine Program Components
Component 1
Statutory Authority
and Food Safety
Regulations
Component 2
Inspection
Component
Sampling
Programs
3
Component 4
Component 5
Staffing, Training,
and Supervision
Humane Handling
Compliance
Component 8
Civil Rights
Component 9
Component 7
Laboratory
Methods and
Quality Assurance
Program
Component 6
Financial
Accountability
For each of the first six (1-6) components, State MPI programs need to submit selfassessment documentation demonstrating the State MPI program is meeting the “at
least equal to” Federal inspection requirements. Such documentation should include
the attached Annual Certification – “At Least Equal To” Meat and Poultry Inspection
Program (Attachment 1, page 10) and a narrative describing any changes made in the
State MPI program during the previous 12 months.
For Component 2, State MPI programs that have elected not to use the FSIS Public
Health Information System (PHIS), should refer to guidance information (Attachment 3,
Page 7
page 38) titled, “At least equal to” data system guidance for State Cooperative Meat and
Poultry Inspection (MPI) programs electing not to use Public Health Information System
(PHIS) can be found at the end of Component 2. State MPI program Directors are to
submit the requested data system information with the annual self-assessment
submission to FSAB for review.
For Component 7, State MPI programs need to submit the following self-assessment
documentation to FSIS, Office of Public Health Science (OPHS):
•
A list of current State laboratory and/or contract laboratory test methods and
copies of new or revised methods accompanied by a Laboratory Method
Notification Form; and
•
A completed FSIS Form 5720-14, FSIS MPI Program Laboratory Quality
Management System Checklist or use another easy to read format for each
State or contract laboratory performing MPI-related analyses or their current ISO
17025 certificates of accreditation for each State and/or contract laboratory
performing MPI-related analyses
For Component 8, the State MPI programs are to complete and submit FSIS Form
1520-1, Civil Rights Compliance of State-Inspection Programs, or use another easy to
read format to the FSIS Civil Rights Staff.
Relative to Component 9, the State MPI programs should submit specified financial
reports as requested throughout the fiscal year. Although deadlines for submitting
certain financial reports may coincide with FSIS’s self-assessment submission deadline
of November 1. Financial Reviews and Analysis Section (FRAS) does not require the
inclusion of these financial reports as part of the annual self-assessment submission for
Component 9. Component 9 includes a list of supporting documentation the State
agencies should have readily available for FSIS reviewers, upon request, prior to or
during the on-site financial review.
State MPI program Directors should submit the self-assessment for the various program
components and any required or requested documents as follows:
Components 1–6
Email: [email protected]
USDA, FSIS, OIEA, MCAD, FSAB Chief
Edward Zorinsky Federal Building
1616 Capital Avenue, Suite 260
Omaha, NE 68102-5908
Telephone: 402-344-5018
Fax: 402-344-5104
Page 8
Component 7
Email: [email protected]
Director, USDA, FSIS, OPHS, Laboratory Quality Assurance Staff
950 College Station Road
Athens, GA 30605
Telephone: 706-546-3559
Component 8
FSIS Civil Rights Staff
5601 Sunnyside Avenue, Mail Drop 5261
Beltsville, MD 20705-5261
Telephone: 800-269-6912
Fax: 301-504-2141
Component 9
Email: [email protected]
Financial Reviews and Analysis Section
USDA/FSIS/OA/OCFO/FMD/FASMB
5601 Sunnyside Avenue, Mail Drop 5264
Beltsville, MD 20705-5264
Telephone: 301-344-0479
Fax: 301-504-5914
Page 9
Attachment 1
Annual Certification
“At Least Equal To” Meat and Poultry Inspection Program
I have reviewed the attached self-assessment submission of the [insert name of State]
State-Federal Cooperative Inspection program. Based on current information, I certify
that the State Meat and Poultry Inspection (MPI) program is “at least equal to” the
requirements specified in the Federal Meat Inspection Act (FMIA), the Poultry Products
Inspection Act (PPIA), the Humane Methods of Slaughter Act (HMSA) and current FSIS
regulations, directives, notices and policies. The State MPI program officials intend to
maintain the program as “at least equal to” the applicable requirements specified in the
FMIA, PPIA and HMSA, and certify that the program is able to stay current with
applicable FSIS regulations, directives, notices and policies to ensure an “at least equal
to” status. If conditions change that impact this certification, I will immediately notify the
Chief of the Federal-State Audit Branch.
USDA, FSIS, OIEA, MCAD, FSAB Chief
Edward Zorinsky Federal Building
1616 Capital Avenue, Suite 260
Omaha, NE 68102-5908
Telephone: 402-344-5018
Fax: 402-344-5104
Name of Responsible State Official ____________________________________
Title of Responsible State Official _____________________________________
Signature of Responsible State Official _________________________________
Date __________________________
State __________________________
Contact Telephone Number _________________________________________
Contact E-Mail ____________________________________________________
Contact Fax Number _______________________________________________
Page 10
IV. ON-SITE REVIEW
In addition to the annual self-assessment submission, State MPI programs are subject
to an on-site review at a minimum frequency of once every three years to verify the
accuracy and implementation of the self-assessment submissions. In the year that a
State MPI program is scheduled for an on-site review, FSIS’s annual determination of
whether the program is “at least equal to” the Federal inspection
program will be based on a review of the annual self-assessment
submission and the on-site review. Please refer to FSIS Directive
5720.3, Methodology for Performing Scheduled and Targeted
Reviews of State Meat and Poultry Inspection Programs, for the
FSIS Review Methodology.
The purpose of the on-site review is for FSIS to verify the State
MPI program implements and maintains its inspection system in
accordance with its annually submitted self-assessment, and to determine whether the
State MPI program is “at least equal to” the Federal inspection program in its
administration and enforcement of requirements. The FSIS review team will review the
State MPI program’s current annual self-assessment submission in advance so that
they are able to begin the on-site review of the State MPI program with a thorough
understanding of the State program’s current self-assessment submission. FSIS will
review a selected number of establishments within the State MPI program and examine
and evaluate documentation at the central office to verify the State MPI program’s
implementation, oversight, and management controls.
In October of each year, FSIS will announce the State MPI programs scheduled for an
on-site review in the upcoming federal fiscal year. FSIS will send a written notification
to State MPI programs at least 30 days before the start of the on-site review process.
The on-site review will begin with a teleconference serving as the entrance meeting
between FSIS and State MPI program officials. To facilitate FSIS’s selection of
establishments to review, State MPI program officials are to supply information from the
last 12 months (12 months prior to review) to FSIS within 10 business days after the
conclusion of the entrance meeting. The information is to include the following:
•
•
A current list of establishments and their operating schedules (please omit ID
warehouses and establishments which slaughter or process only non-amenable
species), supervisory boundaries, program updates, and HACCP process
categories for all establishments with the 5 highest producers for each category
identified.
Positive Shiga toxin-producing E. coli (STEC) results
•
Positive Listeria monocytogenes (Lm) or Salmonella results in RTE products
•
Failures of Salmonella and Campylobacter Performance Standards for raw
products
•
Enforcement actions taken
•
Recalls conducted and associated documentation
Page 11
•
Establishments that sustained structural damage in production areas due to
natural disasters
•
Establishments that the State MPI program reviewed, e.g., FSAs, supervisory
reviews, internal reviews, management control audits
At least one week before the scheduled on-site review, FSIS will notify the State MPI
program of the establishments chosen for the on-site review. Should the State MPI
program officials ask FSIS to omit a chosen State establishment from its review, they
will need to provide written justification for their request (e.g., the establishment is
closed the day of the review, the establishment is a seasonal operator). FSIS travels to
the chosen State establishment and follows the on-site review protocol. If a chosen
State establishment decides not to operate after the on-site review process begins,
FSIS selects an alternate State establishment to visit. An electronic draft report of
individual establishment findings will be provided to the State MPI program officials by
the next business day. At the end of each establishment review, after a short
correlation with FSIS, the State MPI program personnel will lead an exit meeting with
State establishment management.
Within 10 working days of completing the on-site review, FSAB will schedule a
teleconference exit meeting with State MPI program officials. Before the teleconference
exit meeting, FSAB will provide a summary report of all findings to the State MPI
program officials.
The types of findings detailed in the aforementioned FSAB summary report that requires
corrective actions will include:
•
•
•
Processes that are not operating or functioning in the manner intended as
detailed in the State’s annual self-assessment or that are not included in
the self-assessment submission;
Processes that are ineffective; and
Regulatory noncompliances.
The State MPI program has 10 working days after the teleconference to present an
action plan designed to address all findings that require corrective actions. The State
MPI program is to identify any underlying causes for findings that require corrective
actions. Corrective actions may include the implementation of preventive measures
e.g., targeted staff training, increased supervisory oversight, where applicable. If the
State MPI program is unable to identify underlying causes for certain findings they are
to share and explain the method they used in their attempts to identify the underlying
causes and the results of the associated evaluation conducted to draw the conclusion.
They are to also justify why they believe the corrective actions identified in the action
plan for such findings are adequate. After receiving documentation demonstrating
implementation of the action plan, FSAB will assess the plan and determine if actions
taken are sufficient. If the action plan is adequate FSAB will issue a determination
Page 12
memorandum and Interim Annual Comprehensive Review and Determination Report to
the State MPI program Director.
FSIS may request clarification of specific items regarding the State MPI program’s
implementation of its action plan, and in certain cases, may perform a targeted on-site
review before the issuance of a determination memorandum. A targeted on-site review
conducted prior to the issuance of a determination memorandum is an in-depth
evaluation of the State MPI program’s implementation of its action plan. FSIS uses the
targeted review to verify resolution of any public health concerns and compliance with
the “at least equal to” criteria.
The Annual Comprehensive Review and Determination Report will summarize the
results of the State’s self-assessment submission and on-site review of the State MPI
program (including the results of the targeted on-site review, if applicable). The report
will include the FSIS review team’s final “at least equal to” determination supported by
individual component determinations.
V. DETERMINATION PROCESS
FSIS makes a determination after evaluating the State’s annual self-assessment and
the results of the on-site review, as applicable. The definitions for the three FSIS
determinations on the status of the State MPI program are:
1. “At Least Equal To”—The State MPI program has adopted laws, regulations,
and programs, and implements them in a manner that is “at least equal to”
FSIS’s Federal inspection program for all review components.
2. “At Least Equal To,” with Provisions—FSIS makes a provisional
determination of the State MPI program’s “at least equal to,” status provided
the program takes additional action to resolve review findings.
3. Not “At Least Equal To”—The State MPI program has not adopted laws,
regulations, or programs, or does not implement them in a manner that is “at
least equal to” FSIS’s Federal inspection program for one or more of the
review components.
At the conclusion of each annual self-assessment review, FSIS decides whether the
State MPI program is or is not meeting the “at least equal to” requirements. If the State
MPI program is not scheduled for an on-site review during the current fiscal year, FSIS
makes an annual determination based only on the results of the self-assessment
review. If the State MPI program is scheduled for an on-site review during the current
fiscal year, FSIS bases the annual determination on the results of the self-assessment
and the on-site review. If the determination of the self-assessment, or self-assessment
and the on-site review, if applicable, is that the State program meets the “at least equal
to” standard, FSIS promptly gives the State program officials written notification of that
Page 13
fact. If additional clarification is needed for a determination, FSIS requests
supplemental information from the State MPI program and issues an Interim Annual
Comprehensive Review and Determination Report.
When an analysis of all findings, clarifications, and corrective actions from the selfassessment or on-site review indicates a State MPI program cannot support an “at least
equal to” determination, FSIS recommends to the Secretary of Agriculture that the State
be designated for Federal inspection. 1 If a State cannot immediately implement an
action plan but is committed to making the corrections and has the resources to support
the changes, FSIS defers designation instead of making a final determination that the
State program is not “at least equal to” FSIS’s Federal inspection program.
Before the Secretary initiates the Federal designation process that results in State
establishments being subject to the Federal inspection program, FSIS and the State
agency confer on the State MPI program’s deficiencies. If the State MPI program is
unable to meet the “at least equal to” requirements or if its responsible officials are
unwilling to do so, the Secretary of Agriculture notifies the Governor of the State that the
State does not have an “at least equal to” MPI program and is not in compliance with
the cooperative agreement between FSIS and the State, and is subject to the Federal
designation of its MPI program.
If deficiencies are not resolved, the Secretary will designate the State MPI program for
Federal meat and poultry inspection and publish a notice of the designation in the
Federal Register. Upon the expiration of thirty days after the publication of the Federal
Register notice the State-inspected establishments will become subject to Federal
inspection.
VI. APPEAL PROCESS
State officials have the right to appeal any program status determination made by FSIS.
The appeal process follows the Office of Investigation, Enforcement and Audit’s (OIEA)
chain of command. The chain of command ensures that Agency employees most
familiar with the facts of the appeal will perform the initial evaluation of the appeal. The
Appeal process gives State officials the right to appeal to the next highest level if not
satisfied with the outcome. The OIEA chain of command is:
1) FSIS employee who made the finding (e.g., FSAB Program Auditor);
2) FSAB Team Lead;
3) FSAB Chief;
4) Management Controls and Audit Division (MCAD) Director;
5) OIEA Deputy Assistant Administrator;
1
Directive 5710.1, Designation of States for Federal Meat or Poultry Inspection, outlines the procedures for
designation of States for Federal meat or poultry inspection.
Page 14
6) OIEA Assistant Administrator; and
7) FSIS Administrator.
VII. FSIS REPORTS
The State MPI program officials are notified in writing when FSIS makes a
determination after analysis of the self-assessment and on-site review, as applicable.
An individual end-of-year report is sent to each State MPI program summarizing
program findings. Additionally, each year FSIS publishes on its Web site an overall
end-of-year summary report of the findings and final determinations for all State MPI
programs at http://www.fsis.usda.gov/wps/portal/fsis/topics/inspection/state-inspectionprograms/state-inspection-and-cooperative-agreements/reviews-of-state-programs
VIII. NINE PROGRAM COMPONENTS
Component
Component1:1:
Statutory
and
StatutoryAuthority
Authority
and
Food
Safety
Regulations
Food Safety Regulations
Criteria for “at least equal to” determination
State MPI programs need to have meat and poultry inspection laws and regulations
that impose mandatory ante-mortem and post-mortem inspection, reinspection,
sanitation requirements, recordkeeping requirements, and enforcement authorities “at
least equal to” those prescribed by the FMIA 2 (21 U.S.C. 601, et seq.) and PPIA 3(21
U.S.C. 451, et seq.). State MPI programs need to also enforce requirements that are
“at least equal to” those imposed under the Humane Methods of Slaughter Act of 1978
(HMSA) 4 (7 U.S.C. 1901, et seq.).
2
The Federal Meat Inspection Act (21 U.S.C. 601, et seq.) governs the slaughter of livestock and the processing and
distribution of meat products in the United States. Passed by Congress in March 1907, the FMIA authorizes the
Secretary of Agriculture to set national standards for meat inspection. The FMIA was amended in the Wholesome
Meat Act of 1967, granting the Secretary of Agriculture the authority to authorize each State to develop its own
meat inspection program if their requirements are “at least equal to” Federal requirements. The amended FMIA
assures uniformity in regulation of products shipped interstate, intrastate, and in foreign commerce.
3
The Poultry Products Inspection Act (21 U.S.C. 451, et seq.) governs the slaughtering,
processing, and distribution of poultry products in the United States. Passed by Congress in August 1957, the PPIA
authorizes the Secretary of Agriculture to make rules and regulations setting national standards for poultry
inspection. The PPIA was amended in the Wholesome Poultry Products Act of 1968, granting the Secretary of
Agriculture the authority to authorize each State to develop its own poultry inspection program if their requirements
are “at least equal to” federal requirements. The amended PPIA assures uniformity in regulation of products
shipped interstate, intrastate, and in foreign commerce.
4
The Humane Methods of Slaughter Act (7 U.S.C. 1901 et seq.) governs the humane treatment of animals at official
establishments. Passed by Congress in 1978, the HMSA authorizes the Secretary of Agriculture to make rules and
regulations setting national standards for livestock inspection. The HMSA prevents needless suffering of animals,
Page 15
State MPI programs need to also be in compliance with Federal Civil Rights laws:
•
Title VI of the Civil Rights Act of 1964 [42 U.S.C. 200 (d)];
•
Section 504 of the Rehabilitation Act of 1973, as Amended (29 U.S.C. 794);
•
Age Discrimination Act of 1990 (42 U.S.C. 12101, et seq.);
•
Applicable USDA Civil Rights regulations;
•
Financial Accountability requirements pursuant to the Uniform Administrative
Requirements for Grants and Cooperative Agreements to State and Local
Governments (7 Code of Federal Regulations (CFR) Part 3016), (previously
known as the Common Rule);
•
The Uniform Administrative Requirements for Grants and Cooperative
Agreements to State and Local Governments (7CFR Part 3016), (previously
known as the Common Rule); and
•
FSIS Directive 3300.1, Rev. 2, Fiscal Guidelines for Cooperative Meat and
Poultry Inspection Programs.
To ensure States are in compliance with the statutory and regulatory requirements
detailed above, State MPI programs need to:
•
Adopt by reference the FMIA, PPIA, and HMSA and implementing
regulations; or impose State laws that meet the “at least equal to”
requirements of the FMIA, PPIA, and HMSA, and explain in their submission
to FSIS how those requirements provide a level of protection that is “at least
equal to” that which is imposed by the FMIA, PPIA, HMSA and implementing
regulations
FSIS allows time for the State’s rulemaking process when necessary, because there are
States that have legislatures that do not always meet on an annual basis. The State
MPI program needs to ensure there are measures in place to verify compliance and
take enforcement actions for non-compliance findings until the final rulemaking process
has been completed. The State MPI program needs to have the authority to expedite
the rulemaking process in a manner “at least equal to” that provided for in the
Administrative Procedure Act, 5 U.S.C. §553.
If a State MPI program has enacted its own comparable State statutes and regulations
that are “at least equal to” those governing the Federal inspection requirements, it
needs to ensure that the statutes and regulations establish requirements that State
produces safer and better working conditions, brings about improvement of products and economies, and produces
other benefits for producers, processors and consumers. Nothing in the HMSA shall be construed to prohibit,
abridge, or in any other way hinder the religious freedom of any person or group.
Page 16
establishments maintain sanitary conditions and operate in a manner that includes
evaluating hazards, taking steps to control hazards, and routinely verifying that product
is safe, wholesome, not adulterated, and properly marked and labeled.
States need to ensure that their statutes and regulations adequately address, in an “at
least equal to” manner, mandatory ante-mortem and post-mortem inspection,
reinspection, sanitation requirements, recordkeeping requirements, compliance
provisions, and enforcement authorities to ensure that product is wholesome and not
adulterated. In addition, State regulations need to address the humane treatment of
animals at establishments under inspection.
Outcome
The expected outcome is a set of laws and regulations in place that, when objectively
reviewed by FSIS, are determined to be “at least equal to” FSIS’s Federal laws and
regulations.
“At least equal to” Requirements
State MPI program officials need to stay current with applicable laws, administrative
rules, FSIS regulations, FSIS directives and notices, and any other policies, and be
able to explain how their State programs are “at least equal to” FSIS’s Federal
inspection program requirements. The State officials should include a narrative that
describes any changes in the State laws and regulations over the past 12 months, and
of any proposed changes that may affect their “at least equal to” status over the
subsequent 12 months.
Objective
State MPI programs need to periodically review applicable State laws, regulations, FSIS
Directives and Notices and other FSIS policies to ensure the State programs provide a
level of protection that is “at least equal to” those imposed by FMIA, PPIA, HMSA and
regulations in section 9 of the CFR.
Statutory Authority and Food Safety Regulations Methods and Procedures
State MPI programs need to have methods to periodically evaluate changes to Federal
laws and regulations for applicability to State MPI programs, and need to revise State
MPI laws and regulations as necessary.
The methods should, at a minimum, address the following critical aspects:
•
Procedures for periodic evaluation of changes to applicable laws and regulations;
•
State legislative procedures;
•
State emergency legislative procedures;
Page 17
•
State rulemaking procedures; and
•
State emergency rulemaking procedures.
Evidence of system application
State MPI programs should provide evidence which demonstrates implementation of
methods and procedures that are “at least equal to” those of FSIS’s Federal inspection
program.
At a minimum, the State MPI program should submit:
•
Documentation of periodic evaluations of current State laws, regulations and
other policies;
•
The State laws and regulations applicable when species other than those
covered by the FMIA and PPIA are considered amenable under State laws;
•
Current copies or Web links to State laws, regulations, and other policies with
specific cross-references to 9 CFR;
•
Current copies or Web links to State rulemaking and emergency rulemaking
procedures;
•
Documentation of laws and regulations currently undergoing State rulemaking
and emergency rulemaking processes which affect the State MPI program;
•
Documentation that verify State laws are “at least equal to” the provisions of the
FMIA, PPIA, and HMSA as specified in Attachment 2; and
NOTE: The Statutory Side-by-Side Comparison Table (Attachment 2, page 19) has
been provided as a tool for the State MPI programs to demonstrate comparable
State statutes, laws, or regulations for each of the applicable FMIA, PPIA, and
HMSA provisions.
•
Legal documentation that State MPI programs have the authority to impose meat
and poultry inspection laws and regulations with the same purposes as the
Federal laws that govern FSIS’s Federal inspection program.
Page 18
Attachment 2
FEDERAL Acts
STATE MPI PROGRAM
STATUTORY SIDE-BY-SIDE COMPARISON TABLE
Comparable Specific State Statutes, Laws, Rules or
Regulations
Federal Meat Inspection Act
Subchapter I - Inspection Requirements; Adulteration &
Misbranding.
§601. Definitions.
§602. Congressional statement of findings.
Not applicable to “at least equal to” criteria
Ante-Mortem And Post-Mortem Inspection Requirements
§603. Inspection of meat and meat food products.
Authority To Take Action Against Any Persons Found To Be Engaging In Inhumane Methods Of Slaughter
b) Humane methods of slaughter.
In conjunction with:
7 U.S.C. § 1902 - Humane methods.
§604. Post mortem examination of carcasses and
marking or labeling; destruction of carcasses
condemned; reinspection.
Re-inspection Requirements
§605. Examination of carcasses brought into slaughtering
or packing establishments, and meat food products
issued from and returned thereto; conditions for entry.
§606. Inspection and labeling of meat food products.
§607. Labeling, marking, and container requirements.
Sanitation Requirements
§608. Sanitary inspection and regulation of slaughtering
and packing establishments; rejection of adulterated
meat or meat food products.
§609. Examination of animals and food products thereof,
slaughtered and prepared during nighttime.
Not applicable for “at least equal to” criteria
Prohibited Acts
§610. Prohibited acts.
Devices, Marks, Labels, and Certificates; Simulations
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§611. Devices, marks, labels, and certificates;
simulations.
Notification
§612. Notification.
Plans and Reassessment
§613. Plans and reassessments.
§614. Repealed.
Not applicable for “at least equal to” criteria
§615. Inspection of carcasses, meat intended for export.
Not applicable for “at least equal to” criteria
§616. Inspectors of carcasses, etc., meat intended for
export; certificates of condition.
Not applicable for “at least equal to” criteria
§617. Clearance prohibited to vessel carrying meat for
export without inspector's certificate.
Not applicable for “at least equal to” criteria
§618. Delivery of inspectors' certificates, and of copies.
Not applicable for “at least equal to” criteria
§619. Marking, labeling, or other identification of kinds
of animals of articles' derivation; separate
establishments for preparation and slaughtering
activities.
Not applicable for “at least equal to” criteria
§620. Imports.
Not applicable for “at least equal to” criteria
§621. Inspectors make examinations provided for;
appointment; duties; regulations.
Bribery
§622. Bribery of or gifts to inspectors or other officers
and acceptance of gifts.
§623. Exemptions from inspection requirements.
§624. Storage and handling regulations; violations;
exemption of establishments subject to non-Federal
jurisdiction.
Not applicable for “at least equal to” criteria
§625. Inapplicability of certain requirements to catfish.
Not applicable for “at least equal to” criteria
Prohibition of articles not intended for use as human food; denaturation or other identification prior to distribution in
commerce; inedible articles
Subchapter II - Meat Processors & Related Industries
§641. Prohibition of subchapter I inspection of articles
not intended for use as human food; denaturation or
other identification prior to distribution in commerce;
inedible articles.
Page 20
Record-Keeping Requirements And Examination Of Records
§642. Recordkeeping requirements.
Registration Of Business, Name Of Person, And Trade Names.
§643. Registration of business, name of person, and
trade names.
§644. Regulation of transactions, transportation, or
importation of 4-D animals to prevent use as human
food.
§645. Federal provisions applicable to State or Territorial
business transactions of a local nature and not subject to
local authority.
Not applicable for “at least equal to” criteria
Subchapter III - Federal & State Cooperation
§661. Federal and State cooperation.
Not applicable for “at least equal to” criteria
Inspection Services; Refusal Or Withdrawal; Hearing; Business Unfitness Based Upon Certain Convictions; Other
Provisions For Withdrawal Of Services Unaffected; Responsible Connection With Business; Finality Of Secretary's
Actions; Judicial Review; Record.
Subchapter IV - Auxiliary Provisions
§671. Inspection services; refusal or withdrawal;
hearing; business unfitness based upon certain
convictions; other provisions for withdrawal of services
unaffected; responsible connection with business;
finality of Secretary's actions; judicial review; record.
Detention
§672. Administrative detention; duration; pending
judicial proceedings; notification of governmental
authorities; release.
Seizure and Condemnation
§673. Seizure and condemnation.
§674. Federal court jurisdiction of enforcement and
injunction proceedings and other kinds of cases;
limitations of section 607(e) of this title.
Not applicable for “at least equal to” criteria
Assaults-Intimidation
§675. Assaulting, resisting, or impeding certain persons;
murder; protection of such persons.
Violations
§676. Violations.
§677. Other Federal laws applicable for administration
and enforcement of chapter; location of inquiries;
jurisdiction of Federal courts.
Not applicable for “at least equal to” criteria
§678. Non-Federal jurisdiction of federally regulated
Not applicable for “at least equal to” criteria
Page 21
matters; prohibition of additional or different
requirements for establishments with inspection services
and as to marking, labeling, packaging, and ingredients;
recordkeeping and related requirements; concurrent
jurisdiction over distribution for human food purposes of
adulterated or misbranded and imported articles; other
matters.
§679. Application of Federal Food, Drug, and Cosmetic
Act.
Not applicable for “at least equal to” criteria
§679a. Safe Meat and Poultry Inspection Panel.
Not applicable for “at least equal to” criteria
§679b. Pasteurization of meat and poultry.
Not applicable for “at least equal to” criteria
§679c. Expansion of Food Safety Inspection Service
activities.
Not applicable for “at least equal to” criteria
§680. Authorization of appropriations.
Not applicable for “at least equal to” criteria
Subchapter IV-A - Inspections By Federal and State
Agencies
§683. Interstate shipment of meat inspected by Federal
and State agencies for certain small establishments.
Not applicable for “at least equal to” criteria
Subchapter V - Inspections by Federal and State Agencies
§691. Omitted.
Not applicable for “at least equal to” criteria
§692. Inspection extended to reindeer.
Not applicable for “at least equal to” criteria
§693. Inspection of dairy products for export.
Not applicable for “at least equal to” criteria
§694. Authorization of appropriations.
Not applicable for “at least equal to” criteria
§695. Payment of cost of meat-inspection service;
exception for cost of overtime.
Not applicable for “at least equal to” criteria
Poultry Products Inspection Act
Comparable Specific State Statutes, Laws, or Rules
§451. Congressional statement of findings.
Not applicable for “at least equal to” criteria
§452. Congressional declaration of policy.
Not applicable for “at least equal to” criteria
§453. Definitions.
§454. Federal and State cooperation in development
and administration of State poultry product inspection
programs.
Not applicable for “at least equal to” criteria
Ante-mortem and Post-mortem inspection and Reinspection requirements
Page 22
§455. Inspection in official establishments.
Sanitation Requirements
§456. Operation of premises, facilities and equipment.
§457. Labeling and container standards.
Prohibited Acts
§458. Prohibited acts.
Devices, Marks, Labels, and Certificates; Simulations
(b) No brand manufacturer, printer, or person…
(c) No person shall forge…
Notification
§459. Compliance by all establishments.
(b) Notification.
Plans and Reassessment
(c) Plans and reassessments.
Prohibition Of Articles Not Intended For Use As Human Food; Denaturation Or Other Identification Prior To
Distribution In Commerce; Inedible Articles
§460. Miscellaneous activities subject to regulation.
Record-Keeping And Examination Of Records
(b) Recordkeeping requirements; persons liable; scope of
disclosure; access to places of business; examination of
records, facilities, and inventories; copies; samples.
(c) Registration of business, name of person, and trade
names.
(d) Regulation of transactions, transportation, or
importation of dead, dying, disabled or diseased poultry
or carcasses to prevent use as human food.
(e) Federal provisions applicable to State or Territorial
business transactions of a local nature and not subject to
local authority.
Assaults and Intimidation
§461. Offenses and punishment.
§462. Reporting of violations; notice; opportunity to
present views.
§463. Rules and regulations.
Not applicable for “at least equal to” criteria
§464. Exemptions.
§465. Limitations upon entry of poultry products and
Page 23
other materials into official establishments.
§466. Imports.
Not applicable for “at least equal to” criteria
Inspection Services; Refusal Or Withdrawal; Hearing; Business Unfitness Based Upon Certain Convictions; Other
Provisions For Withdrawal Of Services Unaffected; Responsible Connection With Business; Finality Of Secretary's
Actions; Judicial Review; Record.
§467. Inspection services.
Detention
§467a. Administrative detention; duration; pending
judicial proceedings; notification of government
authorities; release; removal of official marks.
Seizure and Condemnation
§467b. Seizure and condemnation.
§467c. Federal court jurisdiction of enforcement and
injunction proceedings and other kinds of cases;
limitations; United States as plaintiff; subpoenas.
Not applicable for “at least equal to” criteria
§467d. Administration and enforcement; applicability of
penalty provisions; conduct of inquiries; power and
jurisdiction of courts.
Not applicable for “at least equal to” criteria
§467e. Non-Federal jurisdiction of federally regulated
matters; prohibition of additional or different
requirements for establishments with inspection services
and as to marking, labeling, packaging, and ingredients;
recordkeeping and related requirements; concurrent
jurisdiction over distribution for human food purposes of
adulterated or misbranded and imported articles; other
matters.
Not applicable for “at least equal to” criteria
§467f. Federal Food, Drug, and Cosmetic Act
applications.
(a) Exemptions; authorities under food, drug, and
cosmetic provisions unaffected.
(b) Enforcement proceedings; detainer authority of
representatives of Secretary of Health and Human
Services.
Not applicable for “at least equal to” criteria
§468. Cost of inspection; overtime.
Not applicable for “at least equal to” criteria
§469. Authorization of appropriations.
Not applicable for “at least equal to” criteria
§470. Omitted.
Not applicable for “at least equal to” criteria
§471. Safe Meat and Poultry Inspection Panel.
Not applicable for “at least equal to” criteria
§472. Interstate shipment of poultry inspected by
Not applicable for “at least equal to” criteria
Page 24
Federal and State agencies for certain small
establishments.
Humane Methods of Livestock Slaughter Act
Comparable Specific State Statutes, Laws, or Rules
§1901. Findings and declaration of policy.
Not applicable for “at least equal to” criteria
§1902. Humane methods.
§1904. Methods research; designation of methods.
Not applicable for “at least equal to” criteria
§1906. Exemption of ritual slaughter.
§1907. Practices involving nonambulatory livestock.
Not applicable for “at least equal to” criteria
Page 25
Component 2: Inspection
Criteria for “at least equal to” Determination
Each State MPI program need to submit a current narrative describing the State
inspection system used to enforce all applicable laws, regulations, and FSIS policies.
The State system should have the capability to correct any deviations from regulatory
requirements that may affect its program’s being “at least equal to” FSIS’s Federal
inspection program.
State MPI programs need to submit any supporting documentation (preferably
completed reports and documents) to demonstrate the State inspection system, as
described in the narrative, has been implemented, is functioning as intended, and will
ensure the State MPI program has the ability to remain “at least equal to” FSIS’s
Federal inspection program for the next 12 months.
Inspection methods and procedures followed under a State MPI program must be “at
least equal to” the FMIA, PPIA, HMSA, the applicable regulations in 9 CFR 300 to end,
and applicable policies issued for FSIS’s Federal inspection program. At a minimum,
the State inspection program should include the following criteria:
•
Ante-mortem A State MPI program is to examine and inspect all livestock and
poultry before slaughter to determine whether animals are fit for slaughter and
can be used for human food. A State MPI program should verify that
establishments present all animals for ante-mortem inspection in accordance
with the FMIA, PPIA, and 9 CFR, ensuring animals with abnormalities and signs
that could otherwise indicate disease are removed from human edible food
channels.
•
Post-mortem State Inspection Program Personnel (IPP) should examine and
inspect carcasses in the slaughter process and post-mortem in State inspected
establishments to determine whether carcasses and parts are wholesome and
not adulterated and thus permitted to receive the State mark of inspection.
Inspection of meat and poultry carcasses, including applicable parts, is
conducted in a manner “at least equal to” FSIS’s processes, as described in 9
CFR 311 and 381, Subpart K, respectively.
•
Sanitation A State MPI program should verify that establishments have
developed, implemented, and maintained Sanitation Standard Operating
Procedures (Sanitation SOPs) consistent with requirements in 9 CFR 416.
•
Food Safety Requirements A State MPI program should verify each State
inspected establishment’s food safety system, including Hazard Analysis and
Critical Control Point (HACCP) plans are consistent with requirements in 9 CFR
417.
•
Non-Food Safety Requirements A State MPI program should verify all products
produced for distribution in intrastate commerce are wholesome, and properly
labeled. State IPP need to perform the appropriate activities for verifying
Page 26
compliance with applicable requirements to those in the FMIA, PPIA, and 9 CFR.
These activities include verifying accuracy of State inspected establishment
product formulation for labeling and product standard of identity requirements;
observing preparation or processing procedures; reviewing establishment
records; and performing a variety of in-plant measurements and calculations.
•
Regulatory Enforcement A State MPI program should develop and apply
administrative enforcement consistent with those in 9 CFR 500 (Rules of
Practice) to ensure establishments are provided due process of law and bring
noncompliant establishments back into compliance with the FMIA, PPIA, HMSA,
and 9 CFR.
•
Exempt Facility Reviews A State MPI program should verify that all products
produced in State exempt facilities (either in official State inspected
establishments or a separate facility) comply with regulatory and statutory
requirements for sanitation, adulteration, and labeling.
•
New Issuance Reviews A State MPI program should evaluate the applicability of
new FSIS laws, regulations, FSIS Directives and Notices and any other policies,
and ensure they are implemented, as appropriate.
Outcome
When objectively reviewed by FSIS, the State MPI program is determined to be “at least
equal to” FSIS’s Federal inspection program.
A State MPI program has:
•
A series of standards and policies that define how State inspected
establishments can operate to produce safe, wholesome, not adulterated and
properly labeled and packaged products.
•
A comprehensive State regulatory inspection system (e.g., Public Health
Information System (PHIS)) that collects, consolidates, and analyzes data and
enforces the meat and poultry regulations at State-inspected establishment.
NOTE: State MPI program Directors that have elected not to use FSIS’s PHIS can find
guidance information titled, “At least equal to” data system guidance for State
Cooperative Meat and Poultry Inspection (MPI) Programs electing not to use Public
Health Information System (PHIS) (Attachment 3, page 38). State MPI program
Directors are to submit the requested data system information with the annual selfassessment submission to the FSAB for review. By August 1st of each year, FSIS will
provide State MPI programs with guidance on the PHIS inspection tasks.
• Assurances that State-inspected establishments can maintain food safety
systems to reduce, eliminate, or prevent food hazards (i.e., any biological,
chemical, or physical property that may cause a food to be unsafe for human
consumption)
Page 27
•
A system to carry out administrative actions when State inspected
establishments are not meeting the provisions of “at least equal to” the FMIA,
PPIA, HMSA, applicable State laws, and 9 CFR
•
A system to review exempt facilities to determine their compliance under the
sanitation, adulteration, labeling, and other statutory and regulatory requirements
•
A system to evaluate the applicability of new FSIS policies and determine how to
implement the policies in the State MPI program
“At least equal to” Requirements
The State MPI program is required to maintain:
•
A Slaughter Inspection System;
•
A Food Safety Verification System;
•
A Non-Food Safety Verification System;
•
An Exempt Facility Review System; and
•
A New Issuance Review System.
NOTE: State MPI program Directors need to submit the data integrity information for the
data collected and maintained in their system in place of the PHIS. The data integrity
information should include:
•
The type of data maintained outside of PHIS (e.g., FSAs, custom exempt
reviews, NOIEs);
•
How the data integrity is maintained (e.g., safeguards to restrict access, security
tools); and
•
The State law or administrative rule that governs the security and integrity
preservation of meat and poultry inspection program records.
Slaughter Inspection System
State MPI programs should maintain a slaughter inspection system that is able to verify
whether State inspected establishments comply with requirements consistent with the
FMIA, PPIA, and HMSA. The slaughter inspection system should have a method for
assigning tasks and documenting task results for slaughter inspection requirements at
State inspected establishments. The slaughter inspection system needs to be able to
capture the results of ante-mortem and post-mortem inspection activities (e.g.,
suspected animals, condemned carcasses and parts) including the capability to capture
any regulatory noncompliance and regulatory control actions taken. State MPI program
officials should create or adopt slaughter inspection policies and procedures for
conducting ante-mortem and post-mortem inspection activities that ensure compliance
with Federal and State laws and regulations.
Page 28
Objective
To implement state inspection activities which ensure animals are suitable for slaughter;
products are not adulterated, wholesome, properly labeled, marked, and packaged, and
carcasses and parts are eligible for human consumption.
Inspection Methods and Procedures
State MPI programs should implement slaughter inspection methods and procedures “at
least equal to” those of FSIS’s Federal inspection program. The methods and
procedures at a minimum should include:
•
•
Methods and procedures to inspect livestock and poultry before slaughter (antemortem inspection) and verify that animals offered for slaughter have received
ante-mortem inspection
•
Procedures to follow when State IPP observe animals showing symptoms
of disease or abnormalities and signs that could indicate disease or other
health conditions that would prohibit the animal from entering the food
supply
•
Procedures to mark and document dispositions of livestock following antemortem inspections
Methods and procedures to inspect livestock and poultry after slaughter (postmortem inspection) to make and document dispositions of carcasses following
post-mortem inspections
•
Procedures to verify State inspected establishments that slaughter cattle
and establishments that process the carcasses or parts of cattle are
complying with 9 CFR 310.22, requiring the removal, segregation, and
disposition of specified risk materials (SRMs)
•
Methods and procedures used to document and maintain case files supporting
administrative enforcement and other actions taken under the authority of FMIA,
PPIA, and applicable State laws
•
Methods and procedures to assess whether slaughter inspection activities
successfully meet the State MPI program management’s expectations for:
•
•
In-Plant Level Slaughter Inspections
•
Ante-mortem
•
Post-mortem
•
Noncompliance regulatory documentation
•
Enforcement actions
•
Product recalls (e.g., uninspected animals and carcasses)
Central Office Level Assessments
•
Administrative case development
Page 29
•
Program personnel competency
Evidence of system application
A State MPI program should provide evidence that demonstrates the implementation of
a State slaughter inspection system that is “at least equal to” that of the FSIS’s Federal
inspection program. At a minimum, the State MPI program should submit:
•
Representative State Animal Disposition Summary/PHIS analogous reports that
list animal and carcass dispositions performed within the last 12 months
•
Documentation of regulatory control, withholding, suspension, enforcement, or
administrative actions taken when noncompliance is identified (e.g.,
Noncompliance Records (NRs), 30 day letters, Notice of Intended Enforcement
(NOIE) letters, Suspension letters, or notification to withhold the marks of
inspection)
•
Management’s evaluation and results of State slaughter inspection system
performance
Food Safety Verification System
The sanitation criteria incorporate the regulations that address SPS, Sanitation SOPs,
and HACCP, which are identified as essential parts of a food safety system. The
regulations require that State inspected establishments maintain Sanitation SOPs and
meet the SPS requirements. Sanitation SOPs are a prerequisite to an establishment’s
HACCP plan, and establishments may use Sanitation SOPs to support decisions in the
hazard analysis that certain hazards are not reasonably likely to occur. State inspected
establishments may also maintain other prerequisite programs to support decisions in
their hazard analyses.
The State MPI programs are required to maintain a food safety verification system
capable of identifying noncompliances in an establishment’s food safety systems. The
State MPI system should have the ability to identify deleterious trends that occur in
State inspected establishments’ food safety system (e.g., increased number of NRs,
increased positive sample results), and should also be able to document the results of
food safety verification activities, including regulatory noncompliance and regulatory
actions taken. Additionally, State MPI program managers are required to adopt or
create policies for conducting food safety verification activities to ensure compliance
with Federal and State laws and regulations.
Objective
To implement food safety verification activities that ensure all State inspected meat and
poultry products found in intrastate commerce are safe, wholesome, not adulterated and
properly marked, labeled and packaged, and can verify State inspected establishments
comply with applicable State laws, regulations and policies.
Page 30
Food Safety Verification System Methods and Procedures
State MPI programs need to implement food safety verification system methods and
procedures “at least equal to” those of FSIS’s Federal inspection system. The methods
and procedures at a minimum should include:
•
Methods to schedule tasks, record food safety verification tasks, and document
noncompliance with regulatory requirements
•
Procedures to protect the public health by properly verifying State
inspected establishments’ compliance with the pathogen reduction,
sanitation, and the HACCP regulations
•
Procedures to verify that State inspected establishments that slaughter
cattle and establishments that process the carcasses or parts of cattle are
complying with 9 CFR 310.22 and prescribe to requirements for the
removal, segregation, and disposition of SRMs
•
Procedures to verify State inspected slaughter operations are
implementing sanitary dressing and process control procedures that
prevent contamination of carcasses
•
Procedures to verify that State inspected establishments implement other
prerequisite programs as described and in accordance with 9 CFR 417
•
Procedures for protecting public health by verifying, documenting, and
enforcing the requirements for no visible fecal material, milk, or ingesta on
livestock carcasses at or immediately after the final rail, and by verifying
feces, ingesta, and milk are not present on head meat, cheek meat, and
weasand meat
•
Procedures for verifying visible fecal material are not present on State
inspected poultry carcasses entering the chill tank
•
Procedures to protect the public health by properly verifying State
inspected establishments’ compliance with the pathogen reduction,
sanitation, and the HACCP regulations
•
Procedures for holding weekly meetings with State inspected
establishment management to discuss topics pertaining to the
establishments’ food safety system and other issues which could affect
public health
•
Methods to investigate and analyze all food safety aspects (e.g., FSA) that relate
to State inspected establishments and their individual products, the design and
validity of the establishments’ hazard analyses, HACCP plans, Sanitation SOP,
pre-requisite programs, testing programs, and any other programs that constitute
the establishments’ HACCP systems
•
Methods to categorize State inspected processing and slaughter establishments
into a priority level for FSA scheduling, using public health decision criteria, in
addition to traditional event-based scheduling
Page 31
•
Methods used to document and maintain case files that support administrative
enforcement and other actions taken under the authority of the FMIA, PPIA, and
applicable State laws
•
Methods to assess whether food safety verification activities successfully meet
the State MPI program management’s expectation for:
•
•
In-Plant Level Food Safety Verifications
•
SPS
•
SSOP
•
Prerequisite programs
•
HACCP
•
Noncompliance regulatory documentation
•
Enforcement actions
•
Product recalls
Central Office Level Assessments
•
FSA
•
Administrative case development
•
Program personnel competency
Evidence of system application
A State MPI program should provide evidence that demonstrates implementation of a
food safety verification system “at least equal to” that of the Federal inspection system.
At a minimum, the State MPI program should submit:
•
Representative HACCP Summary/PHIS analogous reports by State inspected
establishments/circuits/districts that list all food safety verification tasks
performed within the last 12 months
•
Documentation of enforcement and administrative actions taken when regulatory
noncompliance was identified (e.g., Noncompliance Records (NRs), 30 day
letters, Notice of Intended Enforcement (NOIEs) letters, Suspension letters,
withhold the marks of inspection letters)
•
In-depth establishment food-safety reviews (e.g., FSAs, and supervisory
establishment reviews)
•
State issuances and policies that are different than those issued by FSIS
•
Completed grant-of-inspection approval process, and withdrawal documents
•
Evidence and verification methods that State MPI programs use as an assurance
that their program is effectively implemented
Page 32
•
Documentation of actions taken (e.g., rejection of the knock box, suspension) in
response to identified SPS, Sanitation SOP, or HACCP noncompliance
State MPI programs should submit completed supporting documentation to demonstrate
that these programs, as described in the narrative, have been implemented. The State
MPI programs need to ensure controls exist and are functioning as intended to maintain
their operations over the next 12 months.
Non-Food Safety Verification System 5
The State MPI program should maintain a non-food-safety verification system that
includes methods and procedures for verifying that State inspected meat and poultry
products are wholesome, not economically adulterated, truthfully labeled, and meet the
non-food-safety regulatory requirements. The system should also document identified
noncompliances and regulatory actions taken. State MPI program managers should
adopt policies for conducting non-food-safety verification to ensure compliance with
Federal and State laws and regulations.
Objective
To implement State inspection activities that ensure all State inspected meat and
poultry products found in intrastate commerce are safe, wholesome, not adulterated and
properly marked, labeled and packaged to verify State-inspected establishments comply
with applicable State laws, regulations and policies.
Non-food Safety Verification System Methods and Procedures
State MPI programs need to implement methods and procedures “at least equal to”
those of FSIS’s Federal inspection program. The methods and procedures at a
minimum should include:
•
Methods to schedule and record non-food safety verification tasks, and
document noncompliance with regulatory requirements
•
Methods to verify State inspected establishments comply with non-food safety
regulatory requirements
•
Procedures for:
•
Observing establishment product formulation
•
Verifying the accuracy of labeling
•
Observing preparation or processing procedures
5
“Non-food safety consumer protection” refers to consumer protection activities other than those focused directly
on food safety and public health. Under the FMIA and the PPIA, FSIS is responsible for ensuring that products are
wholesome; are properly marked, labeled, and packaged; and are not economically adulterated or do not contain
components that, while not actually unsafe, are undesirable.
Page 33
•
•
Reviewing establishment records
•
Examining product
•
Checking product identification, condition and temperature
•
Performing a variety of other in-plant measurements, testing, and
calculations
Procedures to verify and determine whether product labels are not false or
misleading and meet applicable requirements of 9 CFR 412 (formerly 9
CFR 317.4, 317.5, 381.132, and 381.133).
•
Methods to review and approve sketch labels and supporting documentation
•
Methods used to document and maintain case files supporting administrative
enforcement and other actions taken under the authority of the FMIA, PPIA, and
applicable State laws
•
Methods to assess whether State non-food safety requirements and label
approval verification activities successfully meet the State MPI program
management’s expectation for:
•
•
In-Plant Level Non-Food Safety Verifications
•
Net weights
•
Standards of identity
•
Generic label requirements
•
Noncompliance regulatory documentation
•
Enforcement actions
•
Product recalls for non-food safety situations
Central Office Level Assessments
•
Label approval process
•
Administrative case development
•
Program personnel competency
Evidence of System Application
A State MPI program needs to provide evidence that its non-food-safety verification
system is “at least equal to”” FSIS’s Federal inspection program. At a minimum, the
State MPI program should submit:
•
Representative Summary or PHIS-analogous reports by
establishments/circuits/districts that list all non-food-safety requirement
verification tasks performed within the last 12 months
•
Final labels including supporting documentation (e.g., sketch labels, label
applications, ingredient formulation worksheets)
Page 34
•
Approved label tracking logs
•
In-depth establishment reviews (e.g., supervisory establishment reviews)
•
Evidence and verification methods State MPI programs use to assure their
program is effectively implemented (e.g., label approvals, label reviews)
•
Documentation of actions taken in response to non-food safety requirements
verification noncompliance
Exempt Facility Review System
The State MPI program needs to maintain a system to conduct reviews of exempt
facilities (either within official State inspected establishments or separate facilities) to
determine their compliance with the FMIA, PPIA, applicable State laws, regulations and
policies. State MPI program managers should adopt or create policies for conducting
reviews of exempt and poultry exempt facilities.
Objective
To ensure State exempt facilities comply with applicable State laws, regulations and
policies.
Exempt Facility Review Methods and Procedures
State MPI programs need to implement review methods “at least equal to” those of
FSIS’s Federal inspection program. The methods, at a minimum, should include:
•
•
A review of the State exempt operation to verify livestock and poultry carcasses
and products are:
•
Not adulterated or misbranded
•
Handled humanely (livestock)
•
Prepared under sanitary conditions
•
Properly marked and packaged
•
Stored separately from State inspected products
•
Documented according to regulatory requirements
A method to assess whether the State exempt facility activities successfully meet
the State MPI program management’s expectations
Page 35
Evidence of system application
A State MPI program needs to provide evidence that demonstrates implementation of
an exempt facility review system that is “at least equal to” that of FSIS’s Federal
inspection system. At a minimum, the State MPI program should submit:
•
Documentation and tracking logs for State exempt facility reviews
•
Management’s evaluation and results of the State exempt facility review system
performance
New Issuance Review System
Objective
The new issuances list is updated quarterly and is used to verify that State MPI
programs are staying current with new FSIS policies. FSIS routinely issues regulations
and notices in the Federal Register to communicate new policies and requirements to
the public. FSIS also routinely issues Directives and Notices to Federal IPP to provide
direction and guidance regarding inspection and enforcement activities.
Each quarter, FSIS provides State MPI programs with an updated list of all applicable
issuances published since the previous quarter. FSIS continues to provide this
information in an effort to better communicate the “at least equal to” criteria for State
MPI programs. State MPI programs are to review all issuances and incorporate any
necessary modifications in their programs. State MPI programs are to submit a
response to the Quarterly List of Applicable FSIS Issuances within 30 days after receipt
of the list.
New Issuances Methods and Procedures
While State MPI programs are not required to follow FSIS issuances verbatim or to
issue similar documents to their inspection program personnel, they need to consider
the implications of each issuance and are expected to be able to explain their “at least
equal to” actions (even if their decision is to do nothing) related to the activity or issue
covered by the FSIS issuances.
When a policy is issued by FSIS, State MPI programs need to have methods in place to
determine the applicability of the policy to their State program, and decide how to
communicate instructions for its implementation within their State inspection programs.
The State’s results will be documented as a response to each new issuance on the
Quarterly List of Applicable FSIS Issuances. For each new issuance, using one of the
alternatives listed below, the State MPI program should document that the State:
•
Determined that the issuance has no application for its State MPI
program maintaining its “at least equal to” status; the State should fully
explain why;
Page 36
•
Adopted essentially the same approach in its State MPI program; and
submitted documentation demonstrating implementation; or
•
Adopted measures in the State MPI program that the State considers to
be “at least equal to” FSIS’s Federal inspection program; provided the
reason and justification for doing so, explained why and how they
became convinced that they are “at least equal to” FSIS’s Federal
inspection program, and provided documentation demonstrating
implementation.
Evidence of system application
State officials need to be able to provide a justification for their “at least equal to”
determination for each new Federal issuance. State MPI programs are to respond to
the Quarterly List of Applicable FSIS Issuances sent on or before the first day of each
quarter of the Federal fiscal year (e.g., October, January, April, and July) within 30
calendar days of receipt. The response should include a description of the methods
used to distribute the issuances and evidence of delivery, and a summary of how the
new issuance or policy change is being implemented. States should submit any
documentation that demonstrates how each issuance was implemented.
Examples of the manner in which issuances are implemented are included in the
Quarterly List of Applicable FSIS Issuances. However, other documents may be used to
demonstrate the implementation.
States should enter information into the designated column on the Quarterly List of
Applicable FSIS Issuances, and attach the responses to an email to the Federal State
Audit Branch (FSAB) at: [email protected], or by USPS,
FedEx, UPS, or FAX (402-344-5104).
Page 37
Attachment 3
“At Least Equal To” Data System Guidance for State Cooperative Meat and
Poultry Inspection (MPI) Programs Electing Not to Use Public Health Information
System (PHIS)
I. PURPOSE
To provide guidance to State Cooperative Meat and Poultry Inspection (MPI) programs
electing to use a data system other than FSIS’s PHIS for meeting the “at least equal to”
data system essentials.
II. BACKGROUND
The Federal Meat Inspection Act (FMIA) (21 U.S.C. 661) and the Poultry Products
Inspection Act (PPIA) (21 U.S.C. 454) authorize FSIS to cooperate with State agencies
in developing and administering their own Meat and Poultry Inspection programs.
Individual State MPI programs are required to operate in a manner and with authorities
that are “at least equal to” the ante-mortem and post-mortem inspection, reinspection,
sanitation, recordkeeping, and enforcement provisions as provided for in the FMIA and
PPIA. Therefore, State MPI programs are required to develop a data system with
characteristics that can produce inspection and recordkeeping outcomes “at least equal
to” FSIS’s procedures. FSIS maintains PHIS as its data system.
FSIS developed PHIS to maintain detailed records of regulatory compliance verification
activities. The activities are conducted by FSIS‘s Federal inspectors and the
information is entered into PHIS by FSIS personnel at official establishments, official
import establishments, and registered facilities. The PHIS database maintains
establishment and facility data, and the results of inspection verifications. FSIS uses
this information to identify issues that require Agency attention.
PHIS supports documentation of appeals to inspection decisions, scheduling, and
documentation of Food Safety Assessments (FSA) and the ability to identify and notify
suppliers of beef products that have tested positive for E. coli O157:H7. FSIS uses
PHIS to manage FSIS’s inspection assignments and FSIS’s employee assignments to
roles and establishments.
The PHIS sample scheduler distributes product sample requests to Establishment Task
Lists. FSIS uses PHIS to apply business rules and risk-based algorithms for sample
selection and output reports of scheduled samples. These scheduled sample requests
tasks are performed by FSIS’s Federal IPP. FSIS uses PHIS to process information
about imported products. FSIS’s Federal IPP input reinspection results for imported
products in to PHIS. PHIS’s functionality includes a means for FSIS’s Office of Policy
and Program Development (OPPD), International Equivalence Staff (IES) and the Office
of Investigation, Enforcement and Audit (OIEA) Management Control and Audit Staff
(MCAD) to schedule and track foreign country audit activities.
Page 38
The information held in PHIS is shared with the Microbial (M2K) transactional database
and the FSIS data warehouse. Information is written to the data warehouse from the
PHIS transactional database to be used by other systems including the Enterprise
Reporting System (ERS). The FSIS data warehouse provides a source of legacy
system data which is used to support the analysis of inspection, audit, and assessment
outcomes, and it maintains data from VetNet and PulseNet.
FSIS analyses the data collected in PHIS through its regulatory verification, compliance
and enforcement, and sampling activities to assess the appropriateness of policy design
and policy implementation. The analysis informs further policy development.
Additionally, FSIS uses the information gathered from data analysis to ensure that
policy and program components are effective in meeting the FSIS’s public health goals
and objectives.
FSIS recognizes that an integrated infrastructure with high-quality data and feedback
interaction is essential to a data-driven approach to inspection. A data-driven approach
to inspection requires quality data collection methods, ongoing data analysis to refine
analytical decision-making tools, and performance measures to assess the impact of
policies and programs.
The Task Library in PHIS supports the assignment of tasks to Establishment Task Lists.
Each task is distributed to the Establishment Task List with a due date for completing
the task. FSIS’s Federal IPP have the ability to schedule the assigned tasks by moving
the tasks from the Establishment task List to the Establishment Task Calendar. FSIS
designed PHIS to allow IPP the flexibility to decide on which days they will perform the
tasks.
Alerts are issued when specific events requiring immediate attention occur. Alerts are
also used to remind FSIS’s Federal IPP to take a particular action, such as, acquiring a
product sample for laboratory analysis. An alert consists of a “trigger” and a
“notification” function. The trigger is a feature that automatically scans the data for a
specific event, and upon finding it, issues the notification. The notification can take the
form of an email sent by PHIS, a message on the user’s PHIS Alerts Dashboard, or
both.
PHIS issues Public Health Regulation (PHR) alerts when there is a pattern of
noncompliance at the establishment. Each month the Office of Data Integration and
Food Protection (ODIFP) uses the results of inspection tasks to calculate the PHR
noncompliance rate for each meat and poultry establishment as well as egg products
plants. A PHR alert is issued to FSIS’s Federal IPP when an establishment has a
noncompliance rate that is elevated.
Examples of other events that trigger alerts are: a large number of inspection tasks not
completed at an establishment, high rates of noncompliance in an establishment, and a
positive adulterant pathogen test result at an establishment (e.g., Escherichia coli (E.
coli) O157:H7 in raw ground beef, Shiga toxin-producing Escherichia coli (STEC) in
beef manufacturing trimmings, or Listeria monocytogenes (Lm)/Salmonella in ready-toPage 39
eat (RTE) products). The alert text gives directions to FSIS’s Federal IPP by pointing
them to the appropriate regulations and directives needed for the response.
PHIS Dashboard Alerts and e-mail notifications are issued to Headquarters and FSIS’s
Federal IPP as events occur. The alerts and notifications provide FSIS’s Federal IPP
and FSIS‘s Headquarters personnel with information that is important to the execution
of their work assignments.
The PHIS includes a set of standard reports available to all FSIS administrative levels.
FSIS produces a wide range of PHIS reports. The reports are run by FSIS personnel
on an as needed basis. The reports are run for specific time frames identified by the
user. The reports are available to FSIS personnel based on their assigned PHIS role.
So, District management teams see aggregated reports for a District while FSIS’s
Federal IPP assigned to an establishment see reports for the assigned establishment.
An example of a standard report is the monthly report of noncompliances by FSIS
District Offices.
Reports are used at all levels of FSIS to monitor operations, to identify areas needing
corrective actions, and to communicate progress towards goals. Users can review the
reports and identify results that require investigation and establishment response. PHIS
reports provide FSIS’s Federal IPP and FSIS’s Headquarters personnel with information
that is important to the execution of their work assignments.
III. ELEMENTS OF AN “AT LEAST EQUAL TO” DATA SYSTEM
To be “at least equal to” the FSIS’s system, the State MPI data system needs to:
•
Collect, analyze and respond to State inspected establishment and State MPI
program data;
•
Monitor data streams to determine State inspected establishment performance;
and
•
Respond, near real-time, to State inspected establishments that may pose a risk
to public health
To be “at least equal to” the State MPI data system needs to collect data from the
following four activities:
•
Daily inspection verification activities at operating State inspected establishments
•
State MPI program HACCP verification testing
•
State MPI program in-depth food safety reviews
•
State MPI program administrative enforcement actions
Set out below are guidance and recommendations for State MPI programs to use in
developing their data systems if they choose not to participate in PHIS. State MPI
programs should monitor data collected from the four activities listed above. The data
collected should be compared to different data sets (e.g., data of multiple circuits, data
Page 40
of multiple establishments, and data from previous months) and analyzed to determine
whether the State MPI program is meeting program goals and objectives. State MPI
programs should take appropriate actions, based on the analysis, when goals and
objectives are not being met.
1. Daily inspection verification activities at operating State inspected
establishments
Data Collection
State MPI programs need to collect State inspected establishment demographics
(profiles). These profiles should include critical up-to-date information about the
establishment’s size, products produced, production volume, recall history, noncompliance history, and food defense plans. HACCP information for the
establishment should be available in the profile and include summary information,
processing categories, food safety hazards, critical control points, and prerequisite
programs. A State MPI program should ensure State IPP are able to verify that
State inspected establishments’ profile information is accurate and current at set
intervals (e.g., at least every thirty days or whenever the HACCP plan changes).
NOTE: By August 1st of each year, FSIS provides State MPI programs with
guidance on the PHIS inspection tasks. The FSIS PHIS Inspection Task Catalog
will be updated annually to reflect current PHIS task information and then
distributed separately as an addendum to the State MPI programs.
Data Analysis
The State MPI program’s data system should contain public health-based decision
criteria to identify State inspected establishments requiring more frequent inspection
activities (e.g., increased directed food safety verification tasks).
The State MPI program’s data system should also include a mechanism to react to
State inspection results. Examples of events or trends that would trigger the State
MPI program to react to State inspection results include:
•
A large number of inspection activities not completed in State inspected
establishments;
•
High rates of non-compliance in State inspected establishments;
•
A positive pathogen test result in State inspected establishments (e.g., E.
coli O157:H7 in raw ground beef or Lm in RTE products)
•
Infrequent State inspected establishment profile updates (e.g., HACCP plan
changes failed to be identified or documented)
•
Tasks are not being performed at frequencies sufficient to ensure the safety
of public health
Page 41
The State MPI programs should ensure data quality and accuracy so that the
integrity of the information is not compromised (i.e., system identifying outdated
establishment profile information or unperformed tasks).
2. State MPI program HACCP verification testing
Data Collection
The State MPI programs should maintain a system for tracking pathogen and
residue testing results.
Data Analysis
The State MPI program’s verification testing system should contain public healthbased decision criteria to identify establishments requiring more frequent inspection
activities (e.g., increased directed sampling due to positive sampling results or
concerns with establishment’s production process).
The system should include a mechanism to react to sampling results. Examples of
events that would trigger the State MPI program to react to sampling results may
include but are not limited to:
•
A large number of sampling activities not completed at State inspected
establishments
•
A large number of laboratory discards
•
Positive sampling results in State inspected establishments for adulterant
pathogens (e.g., E. coli O157:H7 in raw ground beef, STEC in beef
manufacturing trimmings, or Lm/Salmonella in RTE products)
•
Violative residues
•
Identifying long-term processes that may have exceeded their schedule (e.g.,
a Salmonella sample set that has not been finished)
3. State MPI program in-depth food safety reviews
State MPI programs should have procedures (e.g., Food Safety Assessments
(FSA)) to verify that an establishment’s food-safety systems are effective and
yielding products that are wholesome and not adulterated, properly marked, labeled
and packaged.
Data Collection
A State MPI program system should track routine and “for cause” in-depth foodsafety reviews.
Data Analysis
Page 42
The State MPI program’s data system includes a mechanism to react to sampling
and inspection results that could lead to a “for cause” in-depth food safety system
review. Examples of events that may trigger the State MPI program to conduct a
“for cause” in-depth food safety system review may include, but are not limited to:
•
State inspected establishments not in compliance with specific laws and
regulations
•
A positive for STECs in raw ground beef or raw ground beef components
•
A positive Lm or Salmonella in RTE products or a positive Lm food contact
surface sample
•
A Class I recall or a food-safety-related enforcement action (e.g., Notice of
Intended Enforcement) that is not the result of an in-depth food safety system
review
•
State inspected establishments that fail Salmonella or Campylobacter
performance standards
•
A State inspected establishment that is the supplier of a product that tested
positive for STECs in raw beef products
•
Human illness linked to a product from a State inspected establishment
•
A State inspected establishment that has a high level of public health-related
Non-compliance Records (NR)
4. State MPI program administrative enforcement action
State MPI programs should have procedures in place to initiate enforcement actions,
as needed, to ensure food safety compliance.
Data Collection
The State MPI programs should maintain a system to collect data and facts to
support administrative enforcement actions, and to track the results of actions taken
(e.g., NRs, in-depth food-safety system reviews, intensified verification testing (IVT),
suspensions, and recall information).
Data Analysis
The State MPI program’s data system should include a mechanism to react to the
data collected in support of administrative enforcement actions. Examples of events
that may trigger the State MPI program to take administrative enforcement actions
may include:
•
Positive STECs in raw ground beef or raw ground beef components
Page 43
•
Positive Lm, Salmonella, or E. coli O157:H7 in RTE products or a positive Lm
food-contact-surface sample
•
A State inspected establishment that is the supplier of a product that tested
positive for STECs in raw beef products
•
Human illness linked to State inspected product from an establishment
(possible recall)
•
State inspected establishments not in compliance with specific State laws and
regulations
An explanation of the data system and supporting documents should be included in the
annual State Self-Assessment that is submitted to the Federal State Audit Branch by
November 1 of each year.
IV.
REFERENCES
FSIS Public Health Information System (PHIS) Reference Information:
FSIS Strategic Data Analysis Plan for Domestic Inspection
http://www.fsis.usda.gov/wps/wcm/connect/84fa563e-0f5c-4df5-8e0499a04e9ce102/2010_Strategic_Data_Analysis_Plan.pdf?MOD=AJPERES
Data-Driven Inspection for Processing and Slaughter Establishments
http://www.fsis.usda.gov/wps/wcm/connect/fcaeabab-b89e-4bd4-b990c697f34a797f/2010_Public_Health_Decsion_Criteria_Report.pdf?MOD=AJPERES
Public Health Regulation List, Fiscal Year 2017
http://www.fsis.usda.gov/wps/portal/fsis/topics/data-collection-and-reports/fsis-dataanalysis-and-reporting/data-reporting/public-health-regulations
Page 44
Component 3: Sampling
Programs
Criteria for “at least equal to” Determination
Each State MPI Program needs to submit a current narrative describing the complete
verification sampling program used to evaluate the effectiveness of each State
inspected establishment’s food safety system. The narrative should identify the various
chemical and microbiological sampling projects that are a part of the State MPI
program’s verification sampling program. The State MPI program should ensure that
the product and the production environment are tested for microbiological contaminants
or chemical residues, in a manner that is “at least equal to” FSIS’s Federal sampling
programs.
NOTE: State MPI programs should not include any sampling activities (e.g., generic E.
coli) conducted by establishments in the narratives.
State MPI programs need to submit documentation that the verification sampling
programs, as described in the narrative, have been implemented and have been
functioning as intended over the last 12 months. Documentation should include factual
information on the State’s ability to maintain its program for the next 12 months. State
MPI program officials report laboratory sample results per sample project in an easy-toread format of the State MPI Program Sampling Activity Table (Attachment 4, page 5051).
To be considered “at least equal to” FSIS’s Federal inspection program in its
verification sampling program, at a minimum, the State MPI sampling program needs to
include the following criteria:
•
Sampling Project Eligibility – State MPI programs consider product risk, product
class, the product’s intended use, and production volume when determining the
eligibility for each sampling project. State programs are to include the criteria for
determining the scope of sampling, including the frequency of scheduled
samples on an average basis per year across all applicable State inspected
establishments.
•
Sample Result Analysis – State MPI programs analyze sample results for trends
(e.g., samples collected but not analyzed, increased positive test results, and
product non-availability for sample collection) that may influence program
inspection activities.
•
Response Plan for Positive Test Results – State MPI programs have action plans
for responding to positive results, including actions taken by the State MPI
program to recall product (See Component 6) and prevent adulterated product
from entering commerce.
•
Sampling Project Adaptability – The State MPI program’s sampling verification
projects should be adaptable to keep pace with changes, such as emerging
Page 45
pathogens, new products and processes, new or revised policies, and new
laboratory analytical methods.
By August 1st of each year, FSIS provides State MPI programs with guidance on
minimum testing frequencies for small and very small establishments.
State MPI programs need to maintain a verification testing program, with laboratory
capacity, to address food safety (e.g., adulterants) and other regulatory requirements
(e.g., standards of identity, species identification).
The verification program needs to include more specific criteria for routine analysis for
the following product classes:
Raw Product
•
•
Adulterant
•
Shiga toxin-producing Eschericia coli (STEC) in non-intact beef or intact
product used to produce non-intact beef
•
Violative chemical compound residues (e.g., antibiotic drugs, pesticides,
etc.)
Measure of food-safety system process control
•
Pathogen reduction performance standards for Salmonella in certain raw
meat and poultry products.
•
Pathogen reduction performance standards for Campylobacter in certain
raw poultry products.
Ready-to-eat (RTE) product
•
Adulterant
•
Salmonella in meat and poultry products
•
Listeria monocytogenes in meat and poultry products
NOTE: Listeria monocytogenes is also a food-contact-surface and environmental
contaminant associated with meat and poultry products. Thus, the sampling project
(e.g., routine Listeria monocytogenes (RLm) sampling project) needs to address the
post-lethality environment in which RTE products are produced.
State MPI programs need to have the capability to conduct the following analyses as
needed:
Raw and ready-to-eat (RTE) product
•
Adulterant
Page 46
•
•
Unexpected biological, chemical, or physical hazards sufficient to cause
illness (e.g., allergens)
Misbranding
•
Significant nutrition labeling deviations
•
Central nervous system tissue in boneless meat derived from advanced
meat recovery systems
•
Species not identified on the label
NOTE: It is not expected that the State MPI programs have a special laboratory for
atypical analyses (e.g., bovine tuberculosis), but rather, that the State MPI program be
able to procure atypical analyses when needed.
Outcome
When objectively reviewed by FSIS, the State MPI Program is determined to be “at
least equal to” the Federal inspection system.
The State MPI program has a system for preventing products adulterated with
pathogenic bacteria or violative residues from reaching the public through reliable and
timely laboratory analyses of samples.
“At least equal to” requirements
State MPI programs should maintain a system for periodic verification of each State
inspected establishment’s food-safety system.
NOTE: State MPI program Directors are to submit the data integrity information for the
data collected and maintained in a system elected in place of PHIS. The data collected
may include State laboratory or contract laboratory sample test results. The data
integrity information should include:
•
The type of data maintained in the State MPI program system elected in place of
PHIS (e.g., FSAs, custom exempt reviews, NOIEs).
•
How the State MPI program’s data integrity is maintained (e.g., restriction to
access the data, ability to track data changes).
•
The State law or administrative rule governing the security and integrity
preservation of meat and poultry inspection program records.
Objective
To verify the effectiveness of each State inspected meat and poultry establishment’s
food-safety system to ensure that only safe, wholesome, not adulterated, properly
marked, labeled and packaged meat and poultry products enter commerce.
Page 47
Verification Sampling Methods and Procedures
State MPI programs need to apply verification sampling methods that are “at least equal
to” those of FSIS’s Federal inspection program. At a minimum, to “be at least equal”
verification sampling program methods need to:
•
Create sampling frequencies based on product risk, product type, production
volume, time of year, product availability, etc.
•
Ensure current sampling projects include all State inspected establishments
producing eligible products (e.g., raw beef non-intact, RTE post-lethality exposed
(see 9 CFR 430))
•
Ensure current sampling projects include all State inspected establishments
slaughtering eligible livestock and poultry classes and use the Kidney Inhibition
Swab (KIS™) test to screen for violative drug residues in applicable livestock
NOTE: The KIS™ test can detect residues for Tilmicosin, Tulathromycin, Bacitracin,
Penicillin G, Neomycin, and Sulfonamide.
•
Respond to public health concerns associated with products that test positive for
adulterants (e.g., increase inspection activity, perform “for cause” FSA, conduct
Intensified Verification Testing (IVT), initiate product recalls)
•
Respond to performance standard failures (e.g., based on Salmonella
Performance Standards, Campylobacter Performance Standards)
•
Analyze sample results for trends (e.g., samples collected but not analyzed,
increased positives results, product not available for sample collection)
•
Respond to adverse trends (e.g., adapting sample frequency, evaluate State
inspection program personnel (IPP) understanding of sample collection)
•
Obtain serotype and Pulse-Field Gel Electrophoresis (PFGE) patterns of positive
pathogens (partner with FSIS)
•
Assess whether sampling activities successfully meet the State MPI program
management’s expectation for:
•
Creating sampling frequencies
•
Sampling eligibility
•
Responding to positive sampling results
•
Managing positive pathogen results
•
State IPP competency
Evidence of System Application
Page 48
A State MPI program needs to provide evidence that demonstrates implementation of a
verification sampling program that is “at least equal to” FSIS’s Federal inspection
program. At a minimum, State MPI programs should submit:
•
A list of applicable sampling projects that identify the target agent (microbial or
chemical), eligible establishments, projected sampling frequency, actual samples
analyzed, and the number of positive or violative samples
•
Completed tracking log showing the scheduling and collection of samples per
project (both microbiological and chemical)
•
Laboratory results (e.g., completed lab forms)
•
Documentation verifying how sample integrity is maintained (e.g., use of sample
seals)
•
Directed and inspector generated residue sampling and results
•
Follow-up actions to positive results (e.g., recall actions, “for cause” FSA, IVT,
administrative enforcement)
The information can be submitted using the table below or in another format.
Page 49
Attachment 4
State MPI Program Sampling Activity Table
(Suggested Format)
Name of State Agency:
Microbial and Residue Sampling
Sampling Dates Covered:
Number of
ESTs
Eligible for
Sampling
Number
Samples
Targeted per
EST (Intended
*
Frequency)
Number of
Samples
Actually
Requested
Program wide
Number of
Viable
Samples
Analyzed per
Program
wide
Number of
Confirmed
Positives
Program
wide
E. coli O157:H7 in raw ground beef
and Salmonella (MT43)
E. coli O157:H7 and Non-O157
STEC (O26, O45, O103, O111,
O121, O145) in raw beef trimmings
(MT60)
E. coli O157:H7 in components
other than trim (MT64)
E. coli O157:H7 in raw beef bench
trim (MT65)
**
MT 44 – Follow-up Testing for E.
coli O157:H7 in Response to
Ground Beef Positive Results
(MT43)
**
MT 52 – Testing of Beef
Manufacturing Trimmings or Other
Components from Originating
Slaughter Suppliers(Based on a
Positive Result (MT43))
**
MT 53 – Follow-up Testing in
Response to Positive Beef
Manufacturing Trimmings Results
(MT52 or MT60)
Listeria monocytogenes and
Salmonella in RTE products not due
to risk (RTEPROD- random)
Listeria monocytogenes and
Salmonella in RTE products – risk
based post-lethality exposed RTE
products (RTEPROD- risk)
Listeria monocytogenes in RTE
products – risk based per 9 CFR
430 (RLm)
Listeria monocytogenes in RTE
products – risk based per 9 CFR
**
430 (IVT )
Page 50
Salmonella in RTE products – risk
**
based per 9 CFR 430 (IVT )
Microbial and Residue Sampling
# ESTs
Eligible for
Sampling
# Samples
Targeted per
EST (Intended
*
Frequency)
# Samples
Actually
Requested
Program wide
# Viable
Samples
Analyzed per
Program
wide
#
Confirmed
Positives
Program
wide
Salmonella in Young Chicken
Salmonella in Young Turkey
Salmonella in comminuted Chicken
Salmonella in comminuted Turkey
Campylobacter in Young Chicken
Campylobacter in Young Turkey
Campylobacter in Ground Chicken
Campylobacter in Ground Turkey
Salmonella in raw Ground Beef
(HC01)
Residue Directed
Residue inspector Generated
Food Chemistry
Other
*
st
By August 1 of each year, FSIS will provide the Guidance to States on Frequency of Microbiological
Testing to identify the minimum testing frequencies for small and very small establishments.
**
Complete for State MPI program follow-up testing as a result of a positive sample.
Names and addresses of all laboratories used: (attach additional sheets if needed)
Name:
Address:
Phone number:
Page 51
Component 4: Staffing,
Training, and Supervision
Criteria for “at least equal to” Determination
Each State MPI program needs to submit a current narrative describing the personnel
management system used to staff State-inspected establishments, the training of State
inspection program personnel, and the supervision of inspection and compliance
enforcement activities.
State MPI programs need to submit any supporting documentation (preferably
completed reports and documents) to show the system, as described in the narrative,
has been implemented, is functioning as intended, and that the State MPI program
remains “at least equal to” FSIS’s Federal inspection program requirements for the next
12 months. State MPI program officials report the number of State-inspected
establishments and number of State personnel performing duties, States can use the
format of the State MPI Program Establishment Count (Attachment 5, page 59) and
State MPI Program Employee Primary Roles (Attachment 6, page 60).
State MPI programs are required to be “at least equal to” FSIS’s Federal inspection
program. The Staffing, Training, and Supervision system at a minimum need to include
the following criteria:
•
Daily Inspection Coverage – State MPI programs provide and maintain
inspection coverage at State inspected meat and poultry establishments every
day the State inspection marks are applied to products; at least once per shift at
processing establishments and inspection on the line during all slaughter
operations.
•
Employee Training – State MPI programs provide MPI employees with sufficient
knowledge, skills, and training that provide them with the ability to carry out State
meat and poultry inspection and compliance enforcement duties in a manner that
is “at least equal to” FSIS’s Federal inspection program.
•
Supervision – State MPI programs provide direction to daily State inspection and
compliance enforcement activities performed by State MPI program personnel.
Outcome
When objectively reviewed by FSIS, the State MPI program is determined to be “at least
equal to” FSIS’s Federal inspection program in its staffing, training, and supervision
systems.
The State MPI program needs to have:
•
State inspectors that perform inspection activities at State inspected meat and
poultry establishments, as required by State laws to ensure only safe,
wholesome, not adulterated, properly marked, labeled and packaged meat and
poultry products receive the State mark of inspection.
Page 52
•
Trained State inspection program personnel capable of applying State MPI
program methods and procedures in accordance with applicable State laws,
regulations and directives, and are capable of making sound decisions based
upon facts and evidence.
•
State MPI program managers and supervisors who can objectively evaluate the
effectiveness of implemented program systems and competency MPI of State
MPI program personnel
“At least equal to” Requirements
The State MPI program needs to maintain:
•
A Staffing System,
•
A Training Program, and
•
A Supervisory System.
NOTE: State MPI program Directors need to submit the data integrity information for the
data collected and maintained in a system used in place of PHIS. The data integrity
information should include:
•
The type of data maintained in the system used in place of PHIS (e.g., FSAs,
custom exempt reviews, NOIEs).
•
How the data integrity is maintained (e.g., restriction to access the data, ability to
track data changes).
•
The State law or administrative rules governing the security and integrity
preservation of meat and poultry inspection program records.
Staffing System
The State MPI program needs to maintain a staffing system which periodically assesses
the State’s personnel needs required to meet the organizational objectives and public
health goals. As priorities and needs shift, the State MPI program should be capable of
considering changing factors when creating inspection assignments. State MPI
programs also should be able to modify staffing policies to accommodate inspection
demands of State inspected meat and poultry facilities without compromising the State
MPI program’s staffing objectives.
Objective
To provide daily inspection coverage at State meat and poultry establishments to
ensure that only safe, wholesome, not adulterated, properly marked, labeled and
packaged meat and poultry products receive the State mark of inspection.
Page 53
Staffing System methods and procedures
State MPI programs need to implement staffing methods “at least equal to” those of
FSIS’s Federal inspection program. Staffing methods and procedures at a minimum
should include:
•
Methods to determine the workload (e.g., complexity of State inspected
establishment operations, distances between establishments, availability of
inspection personnel) of inspection assignments (i.e., single establishment, multiestablishment assignments) and ensure daily inspection coverage is provided at
all establishments producing products under the marks of inspection
•
Methods to verify inspectors perform required inspection activities on the
scheduled inspection days:
•
•
Procedure to analyze staffing data for trends in missed inspections
•
Procedure to verify regulatory compliance at an establishment that applies
marks of inspection to products on a day when State MPI program
personnel miss a scheduled inspection
•
Procedure for providing inspection services (i.e., relief coverage) at an
establishment when the assigned inspector is absent from duties
Methods to assess whether staffing successfully meets the State MPI program
management’s expectation for:
•
Creating State inspection assignments
•
Verifying performance of scheduled and missed State inspection activities
•
Scheduling relief coverage for State inspection assignments
Evidence of System Application
A State MPI program needs to provide evidence to demonstrate the implementation of a
State staffing system that is “at least equal to” that of FSIS’s Federal inspection
program. At a minimum, the State MPI program should submit:
•
State staffing documentation (e.g., calendars, inspection activity logs, daily
inspection assignments) to support they maintain inspection coverage on each
shift at each State inspected establishment on days when the marks of
inspection are being applied to products. The documentation should identify any
changes made to inspection assignments to accommodate for annual and
emergency leave taken.
Page 54
•
Follow-up documents confirming food safety requirements are met at State
inspected establishments on days when products receiving the marks of
inspection are produced and the State MPI program is unable to provide
inspection services
•
Information regarding the number and types of State inspected establishments
currently operating under the State MPI program in a plain language format (see
the suggested table, State Establishment Count, at the end of this section)
•
Information identifying, by job description, the number of State employees who
currently perform duties for the State MPI program in a plain language format
(see the suggested table, State MPI Employee Primary Roles, at the end of this
section)
•
A current organization chart identifying all State personnel who carry out aspects
of the State meat and poultry inspection at all program levels. The State
organization chart should include any personnel who are employed by other
State programs outside of the State MPI program to assist in accomplishing their
mission. In addition, the organizational chart should show supervisory
boundaries and reporting lines of all State personnel involved. The submission
of an organizational chart can provide the FSIS audit team with a clear
understanding of how each State MPI program carries out its daily operational
and administrative functions.
Training Program
Training and development of employees are key elements to the success of any
organization. FSIS invests a considerable amount of time and resources in improving
the skills of their workforce. State MPI programs need to have a State program in place
to meet the training and development needs of their employees in a manner that is
comparable to FSIS’s Federal inspection program.
Objective
To provide the necessary knowledge, skills, and abilities, through formal and informal
training, to ensure personnel can successfully complete inspection and other critical job
duties.
Training System
The training system should include methods that provide State MPI program employees
with both formal and informal learning experiences that contribute to individual growth
and improved performance in their assigned positions. Formal training courses should
be developed to provide employees with sufficient knowledge, skills, and the ability to
carry out State meat and poultry inspection or enforcement duties in a manner that is “at
least equal to” FSIS’s Federal inspection program. The training methods and
procedures at a minimum should address:
Page 55
•
Inexperienced and newly hired employees in performing the specific job positions
of the State MPI program
•
Ongoing professional and skill development for current employees (e.g., AgLearn
courses, field workshops, professional conferences, on-the-job training)
•
Core inspection activities (e.g., ante-mortem inspection, humane handling, postmortem inspection, pathogen reduction/HACCP, Sanitation SOPs, Sanitation
Performance Standards, Inspection Methods)
•
Core compliance enforcement activities (e.g., surveillance, follow-up surveillance,
investigation, evidence collection, case development, compliance sample
collection)
•
Training needs of all State employees who perform MPI program related duties
•
Testing criteria used to determine if employees have mastered the objectives and
concepts of training courses
•
Standards for evaluating the competency of State MPI program trainers
•
Techniques for determining whether training activities meet the State MPI
program management’s expectations for:
•
Newly hired and inexperienced employees
•
Experienced employees
•
Core inspection activities
•
Core compliance enforcement activities
•
Assessment of training needs for all State MPI program employees
Evidence of system application
A State MPI program needs to provide evidence that demonstrates implementation of a
training system “at least equal to” FSIS’s Federal inspection program. At a minimum,
the State MPI program should submit:
•
A list of training courses offered to State MPI program personnel
•
Training certificates for employees’ training completed within the last 12 months
•
Tracking logs (e.g., personnel, training class, circuit)
•
Management’s evaluation and results of State training system performance
Supervisory System
A State MPI program needs to maintain a State supervisory system that aligns
individual work with its public health and regulatory goals, and ensures recognition of
strong performance and correction of unsatisfactory performance. State MPI program
managers should adopt or create policies that encourage employee development and
strengthen workforce competency.
Page 56
Objective
To implement an effective State MPI inspection program, the program managers should
establish and effectively communicate clear and measurable employee performance
standards, analyze performance results and trends, provide unbiased feedback to
assess individual performance, and manage resources.
Supervisory Methods and Procedures
State MPI programs need to implement supervisory methods “at least equal to” those of
FSIS’s Federal inspection program to ensure effective implementation of the program’s
public health and regulatory obligations. The supervisory methods and procedures at a
minimum should include:
•
Methods and procedures used in developing policies for the State MPI program’s
critical inspection and compliance activities:
•
Methods and procedures to draft and distribute policies in a timely manner
to all State MPI program personnel
•
Methods and procedures to assess FSIS issuances (i.e., FSIS Directives,
Notices, and Compliance Guidelines) for applicability to the State MPI
program
•
Methods and procedures to evaluate job performance and competency of State
MPI program personnel during their probationary periods (if applicable)
•
Methods and procedures to evaluate job performance and competency of all
State MPI program personnel to verify all State MPI program policies are
implemented (e.g., IPPS, OPPS, annual performance appraisals)
•
Methods and procedures to measure and analyze implementation of new and
existing State MPI program policies and instructional documents for inspection
and compliance activities
•
Techniques for determining whether State supervisory activities meet the State
MPI program management’s expectation for:
•
Distribution and implementation of State MPI program policies
•
Employee performance feedback
Evidence of System Application
A State MPI program needs to provide evidence that demonstrates the implementation
of supervisory methods and procedures “at least equal to” FSIS’s Federal inspection
program requirements. At a minimum, the State MPI program needs to submit:
•
Letters, instructions, memoranda of interview or data tracking logs documenting
the distribution and implementation of State MPI program policies regarding
critical inspection and compliance enforcement activities
Page 57
•
Completed evaluations of performance standards and results of trend analyses
(i.e., reasons why policies are not effectively implemented by State IPP)
Completed performance and competency evaluation documents (redacted if
necessary) for program employees (e.g., annual performance appraisals, IPPS
reviews) States may use the tables below to submit this information.
Page 58
Attachment 5
State MPI Program Establishment Count
Suggested Format
Name of State Agency:
Instruction
Number of State
Inspected
Establishments
As of Date:
In the section below, list each establishment only once. If the establishment
performs multiple processes, identify the best category that encompasses all the
establishment processes.
Combination
Establishment
Slaughter
Processing
TOTAL
Slaughter and
Type
Only
Only
Processing
Meat Only
Poultry Only
Combination Meat
and Poultry
TOTAL
Number of
Exempt
Establishments
Meat Only
Poultry Only
Combination Meat
and Poultry
TOTAL
Number of CIS,
TA, or CU
Establishments
Meat Only
Poultry Only
Combination Meat
and Poultry
TOTAL
Remarks:
Page 59
Attachment 6
State MPI Employee Primary Roles
Suggested Format
Name of State Agency:
As of Date:
# State MPI employees
Instruction
Headquarters/
Central Office
Circuit/Area/
District/Etc.
In the section below, list each employee only once. If the employee has multiple
roles, identify the employee under their primary role only and provide details of
additional roles in the adjacent comment box.
Employee Roles
Full
Part
Comments
time
time
Managers
Administrative
EIAOs
VMO/PHVs
Other
Field Supervisors
VMO/PHVs
Other
In-Plant State
Inspection
VMO/PHVs
Inspectors
Relief
Other
CIS, CU, or TA
Inspection
VMO/PHVs
Inspectors
Relief
Other
Compliance Program
Total:
Managers
Compliance Officers
Other
Remarks:
Page 60
Component 5: Humane
Handling
Criteria for “at least equal to” Determination
Each State MPI program needs to submit a current narrative describing the State
verification system used to enforce all applicable laws, regulations, and FSIS policies.
The system should have the capability to correct any deviations from regulatory
requirements that may affect its program being “at least equal to” FSIS’s Federal
inspection program in its humane treatment of animals.
State MPI programs should submit supporting documentation (e.g. completed reports
and documents) to show the State verification system (as described in the narrative,
has been implemented) is functioning as intended, and ensures that the State MPI
program remains “at least equal to” FSIS’s Federal inspection program over the next 12
months.
State verification methods and procedures provided under a State MPI program are “at
least equal to” the FMIA, PPIA, HMSA, FSIS Directives and Notices, Federal Register
publications, regulations, and other applicable policies provided under FSIS’s Federal
inspection program in its humane treatment of animals and good commercial practices
with poultry. At a minimum, the humane handling system should include the following
criteria:
•
Humane Slaughter – A State MPI program verifies all livestock are slaughtered in
accordance with one of two humane methods specified in the HMSA or
applicable State laws.
•
•
•
The first humane method requires that livestock be rendered insensible to
pain on the first application of the stunning device before being shackled,
hoisted, cast, or cut.
The second humane method is in accordance with the ritual requirements of
any religious faith that prescribes a method of slaughter where the animal
suffers loss of consciousness by anemia of the brain caused by the
simultaneous and instantaneous severance of the carotid arteries with a
sharp instrument.
In addition, State IPP are to verify State inspected establishments that slaughter
poultry follow good commercial practices described in 9 CFR 381.
Outcome
When objectively reviewed by FSIS, the State MPI program is determined to be “at least
equal to” FSIS’s Federal inspection program in its humane treatment of animals.
A State MPI program has capabilities to ensure State inspected establishments
humanely handle all livestock presented for slaughter and follow good commercial
practices when poultry are slaughtered and processed on premises.
Page 61
“At least equal to” Requirements
The State MPI program is required to maintain
•
A Humane Handling Verification System.
NOTE: State MPI program Directors need to submit data integrity information for the
data collected and maintained in a system elected in place of PHIS. The data integrity
information should include:
•
The type of data maintained in the elected data system in place of PHIS (e.g.,
FSAs, custom exempt reviews, NOIEs
•
How the data integrity is maintained (e.g., restriction to access the data, ability to
track data changes)
•
The State law or administrative rule governing the security and integrity
preservation of State meat and poultry inspection program records
Objective
To implement State verification activities that ensure State inspected establishments are
humanely handing all livestock when presented for slaughter, follow good commercial
practices when poultry are slaughtered, and comply with applicable State laws, rules,
and policies.
Humane Handling Verification System methods and procedures
State MPI programs need to implement State slaughter verification methods and
procedures “at least equal to” those of FSIS’s Federal inspection program in the
humane treatment and handling of animals and good commercial practices with poultry.
The methods and procedures at a minimum should include:
•
Methods to schedule and record humane handling tasks, and document
noncompliance with the requirements consistent with 9 CFR 313
•
Procedures to verify whether State inspected establishment personnel humanely
handle all livestock presented for slaughter throughout the time they are on
establishment premises
•
Methods to conduct and document humane handling verification reviews (e.g.,
District Veterinary Medical Specialist (DVMS) reviews) at livestock
establishments and conduct poultry good commercial practices reviews at poultry
establishments
•
Methods to assess whether slaughter verification activities successfully meet the
State MPI program management’s expectation for:
•
In-Plant Level Slaughter Verifications
•
Humane handling
Page 62
•
Good commercial practices
•
Noncompliance regulatory documentation
•
Enforcement actions
•
Central Office Level Assessments
•
Humane handling oversight
•
Administrative case development
•
Program personnel competency
Evidence of System Application
A State MPI program needs to provide evidence that demonstrates the implementation
of a slaughter verification system “at least equal to” FSIS’s Federal inspection program
in the humane treatment and handling of animals and good commercial practices with
poultry. At a minimum, the State MPI program should submit:
•
Documentation of regulatory control, withholding, suspension, enforcement, or
administrative actions taken when humane handling noncompliance is identified
(e.g., NRs, 30 day letters, NOIE Letters, Suspension letters, notification to
withhold the marks of inspection)
•
Humane handling verification reviews (e.g., DVMS analogous reports, in-depth
supervisory establishment reviews)
•
Management’s evaluation and results of humane handling verification system
performance
Page 63
Component 6: Compliance
Criteria for “at least equal to” Determination
Each State MPI program needs to submit a narrative describing the State’s compliance
system used to enforce all applicable laws, regulations, and FSIS policies, and takes
appropriate enforcement action in the event that misbranded or adulterated product is
identified in commerce.
The US Code Title 21, Sections 643, 644, 645 and 460 require businesses to register
with the Secretary of Agriculture. FSIS compliance conducts surveillance reviews at
these registered firms which may lead to investigations and enforcement actions.
Under 21 U.S.C. 661 and 454, FSIS expects the States to impose “at least equal to”
FSIS’s Federal inspection program assurances that affected individuals, firms, and
corporations are complying with applicable State statutes when producing, transporting,
storing, and distributing meat and poultry products in intrastate commerce. The State
MPI program’s narrative should address and cite the State MPI program’s statutory
authority for performing surveillance reviews, investigations, and taking enforcement
actions at the following business types:
Distributors
3D/4D operators
Institutions
Warehouses
Salvages
Restaurants
Food banks
Animal food
Retailers
Brokers
Renderers
Transporters
Exempt poultry
If the State MPI program is not granted statutory authority under State law to review,
investigate, or take enforcement actions for any of the business types above, the
narrative should identify the State agency with the State’s statutory authority and cite
the applicable statute. The narrative should also describe how the State MPI program
cooperates with the authorized State agency when meat and poultry products are
involved in the surveillance reviews, investigations, and enforcement actions. State MPI
program officials may provide the narrative information in the plain language format of
the Summary of Statutory Authority per Business Type, (Attachment 7, page 69) or
another format. FSIS identifies the State MPI program as the State Agency responsible
for coordinating with other State agencies to ensure all applicable compliance activities
outlined in the guidelines comply with specified laws, regulations, and policies. This
includes State or contract laboratories, health departments, law enforcement, State
human resources division, and other State regulatory agencies.
State MPI programs need to submit supporting documentation to demonstrate the
compliance system, as described in the narrative, has been implemented and is
functioning as intended, to ensure that the State MPI program remains “at least equal
to” FSIS’s Federal inspection program in its compliance activities over the next 12
months. State MPI program officials may provide a report on compliance activities in a
Page 64
plain language format of the Compliance Activity Report (Attachment 8, page 70) or in
another format.
State MPI programs are “at least equal to” the Federal inspection program in its
compliance system activities. Compliance system activities need to include the
following criteria:
•
Surveillance – State MPI compliance investigators conduct surveillance of
persons, firms, and corporations operating in intrastate commerce who are
subject to the provisions of the FMIA, PPIA, HMSA, 9 CFR, or State laws as
applicable.
•
Investigation - State MPI compliance investigators conduct investigations of
apparent violations, food safety incidents, or other allegations or incidents using
the FMIA, PPIA, HMSA, 9 CFR, or State laws as applicable.
•
Product Control Action - State MPI compliance investigators take appropriate
control of product found in intrastate commerce that may be adulterated,
misbranded, or has not received the mark of inspection, and ensure proper
disposition of such product (e.g., detention, seizure, condemnation, destruction).
•
Case Development and Referral – The State MPI compliance program is to
include case development and referral mechanisms to take criminal, civil, and
administrative enforcement actions, including sanctions, when firms and
individuals violate Federal and State statutes. The State MPI compliance
program recommends cases of criminal and civil violations for prosecution by the
State legal system, or refers them to USDA, FSIS, OIEA, and CID for action.
Outcome
When objectively reviewed by FSIS, the State MPI program is determined to be “at least
equal to” FSIS’s Federal inspection program in its compliance activities.
The State MPI program has:
•
Assurances that affected individuals, firms, and corporations are complying with
applicable State statutes or the Federal Acts when producing, transporting,
storing, and distributing meat and poultry products in intrastate commerce
•
Documentation of surveillance activities, investigations, and enforcement actions
(i.e., including sample collection that supports administrative, civil or criminal
actions imposed against individuals or firms that have violated the State’s laws)
“At least equal to” Requirements
The State MPI program is expected to maintain:
•
A Compliance System
Page 65
NOTE: State MPI program Directors need to submit the data integrity information for the
data collected and maintained in a system elected in place of PHIS. The data integrity
information should include:
•
The type of data maintained in a State compliance system elected in place of
PHIS (e.g., Review and Compliance Records, LOW, ROIs, physical evidence).
•
Where the State compliance data is stored (e.g., server name, name of SharePoint or
share drive, hard copy file cabinet).
•
How the State compliance data integrity is maintained (e.g., restriction to access the
data, ability to track data changes).
•
The State law or administrative rule governing the security and integrity
preservation of meat and poultry inspection program records.
Compliance System
The State MPI program needs to maintain a compliance system to investigate violations
of food safety, food defense, and other consumer protection statutory requirements, and
controls unsafe or violative products through detentions, seizures, and voluntary recalls.
State MPI program managers should create or adopt State compliance policies for
conducting surveillance and investigation activities, and the development of cases to
ensure the imposition of criminal, administrative, and civil enforcement actions are in
accordance with State laws.
Objective
To ensure State MPI program’s compliance activities are carried out in accordance with
applicable State laws, rules and policies, ensuring all State inspected meat and poultry
products found in intrastate commerce are safe, wholesome, not adulterated, properly
marked, labeled and packaged and all enforcement actions imposed are legally
supported.
Compliance Methods and Procedures
State MPI programs need to implement compliance methods “at least equal to” those of
FSIS’s Federal inspection program’s compliance activities. The compliance methods
and procedures should include:
•
Methods for conducting State surveillance and follow-up surveillance of
individuals, firms and corporations operating in intrastate commerce subject to
State laws, regulations and policies pertaining to meat and poultry inspection
program
•
Procedures to prioritize State surveillance resources on intrastate
commerce businesses with the highest public health risk
Page 66
•
•
•
Procedures to determine the collection of raw ground beef samples for E.
coli O157:H7 testing as part of the intrastate commerce surveillance
activities at retail stores
Methods for conducting investigations of apparent violations, food safety
incidents, other allegations or incidents subject to State laws, rules, and policies
pertaining to the State meat and poultry inspection program
•
Procedures for State MPI program compliance investigators to collect,
safeguard, and dispose of evidence in the performance of surveillance,
investigations and other activities subject to the State laws, rules, and
policies pertaining to the State MPI program
•
Procedures for State MPI program compliance investigators to follow
when detaining or in preparation for seizing meat and poultry products
found in intrastate commerce, when there is reason to believe that the
products are adulterated or misbranded
Methods for preparing a report (e.g., Report of Investigation (ROI)) to support
findings of apparent violations, food safety incidents, or other allegations subject
to the applicable State laws
•
Procedures for the evaluation of case documents to support appropriate
criminal, civil, or administrative enforcement actions (e.g., letters of
warning, consent orders, fines, penalties, hearings)
•
Methods for the State MPI program to determine whether to recommend a
product recall
•
Methods for documenting, prioritizing, and investigating consumer complaints
directly related to State inspected meat and poultry products
•
Methods to assess whether compliance activities successfully meet the State
MPI program management’s expectation for:
•
Surveillance
•
Investigation
•
Documentation and reports
•
Product recall
•
Consumer complaints
•
Compliance personnel competency
Evidence of System Application
A State MPI program needs to provide evidence demonstrating the implementation of a
compliance system that is “at least equal to” FSIS’s Federal inspection program in its
compliance activities. The State MPI program should submit:
•
Documentation and tracking logs for surveillance and follow-up surveillance
activities of State MPI program compliance officers
Page 67
•
Retail and investigative product sample results
•
Complete case files that include reports of investigation, evidence collected,
notices of detention, notices of seizure, letters of warning, fines, consent orders,
and documentation from legal proceedings.
•
Evidence preservation and chain of custody verification documents
•
Recall effectiveness checks, public notification of recalls, and other related
documentation
•
Documentation and tracking logs for consumer complaints
•
Documentation and communications for surveillance reviews, investigations, and
enforcement actions for the business types where the State MPI program is not
granted statutory authority
•
Management’s evaluation and results of compliance system performance
States can use the tables below to provide this information.
Page 68
Attachment 7
State MPI Program
Summary of Statutory Authority per Business Type
Suggested Format
Name of State Agency:
Instruction:
Time Period Covered:
List the State agency or program that is granted statutory authority to review, investigate,
or take enforcement actions for the business types listed. Cite the applicable statute that
grants that authority, and describe how the State MPI Program cooperates with the
authorized agency.
(E.G., a State MPI program may not have authority at retail stores in the State because
another State agency has the authority). The State MPI program should provide in this
chart the applicable laws State laws and the name of the State agency that has the
authority to enforce the laws.
Business Type
State Agency Granted
Authority and Statutory
Citation
State MPI Program Cooperation with the
Authorized Agency (if applicable)
Distributors
Warehouses
Transporters
3D/4D operators
Salvages
Renderers
Food banks
Exempt poultry
Restaurants
Retailers
Institutions
Animal food
Brokers
Remarks:
Page 69
Attachment 8
Compliance Activity Report
Suggested Format
Name of State Agency:
Time Period Covered:
Compliance Activities
TOTAL NUMBER
Surveillance per FSIS Directive 8010.1
Distributors, Warehouses, and Transporters
3D/4D Operators, Salvages, Renderers, Food Banks, and Exempt Poultry
Restaurants, Retailers, Institutions, Animal Food, Custom Exempt, Abattoir,
Processor, Port-of-Entry, Bonded Area, Broker, and Miscellaneous
Surveillance Follow-ups
Violation Cases or Investigations
Referrals to FSIS
Letters of Warning
Administrative Hearings
Consent Orders
Court Actions or Prosecutions
Consumer Complaints
State Recalls
Effectiveness Checks
Registrations of Meat and Poultry Handlers
Miscellaneous Actions / Special Projects / Personal Contacts (Please itemize)
Detentions
Number of Detentions
Pounds of Product Detained
TOTAL
NUMBER
Laboratory
TOTAL
NUMBER
Retail Ground Beef samples per FSIS
Directive 8010.1
Investigative Samples (other than
retail ground beef)
Pounds of Product Released
Pounds of Product Donated
Pounds of Product Condemned
Pounds of Product Voluntarily
Destroyed
Remarks:
Page 70
Component 7: Laboratory
Methods and Quality
Assurance Program
Criteria for “at least equal to” Determination
State MPI programs need to have product sampling and laboratory methods with
capabilities and safeguards that are “at least equal to” FSIS’s Federal inspection
program’s product sampling and laboratory methods. State MPI programs should
update and maintain their laboratory microbiological and chemical detection methods so
they are “at least equal to” FSIS’s Federal inspection program methods as detailed in
the FSIS Microbiology Laboratory Guidebook.
To achieve and maintain “at least equal to” laboratory methods, each State MPI
program should meet the criteria in the following areas:
•
•
Laboratory Quality Assurance programs
Laboratory Testing Methods
Outcome
When objectively reviewed by FSIS, the State MPI program is determined to be “at least
equal to” FSIS’s Federal inspection program in Laboratory methods.
FSIS integrates ongoing documents and on-site reviews of the applicable analytical
methods in its annual comprehensive review of State MPI programs. FSIS determines
if a participating State MPI testing program is “at least equal to” the corresponding FSIS
Laboratory testing program.
“At least equal to” Requirements
Sampling methods need to provide analytical results “at least equal to” corresponding
FSIS testing programs. Each State MPI program should provide documentation
through self-assessment and on-site review to demonstrate that its program includes
the following:
1. Laboratory Quality Assurance (QA) Programs
State MPI program laboratories, or contract laboratories, should have an appropriate
QA program “at least equal to” the methods of FSIS’s laboratories to ensure the
reliability and integrity of analytical results. State MPI program laboratories, or contract
laboratories, should ensure that each laboratory meets the criteria outlined in the FSIS
MPI Program Laboratory Quality Management System Checklist.
A laboratory QA program assessment consists of the following:
•
Assurances for sample integrity and identity. Laboratories that analyze samples
for State MPI programs maintain procedures to ensure that samples are not
compromised within the laboratory. These procedures include a documented
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chain of custody as well as traceability to the sample, equipment, and critical
supplies used to analyze the sample.
•
Demonstrated confidence in test results and an assurance that it does not resample or re-test pathogen-positive and non-compliant products
•
Documented program of quality control procedures and an assurance that these
procedures are followed
•
Properly trained personnel; suitable facilities and equipment; and verified,
calibrated, and maintained equipment in a manner consistent with international
norms (e.g., European co-operation for Accreditation (EA) 04/10 or Analytical
Laboratory Accreditation Criteria Committee (ALACC) guidance)
•
Appropriate proficiency testing schemes for food analysis
•
Use of validated method protocols
•
Reporting and recordkeeping capabilities that track and link a test result to the
correct establishment
2. Laboratory Testing Methods
Methods used in support of the State MPI program should be validated for the product
type sampled and are to be “at least equal to” FSIS’s laboratory requirements. State
MPI programs should provide documentation necessary to explain the methods used
and the scientific basis for their selection. Such documentation should include detailed
testing method protocols, supplemental testing procedures, and evidence of method
validation and sustained proficiency testing for microbiology methods and sustained
proficiency testing for chemistry methods. Evidence of analyst training in each subject
method should be provided. Method assessment by FSIS considers the following:
Microbiology
•
Methods of analysis are designed to detect the lowest possible level of stressed
pathogens from State inspected meat, poultry, and environmental samples in
accordance with current FSIS testing programs for each pathogen (e.g., the
method includes an enrichment step, adequate enrichment time, immunobead
capture step for E. coli)
•
Methods of analysis are validated through an experimental study. When
methods are modified, it may be necessary to conduct a supplemental validation
against a reference method (e.g., USDA FSIS Microbiology Laboratory
Guidebook (MLG), FDA Bacteriological Analytical Manual, or International
Organization for Standardization (ISO) Standards). For validation studies
conducted outside Association of Analytical Communities (AOAC), Association
Française de Normalisation (AFNOR), the French national organization for
standardization, or similar organizations, refer to FSIS Guidance for Test Kit
Manufacturers, Laboratories: Evaluating the Performance of Pathogen Test Kit
Methods at:
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http://www.fsis.usda.gov/wps/wcm/connect/966638c7-1931-471f-a79e4155ce461d65/Validation_Studies_Pathogen_Detection_Methods.pdf?MOD=AJ
PERES
•
Methods of analysis detect the same pathogens as the corresponding FSIS MLG
method. Alternative methods are inclusive for strains defined as positive by the
biochemical, genetic, and serological confirmation tests described in the FSIS
MLG.
•
Methods of analysis use appropriately-sized test portions or sampling
methodology and frequency for samples offering enhanced opportunity for
detecting foodborne pathogen contaminations. Information on the test portions
used for FSIS testing programs is available at the USDA FSIS Microbiology
Laboratory Guidebook website at the following link:
http://www.fsis.usda.gov/wps/portal/fsis/topics/science/laboratories-andprocedures/guidebooks-and-methods/microbiology-laboratoryguidebook/microbiology-laboratory-guidebook
•
Each method includes culture confirmation testing using a validated method. If
additional non-validated confirmatory tests are performed by the laboratory,
those tests are not be relied upon to invalidate the previous results.
•
Shipping enrichments to a second confirmatory laboratory is avoided.
FSIS guidance for evaluating microbiological testing methods are found in the
Establishment Guidance for the Selection of a Commercial or Private Microbiological
Testing Laboratory at the following link at:
http://www.fsis.usda.gov/wps/wcm/connect/464a4827-0c9a-4268-8651b417bb6bba51/Guidance-Selection-Commercial-Private-Microbiological-Testing-lab062013.pdf?MOD=AJPERES
Food Chemistry
•
Methods of analysis are capable of measuring food chemistry components as a
percentage of sample weight. Moisture, protein, fat, and salt are included. FSIS
conducts limited food chemistry analysis of products at official establishments
when in-plant inspection personnel believe the product is misbranded.
•
Acceptable methods of analysis are available on the USDA FSIS Chemistry
Laboratory Guidebook website at:
http://www.fsis.usda.gov/wps/portal/fsis/topics/science/laboratories-andprocedures/guidebooks-and-methods/chemistry-laboratory-guidebook/chemistrylaboratory-guidebook
•
AOAC Official Methods of Analysis for food chemistry are also acceptable.
•
Alternative methods for food chemistry analysis are acceptable if they measure
the same components with sufficient accuracy. Evidence to support the use of
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an alternative method includes proficiency-testing data generated by the State
MPI program laboratories or contract laboratories completing the analysis.
The FSIS Accredited Laboratory Program (ALP) provides proficiency-testing
services for food chemistry. For further information, visit the following link:
http://www.fsis.usda.gov/wps/portal/fsis/topics/science/laboratories-andprocedures/accredited-laboratories/accredited-laboratories
Residue
•
Information on in-plant screening of residues in meat and poultry products is
available at:
FSIS Directive 10,800.1, Residue Sampling, Testing and Other Verification
Procedures Under the National Residue Program For Meat and Poultry Products
NOTE: The results of laboratory analyses are reported simultaneously to the State MPI
program and the establishment.
Submission of Laboratory Methods and Quality Assurance Records
State MPI programs need to submit a list of current State laboratory and contract
laboratory test methods along with copies of new or revised methods of Standard
Operating Procedures (SOPs) on or before November 1 as part of the annual selfassessment submission process and whenever their methods are changed throughout
the year. Submission of revised test method SOPs should be submitted on the
Laboratory Method Notification Form available at:
FSIS Form 5720-15, Laboratory Method Notification Form
State MPI programs should submit a completed State Meat and Poultry Program
Laboratory Quality Management System Checklist form available at:
FSIS Form 5720-14 - State Meat and Poultry Inspection Program Laboratory
Quality Management System Checklist
NOTE: States may also submit the information on another easy to read format.
State and contract laboratories accredited to ISO 17025, with all applicable methods
under their scope of accreditation, should provide current certificates of accreditation
and only complete applicable portions of the QA checklist. They should also provide
the list of method SOPs along with any updated copies of methods new or revised since
the previous year’s submission.
The State MPI programs may contract with a laboratory that meets the same
requirements and are to ensure that the contract laboratory submits the same
documentation as described for State MPI program laboratories.
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In the submission, State MPI program Directors should divide the document
submissions into Microbiology methods, Chemistry methods, and QA records. All three
sections should be submitted electronically to the FSIS Outlook mailbox:
[email protected]
NOTE: The subject line for all submissions to the FSIS Outlook mailbox should contain
the name of the applicable State MPI program to allow efficient routing to assigned
FSIS personnel.
If hard copies need to be submitted, please mail them to the following address:
Director, USDA, FSIS, OPHS, Laboratory Quality Assurance Staff
950 College Station Road
Athens, Georgia 30605
On-Site Review of Laboratory Methods and Quality Assurance Records
The State MPI program laboratories and their contract laboratories are subject to
periodic record and on-site reviews by FSIS to evaluate the QA program in comparison
to submitted self-assessments and to verify the accuracy and implementation of the
laboratory methods.
Records related to FSIS laboratory reviews are submitted to the FSIS Outlook mailbox:
[email protected]
Component 8: Civil Rights
Criteria for Review Determination
The State MPI programs need to provide accurate documentation to demonstrate that
they are operating and will continue to operate in a manner that is “at least equal to”
FSIS’s Federal inspection program requirements for the next 12 months.
The State MPI program:
•
Complies with Federal civil rights laws;
•
Complies with USDA civil rights regulations; and
•
Achieves the intended outcome.
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Outcome
State MPI programs need to be conducted in a manner that respects civil rights,
ensures a non-discriminatory environment, and complies with the laws and regulations
cited below.
Civil Rights authorities
State MPI programs should comply with the following civil rights laws, regulations, and
policies:
•
•
•
Statutory
•
Title VI of the Civil Rights Act of 1964, as amended, 42 U.S.C. 2000(d)
(discrimination on the basis of race, color or national origin)
•
Section 504 of the Rehabilitation Act of 1973, as amended, 29 U.S.C. 794
(discrimination on the basis of disability)
•
Age Discrimination Act (ADA) of 1975, 42 U.S.C. 6102 (discrimination on
the basis of age)
•
Title IX of the Education Amendments of 1972, 20 U.S.C. Section 1681
(discrimination on the basis of sex)
Regulatory and Executive Orders
•
7 CFR Part 15 Subpart A, Non-discrimination in Federally Assisted
Programs
•
7 CFR Part 15 a, Education Programs or Activities Receiving or
Benefitting from Federal Financial Assistance
•
7 CFR Part 15 b, Non-discrimination on the Basis of Disability Programs
and Activities Receiving Federal Financial Assistance
•
45 CFR Part 91, Non-discrimination on the Basis of Age in Programs or
Activities Receiving Federal Financial Assistance from HHS
•
Executive Order 13166 on Limited English Proficiency, dated August 11,
2000
Departmental and Agency Policies
•
USDA Regulation 4330-002, dated March 3, 1999, Non-discrimination in
Programs and Activities Receiving Federal Financial Assistance from
USDA
•
USDA Regulation 4300-3, dated November 16, 1999, Equal Opportunity
Public Notification Policy
•
FSIS Directive 1510.1, Equal Opportunity Notification on Material for the
Public, dated January 25, 2001
Page 76
•
FSIS Directive 5720.3, Revision 1, dated March 14, 2011, Methodology for
Performing Scheduled and Targeted Reviews of State Meat and Poultry
Inspection Programs; and “At Least Equal to” Guidelines for State Meat
and Poultry Cooperative Inspection Programs, dated July 2008
The statutes, regulations and policies listed above prohibit discrimination on the basis of
a person's race, color, religion, sex (including gender identity, sexual orientation, and
pregnancy), national origin, age (40 or older), disability or genetic information. It is also
illegal to retaliate against a person for complaining about discrimination, filed a charge
of discrimination, or participating in an employment discrimination investigation or
lawsuit. Acceptance of annual Federal financial assistance under State/Federal
Cooperative agreements triggers Title VI, Section 504, of the Americans with Disabilities
Act (ADA). Title IX covers and authorizes compliance reviews of federally assisted
program delivery (not employment practices that fall under EEO).
Areas of review
1. Civil Rights Assurances
Requires the State to submit written assurances that its Federally assisted
programs and activities are conducted in compliance with Title VI and other nondiscrimination authorities.
2. State Infrastructure and Program Accountability
Requires that State MPI programs identify individuals and offices responsible for
ensuring program accountability and its compliance with civil rights laws,
regulations, policies and guidelines.
3. Public Notification
Requires that all State MPI programs include a public notification system to
inform applicants, participants, and potentially eligible persons of program
availability, program rights and responsibilities, the program’s policy of nondiscrimination, and the procedures for filing a complaint.
4. Racial and Ethnic Data Collection and Reporting
Requires the State to obtain race and ethnic data on potentially eligible
populations, applicants, and participants in their program service area.
5. Complaints of Discrimination
Assesses the complaint procedures for all complaints alleging discrimination in
the delivery of State MPI programs on the basis of race, color, national origin,
disability, age and sex.
NOTE: Complaints can be processed through State procedures or can be
reported directly to USDA for processing.
6. Civil Rights Training
Requires State to ensure all employees involved in administering Federallyassisted MPI programs understand their obligations under civil rights related
laws, regulations, procedures, and instructions.
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7. Disability Compliance
Requires that State agencies ensure equal access to State MPI program
personnel with disabilities.
8. Limited English Proficiency
Requires that State MPI programs provide free language access services to
potentially eligible applicants and program participants who are Limited English
Proficient (LEP).
9. Compliance with the Age Discrimination Act of 1975
Requires Federal agencies to annually report on steps taken to enforce the Act,
including non-employment related affirmative outreach actions of its recipients of
Federal financial assistance.
Instructions
State MPI programs need to complete FSIS Form 1520-1, Civil Rights Compliance of
State Inspected Programs (Attachment 9, page 79-80) or provide another easy to read
format.
The self-assessment Form 1520-1 or format needs to be signed by the designated
State Official (such as a Director, Commissioner or Secretary) who would be deemed
appropriate and responsible for signing the State-Federal Cooperative agreement and
the annual application for Federal financial assistance. Signing the form consents to the
assurance that the State’s MPI program is conducted in compliance with all Federal
statutes relating to nondiscrimination. The completed form needs to be mailed (hard
copy), with an original signature, to the FSIS Civil Rights Staff by November 1st each
year.
Submission Address:
FSIS Civil Rights Staff
5601 Sunnyside Avenue, Mail Drop 5261
Beltsville, MD 20705-5261
Telephone: 800-269-6912
Fax: 301-504-2141
[email protected]
Page 78
Attachment 9
Civil rights Compliance of State Inspected Programs
Page 79
Page 80
Component 9: Financial
Accountability
State MPI programs need to ensure State agency conformance with USDA 7 CFR Part
3016, Uniform Administrative Requirements for Grants and Cooperative Agreements to
State and Local Governments (previously known as the Common Rule). State agencies
should follow FSIS Directive 3300.1, Rev. 2,“Fiscal Guidelines for Cooperative Meat
and Poultry Inspection Programs.”
Criteria for Review Determination -- Certification for Component 9
The following actions are necessary to complete the Component 9 certification:
1. Timely submission of the annual budget to FSIS’s Office of Field Operations
(OFO) and submission of all data requested (See Section IX, Additional
Resources, Procedures for the Preparation of the Cooperative State Meat and
Poultry Inspection Program Budget Submissions, page 112)
2. Timely submission of annual indirect cost proposals to the applicable Federal
Agency (due within six months after close of State fiscal year). Proposals are
sent to the Financial Reviews and Analysis Section (FRAS) of the Financial
Management Division (FMD).
3. Timely submission of Federal Financial Reports (SF 425) to FSIS. Quarterly
Reports are due within thirty days after the close of each quarter (e.g., 4th
Quarter SF 425 is due by October 30). The Final report is due within 90 days of
the end of the Federal Fiscal Year (e.g., by December 30).
4. Timely resolution of all corrective action on financial findings pursuant to the
onsite fiscal review
Documentation Needed for On-site Financial Review and are to be provided to FSIS
auditors prior to the onsite financial review.
•
State’s centralized accounting reports containing State MPI program
expenditures,
•
Worksheets or schedules used to reconcile the centralized accounting reports to
the SF 425,
•
Manual adjustments made to the accounting report expenses (vehicle mileage,
terminal leave payments, etc.),
•
Monthly, quarterly, or final worksheets or schedules that were used to collect,
adjust, calculate indirect costs, and summarize the total costs that were
reported on the Expense Reports (SF 425) for the grant years indicated,
•
A reconciliation by year of Federal Financial Reports and Federal Share of
Expenditures with accounting records for grant years covered by the fiscal
review,
•
Application for Federal Assistance (Form 424) for the grants years covered by
fiscal review,
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•
Expenditure chart accounts for the grant years covered by the fiscal review,
•
Documentation for any other FSIS cooperative agreement renewals (e.g.
Public Health Data Communication Infrastructure Systems (PHDCIS),
Talmadge-Aiken Overtime (TAOT), Cross Utilization (CU), and Cooperative
Interstate Shipping program (CIS) employee roster with the Employee Name,
Job Title ID Number, Date of Hire Hourly, Bi-weekly, or Monthly Salary,
•
Single or departmental audit reports,
•
Detailed organizational chart with employee names,
•
Equipment inventory list as defined by State requirements,
•
Contractual agreements,
•
Procedures for the “Preparation and Review of the Federal Financial Report”,
•
List of employee retirements/terminations by quarter (e.g. April-June) with
disposition of annual and sick leave balances. This is only required if a State MPI
program claims indirect costs and the State’s centralized accounting reports do
not have object codes for terminal leave payments), and
•
List if applicable names of State inspected plants, inspectors and methods
separate from cooperative MPI program reimbursable costs involved in voluntary
programs, or 100% State Inspection (defined as inspection of the slaughtering
and/or processing of animals that are not covered by the FMIA/PPIA).
The above documents are items that State agencies are to send to the FSIS auditors
prior to the onsite financial review.
Instructions for Self-Assessment
The FRAS verifies the State MPI program’s compliance with financial reporting
requirements throughout the Federal fiscal year. Financial reporting compliance will be
determined by FRAS as outlined in this section entitled “Criteria for review
determination – Certification for Component 9.”
If the State agency has satisfied the elements outlined in this section, the State agency
will sign the Certification Statement for Component 9 (Attachment 10, page 85) and
submit the signed certification statement to the appropriate contact in FRAS in order to
completely satisfy self-assessment for Component 9.
If the State has not satisfied the elements in this section, the State agency complete the
following:
•
Submit any outstanding documents for Component 9 Certification to FRAS. For
a list of required documents for Component 9 Certification see the section above
titled Criteria for review determination – Certification for Component 9.
Page 82
•
Submit a letter to FRAS indicating the reasons for the State program’s
delinquency.
•
Upon completion of steps (1) and (2), sign the certification statement at the end
of the section entitled “Certification Statement for Component 9,” and submit the
signed certification statement to the appropriate contact in FRAS to completely
satisfy self-assessment for Component 9.
Guidance
FSIS Directive 3300.1, Rev. 2, Fiscal Guidelines for Cooperative Meat and Poultry
Inspection Programs, contains instructions for the preparation and submission of both
the Annual Budget and SF 425. Additional guidance for the submission of SF 425, and
Federal Financial Reports, is contained in USDA regulation 7 CFR Part 3016.40 (b)(1).
State agency grantees maintain supporting documentation for their final SF 425, and
Federal Financial Reports, for three years after submission (7 CFR Part 3016.42).
Additional guidance for the analysis of budget submissions is contained in the FSIS
document, titled “A Guide for the Preparation of the Cooperative State Meat and Poultry
Inspection program Budget Submissions,” dated September 2004 “Guidelines for the
preparation and submission of Indirect Cost Proposals are contained in OMB CircularA87, Cost Principles for State, Local, and Indian Tribal Governments, Revised 5/10/04.
Annual Assurance Statements
FMD/FRAS and OFO provide annual assurance statements to the OIEA Federal/State
Audit Branch by February 1st that the State agencies are current in the financial
reporting activities required throughout the Federal Fiscal Year. OFO reviews and
reports on matters associated with the submission of annual budgets. FRAS will review
and report regarding the submission of annual Indirect Cost Proposals, submission of
Quarterly and Final SF 425, Federal Financial Reports, and timely responses to
financial review findings in the form of corrective action.
State agencies need to sign the certification statement and submit it to the appropriate
contacts in the FRAS to completely satisfy self-assessment for Component 9.
Please follow the general mailing procedures and specific procedures for the listed
financial documents:
•
Email account for FRAS is: [email protected]
•
Physical location mailing address for FRAS is:
Financial Reviews and Analysis Section
USDA/FSIS/OA/OCFO/FMD/FASMB
5601 Sunnyside Avenue, Mail Drop 5264
Beltsville, MD 20705-5264SF-425 Expense Reports
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Signed electronic copies are sent to the FRAS email address only.
NOTE: Please submit electronic SF 425 only. Do not send the SF 425 to the auditor in
charge of the State Agency except as a carbon copy (cc).
Indirect Cost Rate Proposals (ICP)
Electronic ICPs are sent to the FRAS email address only.
NOTE: Please submit only electronic ICPs. Hard copies are to the FRAS physical
location mailing address.
Billing Rate Proposals (CU/CE/EPI)
Electronic copies with signed cover letters are sent to the FRAS email address.
NOTE: Please submit electronic billing rate proposals only. Do not email any proposals
to the auditor in charge of the State Agency except as a cc.
Page 84
Attachment 10
Certification Statement for Component 9
We, the State agency entitled, _______________________________________for the
calendar year ending _____________________understand that self-certification for
Component 9 entails compliance with the following:
•
Timely submission of annual budget to FSIS; submission of all data requested.
•
Timely submission of annual Indirect Cost Proposal to the Applicable Federal
Agency (due within six months after close of State fiscal year).
•
Timely submission of Federal Financial Reports (SFs 425) to FSIS. Quarterly
Reports are due within thirty days after the close of each quarter (e.g., 4th Quarter
SF 425 is due by October 30). The Final report is due within 90 days of the end of
the Federal Fiscal Year (e.g., by December 30).
•
Timely resolution of all financial findings pursuant to the onsite fiscal review.
I certify to the best of my knowledge and belief that the aforementioned State agency
has complied with the applicable directives and guidelines set forward by the Food
Safety and Inspection Service Agency for successful and complete self-certification
for Component 9, and certify compliance with all Component 9 requirements for the
State agency.
Typed or Printed Name & Title
Telephone (area code, Number and extension)
Signature of Authorized Certifying Official
Date of Submission
Page 85
IX. ADDITIONAL RESOURCES
“Additional Resources” provides State MPI program Directors with additional information
that may be needed to perform business processes related to the budget submissions,
training and Federal resources, cooperation between State and Federal Compliance
Programs, and reference material for internal controls. Contributors to the new
Additional Resources section are OFO, OOEET, and OIEA.
Page 86
OFFICE OF FIELD OPERATIONS
(OFO)
Resource Management and Financial Planning Staff (RMFPS)
Procedures for the Preparation of
Cooperative State Meat and Poultry Inspection Program Budget Submissions
General
Budget submission guidelines for the Cooperative Meat and Poultry Inspection (MPI)
State programs are contained in the FSIS Directive 3300.1, Fiscal Guidelines for
Cooperative Inspection Programs. The procedures below provide further details on the
preparation of MPI program budget submissions.
I. Current Year Budget Execution Analysis
There are two components of the current year budget analysis: a) projection of current
year expenditures for determination of fund availability for the current year, and b)
determination of a basis for analysis of the budget submission for the ensuing year.
A. Current Budget Execution Analysis
1. The analysis of the current year Cooperative State MPI program budget
begins in June of each year. At that time, the Financial Reviews and
Analysis Section, Financial Management Division requests that each State
Agency to submit their estimated projection of the total current fiscal year
obligations by object classes on the Budget Information form (SF-424A).
2. The data is utilized to determine a total projection of estimated fund
utilization for all State MPI agencies. Annual estimates allow FSIS to
determine any requirement for fund reallocation.
B. Budget Submission Base
1. Data collected serves as an annual expenditure basis for comparison and
analysis of budget submissions for the following year.
II. Budget Submission for New Fiscal Year
Each August, RMFPS prepares the budget call letter for the next fiscal year.
Page 87
A. Budget Call Letter
1. The budget call letter is addressed to the head of the State agency for
each Cooperative State MPI program, and is prepared for the signature of
the Assistant Administrator for OFO.
2. The call letter provides specific guidance relative to operational and
budgetary considerations that State agencies take into account when
preparing the budget submission.
3. The call letter has many enclosures for presentation of the budget
submission:
a. Application for Federal Assistance (SF-424) - Attachment 2-2
b. Budget Information – Non-Construction Programs (SF-424A) Attachment 2-3
c. Assurances – Non-Construction Programs (SF-424B) - Attachment
2-4
d. State Assignment and Employment Report (FSIS Form 5720-5) Attachments 2-6
e. State Establishment Profile (FSIS Form 5720-4) - Attachments 2-5
NOTE: The attachment examples are found in FSIS Directive 3300.1, Fiscal
Guidelines for Cooperative Inspection Programs
B. Budget Submission Form Requirements
FSIS forms 5720-4 and 5720-5 are prepared prior to filling out the other forms.
1. Form SF-424 (Application for Federal Assistance) Note that section 15,
Estimated funding is consistent with form SF-424A.
2. Form SF-424A (Budget Information – Non-Construction Programs) The
amounts in form SF-424A are consistent with the data contained in forms
5720-5 and SF-424. The activities to be used for “Grant Program
Function or Activity” are in-plant, Compliance, Laboratory and other.
Costs in section B of Form SF-424A are reported by Object Class
Category as follows:
a. Personnel costs are salaries for State permanent full time (PFT)
and other than permanent (OTP) personnel including base salaries,
overtime, holiday pay, differentials, lump sum payments and annual
and sick leave payments. Costs for contract veterinarians should
appear in “Contractual.”
b. Fringe Benefits are costs paid on behalf of State employees,
including retirement, social security, insurance, clothing allowances,
relocation benefits, workmen’s compensation, etc. This object
class is calculated as a percentage of salary based on historical
data or by using the latest payroll information available.
Page 88
c. Travel provides for travel costs incurred by State employees in the
performance of their assigned duties whether paid directly by the
State or reimbursed to the employee. Some items used in
determining overall travel costs are: mileage costs based on the
estimated miles to be traveled times the rate per mile (the state
approved mileage rate or latest approved Federal rate, whichever is
lower); vehicle rental costs; motor pool costs; auto leases; repairs
for State vehicles; auto insurance; and depreciation. Other allowed
expenses include per diem, subsistence, and meal allowances.
d. Equipment includes the purchase of durable property with an
expected useful life in excess of one year and for more than $500
per unit or in accordance with the State classification of equipment.
Requests for equipment acquisitions are fully justified.
e. Supplies include commodities, supplies, materials and other
expendable items that are normally expended or consumed within a
year of being put to use. They may also be used to form a minor
part of equipment. Small equipment, costing less than $500 per
unit, may also be included. When estimating for the budget year,
prior year one-time purchases are eliminated. Estimates are based
on prior year costs adjusted for inflation.
f. Contractual includes all contracts for service in support of the
program. The salaries of contract veterinarians are included in this
object class. This item includes any contractual laboratory costs.
Budget year estimates are based on contract costs adjusted
upward for inflation and anticipated changes and downward for
discontinued services.
g. Other includes all items of expenditure not included in the above
object classes.
3. Form SF-424B (Assurances – Non-Construction Programs)
4. Two copies of FSIS Form 5720-5 (State Assignment and Employment
Report). The first shows data on personnel as of September 30 of the
current year. The second shows data on personnel positions as projected
for the ensuing budget year. In both cases, the OTP positions are shown
in terms of PTF.
5. Two copies of FSIS Form 5720-4 (State Establishment Profile) The first
shows data on plants as of September 30 of the current year. The second
form shows a projection of plants expected to be in the cooperative
inspection program during the ensuing budget year.
C. Budget Submission Justifications
State MPI program agencies fully justify and explain all changes in the budget
submission compared to the current year estimated expenditures. Justifications
Page 89
are in narrative form referencing the affected object class. If there is no change
in level of spending or program, it must be indicated in a narrative form.
1. The justification for the budget submission compares and contrasts
current year estimated expenditures, staffing, and workloads with those
proposed in the budget submission. Changes in staffing and workload are
reflected on forms FSIS 5720-4 and FSIS 5720-5. A narrative explanation
accompanies the two forms.
2. Justifications for increases in funding are attached to form SF-424A. The
narrative justification explains, by object class, the reasons for changes in
expenditure levels, including items such as pay raises, inflation, changes
in staffing, and training required to maintain “at least equal to” status. If
inflation factors are used to justify an increase for an object class, the rate
used, as well as the publication source of the inflation index, should be
provided.
3. Justifications for increases in salaries, benefits and other salary changes:
a. Provide the following information for all State employees on an
attachment:
1. Name of employee
2. Position title
3. Date employee entered on duty
4. Annual salary
5. Calculated salary cost for the fiscal year
b. Any promotions are justified by providing the following information:
1. Name of employee
2. Position title
3. Annual salary
4. Date of Promotion
5. Calculated salary cost for fiscal year
c.
For merit increases, the following is provided:
1. Name of employee
2. Percentages used and the amount of the increase
3. Date of increase
4. Justifications for increases or decreases in travel items are included in the
submission:
a. The effective date for change in mileage rate, the current rate,
and the new rate
b. Increases in job assignments
Page 90
c. Increase in travel due to training
d. Decrease in number of personnel traveling.
5. An itemized list of all equipment to be purchased during the fiscal year.
D. Talmadge-Aiken (T/A) Submission
State programs with plants inspected under the Federal-State T/A Cooperative
Inspection program provide the following information attached to form SF-424A:
1. The number of personnel performing inspection at Federally inspected
plants (T/A)
2. Total amount of their salaries
3. Staff years and estimated overtime costs(a staff year equals a full-time
workload for an individual for a full year)
E. Cooperative Interstate Shipment (CIS) Budget Submission
States with plants inspected under the CIS program are to prepare a separate
budget request for their CIS program. Each form submitted for base program
budget request is also submitted for the CIS program. The CIS program
budget request includes specific information for the State CIS program. In
some instances States will footnote CIS information on the appropriate forms.
Note: The Employee Roster is expanded to include employees working in
CIS establishments. If a State employee performs inspection at a CIS
establishment in addition to inspection in a cooperative establishment, the
appropriate percentages of the employees’ time in each type of establishment
noted on the roster.
Page 91
OFFICE OF OUTREACH, EMPLOYEE EDUCATION AND TRAINING
(OOEET)
Outreach Partnership Division (OPD)
The Outreach Partnership Division (OPD) is a part of USDA’s Food Safety and
Inspection Service, Office of Outreach, Employee Education and Training. OPD
provides information and support to State MPI programs, as well as to operators of
small and very small meat, poultry and processed egg products establishments,
including State-inspected plants. OPD delivers assistance to State MPI programs and
State-inspected plants through several different avenues.
Resource Library
OPD offers food defense materials, help for dealing with plant emergencies, generic
HACCP models and guidebooks, informational DVDs on humane handling, control of
Listeria monocytogenes, new plant orientation, compliance guidelines, as well a vast
array of other useful food safety resources for industry. These materials are available
free of charge and can be shipped on request. For a complete listing of available
resources, view the “Food Safety Resources for Small and Very Small Plants” brochure
at: http://www.fsis.usda.gov/wps/portal/fsis/topics/regulatorycompliance/haccp/resources-and-information/food-safety-resources-svsp-outreach
Small Plant Help Desk
FSIS’s Small Plant Help Desk assists operators of small and very small meat, poultry
and processed egg product establishments seeking help with agency requirements with
direct access to knowledgeable staff specialists. The helpdesk provides assistance to
State and local food regulatory agencies (FSIS's partners in keeping meat, poultry and
egg products safe for consumers). The Help Desk is open from 8:00 a.m.-4:00 p.m.
EST, Monday through Friday, excluding Federal holidays. To speak to a staff specialist
during this time, call 1-877-FSISHelp (1-877-374-7435). Customers may also contact
the help-desk by email at [email protected].
Management of State MPI Directors Contact List
OPD manages and keeps an up-to-date list of Agriculture Commissioners and MPI
Directors for the 27 States that have their own meat and poultry inspection programs, as
well as the States in which FSIS has entered into cooperative agreements with to
conduct reviews of custom exempt slaughter and processing operations for OFO. This
list is maintained on FSIS’s Web site at:
www.fsis.usda.gov/wps/portal/fsis/topics/inspection/state-inspection-programs/stateinspection-and-cooperative-agreements/state-officials.
Page 92
Monthly State MPI Program Directors Correlation Webinar
OPD coordinates a monthly Webinar with all 27 State MPI Directors and their personnel
to discuss new FSIS policies and any other issues that States need to know to maintain
“at least equal to” status to FSIS’s Federal meat and poultry inspection programs. OPD,
in conjunction with FSAB and other FSIS programs encourage States to provide issues
or topics that need further clarification before the monthly scheduled Webinar so that
the appropriate FSIS subject matter experts can provide updates and answer questions.
OPD solicits topics from the State MPI Directors for upcoming Webinars; however,
State personnel are also welcome to submit suggestions for Webinar topics through the
Small Plant Help Desk.
Management and Renewal of Federal and State Cooperative Agreements
The FMIA and PPIA allow FSIS to cooperate with State agencies in developing and
administering their own MPI programs. OPD administers the base cooperative
agreements between FSIS and the individual States to operate their “at least equal to”
meat and poultry inspection programs. Provided the State continues to operate it’s “at
least equal to” program in good standing, these cooperative agreements are renewed
on an annual basis through OPD.
OPD administers, and renews, the Tallmadge-Aiken (TA) and Cross Utilization (CU)
agreements with States that provide inspection coverage for FSIS-regulated
establishments, as well as the Cooperative Interstate Shipment (CIS) agreements
where State-inspected establishments can sell product outside of their respective State
boundaries and in foreign commerce. OFO has direct oversight of these three
programs, and ensures that State inspection personnel assigned to any TA, CU or CIS
establishment have received FSIS-conducted training. OPD assists the States that
have these programs by ensuring their personnel are registered in the required FSISconducted training courses and providing both the States and OFO with the pass/fail
results of the State employees.
There are several other unique cooperative agreements that OPD administers and
renews based on OFO’s needs. There is a cooperative agreement with Utah’s Egg and
Poultry Grading Program to have Utah State Inspectors provide continuous inspection
in several of FSIS’s egg products inspection plants. Furthermore FSIS has cooperative
agreements with California and Colorado for their personnel to conduct reviews of
custom exempt slaughter and processing operations within those respective States,
which are procedures that OFO would normally perform.
Directors seeking advice or assistance with State MPI programs, or wishing to obtain
copies of current and archived cooperative agreements, are welcome to contact OPD
through the Small Plant Help Desk.
Page 93
Training
OPD provides assistance to the State programs by ensuring they receive course
announcements from FSIS and any assistance to State personnel in securing
enrollment in the classes they might need. This service is especially essential for the
States that have TA, CU or CIS programs where their personnel must have successfully
completed FSIS trainer-led courses in order to conduct inspection activities within TA,
CU or CIS establishments. OPD provides both the States and OFO with the pass/fail
results of the State employees. Furthermore, OPD assists States by providing CDs,
DVDs, or other hard copy resources on food safety and public health-related training
materials for reference offered through FSIS’s Center for Learning. Many of these titles
are interactive computer-based training on disk. State personnel can request a copy of
the catalog and submit any orders through the Small Plant Help Desk, since the online
catalog is only available through FSIS’s Intranet site, which the States cannot access.
Page 94
OFFICE OF INVESTIGATION, ENFORCEMENT AND AUDIT (OIEA)
Compliance Investigation Division (CID)
Cooperation Between Compliance Investigation Division (CID)
and State Compliance Programs
Federal and State Compliance programs are encouraged to integrate and coordinate
their respective programs to the maximum extent possible to eliminate or avoid
duplication of efforts. CID assists and encourages State Compliance programs in
assuming full responsibility for and jurisdiction over the enforcement of meat and poultry
laws within States. State Compliance programs assist CID in coordinating and
channeling various State efforts into a comprehensive national compliance program.
The coordination of CID and State Compliance programs necessitate close
communications in administration of the respective programs.
The compliance personnel of CID and State Compliance programs are cross-utilized
fully to inquire into alleged violations, conduct compliance reviews, develop evaluation
material, and make necessary contacts with the various Federal, State, County,
or Municipal officials and informants. When there is overlapping jurisdiction and
authority, compliance personnel of either CID or State Compliance programs are
authorized to handle the matter and represent fully both Federal and State interests.
CID and State Compliance programs are encouraged to refer cases dependent on
resources to obtain optimal results. These operational details are resolved on a caseby-case basis between CID and State Compliance programs.
CID training programs are open for participation by members of both groups to the
extent possible and feasible.
CID Regions and Contact Information
Western Region (CA, HI, AZ, AK, NM, NV, UT, CO, OR, WA, ID, WY, MT)
620 Central Avenue
Building 2B, 2nd Floor
Alameda, CA 94501
Telephone: 510-769-5733
Southwest Region (TX, OK, KS, MO, NE, IA, SD, ND, IL, MN)
1100 Commerce Street, Room 557
Dallas, TX 75242
Telephone: 214-767-2783
Page 95
Southeast Region (FL, PR, AR, LA, GA, AL, TN, MS, MD, VA, KY, SC, NC, WV, DE,
DC)
100 Alabama Street, SW
1924 Building Suite 3R95
Atlanta, GA 30303-3104
Telephone: 404-562-5962
Northeast Region (PA, NJ, CT, NY, MI, WI, IN, OH, MA, ME, NH, VT, RI)
BNY Mellon Independence Center
701 Market Street, Suite 4100 C
Philadelphia, PA 19106
Telephone: 215-430-6222
Page 96
Management Control and Audit Division (MCAD)
Development of a Federal Program Management Control System
Background
The Federal Managers’ Financial Integrity Act of 1982 (FMFIA) requires the General
Accounting Office (GAO) to issue standards for internal control in government. The
standards provide the overall framework for establishing and maintaining internal control
and for identifying and addressing major performance and management challenges in
areas at greatest risk of fraud, waste, abuse, and mismanagement. Office of
Management and Budget (OMB) Circular A-123, Management Accountability and
Control, revised June 21, 1995, provides the specific requirements for assessing and
reporting on controls.
As a result, Federal program managers continually seek better ways to achieve
agencies’ missions and program results. In other words, they seek ways to improve
accountability. A key factor in helping achieve such outcomes and minimize operational
problems is to implement appropriate internal control. Effective internal control helps
manage change to cope with shifting environments and evolving demands and
priorities.
The term internal control is synonymous with the term management control (as used in
OMB Circular A-123) that covers all aspects of an agency’s operations (programmatic,
financial, and compliance). Recently, other laws have prompted renewed focus on
internal control. The Government Performance and Results Act of 1993 requires
agencies to clarify their missions, set strategic and annual performance goals, and
measure and report on performance toward those goals.
The internal control system helps the program’s management to provide reasonable
assurance of the effectiveness and efficiency of operations, of reliability of financial
reporting, and of compliance with applicable laws and regulations.
Terminology
The following includes definitions for commonly used terms of the Federal management
control systems:
Risk Assessment - Internal control provide for an assessment of the risks the agency
faces from both external and internal sources. A precondition for risk assessment is the
establishment of clear and consistent agency objectives. Risk assessment is the
identification and analysis of relevant risks associated with achieving the objectives,
such as those defined in strategic and annual performance plans developed under the
Government Performance and Results Act, and forming a basis for determining how
risks is managed.
Page 97
Internal Control (Management Control) - An internal control is comprised of control
activities, control document (control), and performance measures (i.e., performance
standards or action level).
Control - Control documents (control) provide direction to program personnel for the
execution of the control activity to meet the expectation of the program’s management.
Controls are policies, procedures, techniques, and mechanisms that enforce
management’s directives, such as the process of adhering to requirements for budget
development and execution. Controls are clearly documented, and the documentation
is readily available for examination. The control document is measurable and appears
in management directives, administrative policies, or operating manuals and may be in
paper or electronic form. All documentation and records are properly managed and
maintained.
Control Activity – Internal control activities help ensure that management's directives
(mission and strategic goals) are carried out. Control activities are effective and
efficient in accomplishing the agency's control objectives. They help ensure that actions
are taken to address risks.
Objective of Control Activity - Objective of control activity specifies the purpose for
program in executing a control activity. The purpose of the control activity directly
relates to and supports the program’s mission and strategic goals.
Implementation (Monitoring) - Internal control monitoring assesses the quality of the
control activity performance over time and ensures the findings of audits and other
reviews are promptly resolved.
Performance Measure - A performance measure (i.e., performance standard or action
level) is an indicator of the effectiveness and efficiency of a control activity. Programs
need to establish activities to monitor performance measures. These activities may
include comparisons and assessments of different sets of data to one another and the
performance measures to analyze the relationships so conclusions can be made and
appropriate actions taken. Controls are aimed at validating the correctness and integrity
of the performance measures.
Page 98
Management Control Helper Questions
Key Function (Functional Area)
•
Why do we exist? How do we accomplish our program’s mission and strategic
goals? Does our existence require us to produce any products?
Risk Assessment
•
What can happen if we do not meet our objective?
•
How will our failures to meet our objectives affect the program’s function or
existence?
•
How will our failures affect the program’s accomplishment of its mission and
strategic objectives?
Control Activity
•
What must be done consistently and well for the program to continue to function
successfully? (NOTE: This does not relate to how it is done)
Objective (Desired Outcome)
•
What is the objective of the control activity?
Management Control
•
What procedures or activities will provide personnel clear instructions for
implementing the control activity and ensure the attainment of the objective?
•
How can we demonstrate our implementation of the controls? (proof)
•
What is our proof of implementation? (NOTE: The proof is management control,
because it is measurable—e.g., a form, tracking log, etc.)
NOTE: Reference for performing the control – e.g., 9 CFR, Directives, Notices, State
Policies
Performance Measure
•
How do we define a success?
•
How can we measure successful completion of the objective?
•
What is our tolerance level of risk for the control activity?
Page 99
Reference Table of Related FSIS Policy Documents
Component 2 – Inspection Related FSIS Directives
Slaughter Inspection
5100.3
Administrative Enforcement Reporting (AER) System - Revision 2 (Oct
18, 2011; 18 pp)
6000.1
Responsibilities Related to Foreign Animal Diseases (FADs) and
Reportable Conditions - Revision 1 (Aug 3, 2005; 6 pp)
6030.1
Religious Exemption for the Slaughter and Processing of Poultry Revision 1 (Aug 10, 2005; 11 pp)
6100.1
Ante-Mortem Livestock Inspection - Revision 2 (Jul 24, 2014; 18 pp)
Bovine Spongiform Encephalopathy (BSE) and Specified Risk Material
(SRM) Guidance Materials and Resources
6100.2
Post-Mortem Livestock Inspection (Sep 17, 2007; 31 pp)
6100.3
Ante-Mortem and Post-Mortem Poultry Inspection - Revision 1 (Apr 30,
2009; 16 pp)
6100.4
Verification Instructions Related to Specified Risk Materials (Sep 13,
2007; 22 pp)
Questions and Answers
Verification of SRM Removal Including Tonsils
6240.1
Inspection, Sampling, and Disposition of Animals for Tuberculosis Revision 1 (Jan 29, 2009; 10 pp)
PHV Training: Multi-species Disposition Basics with a Public Health
Focus
FSIS Guideline No. 4, Inspection of Tuberculin Reactors
Tuberculosis Sample Submission Manual for Meat Inspection
Personnel (USDA-APHIS)
6410.1
Verifying Sanitary Dressing and Process Control Procedures in
Slaughter Operations of Cattle of Any Age - Revision 1 (Nov 3,
2011; 23 pp)
Page 100
6420.2
Verification of Procedures for Controlling Fecal Material, Ingesta and
Milk in Slaughter Operations (Mar 31, 2004; 14 pp)
PHIS FSIS Directive 6420.1
Questions and Answers on FSIS Directives 10,010.1, Revision 1,
5000.2, and 6420.2
Questions and Answers Regarding Directives 5000.2, 6420.2 and
10,010.1, Revision 1, and the Compliance Guidelines on E. coli
O157:H7
Workshops on E. coli O157:H7 Regulations
Food Safety Verification
5000.1
Verifying an Establishment's Food Safety System - Revision 4 (Mar 4,
2014; 76 pp)
Meat and Poultry Hazards and Controls Guide (Oct 4, 2005)
5000.2
Review of Establishment Data by Inspection Personnel - Revision 2
(Dec 4, 2008; 6 pp)
Questions and Answers on FSIS Directives 10,010.1, Revision 1,
5000.2, and 6420.2
Questions and Answers Regarding Directives 5000.2, 6420.2 and
10,010.1, Revision 1, and the Compliance Guidelines on E. coli
O157:H7
Compliance Guidelines For Establishments On The FSIS
Microbiological Testing Program And Other Verification Activities For
Escherichia coli O157:H7
5000.3
Identification and Segregation of Products (Dec 21, 2006; 3 pp)
5000.4
Performing the Review Component of PBIS 01b02 Procedure and
PHIS Pre-Op Sanitation SOP Review and Observation Task in
Federally Inspected Processing, Slaughter and Import EstablishmentsRevision 1 (Sep 28, 2011; 12 pp)
5000.5
Verification of Less Than Daily (LTD) Sanitation Procedures In
Processing Operations- Revision 1 (Sep 28, 2011; 19 pp)
Less than Daily Sanitation Procedures Compliance Guideline (Oct 19,
2009
5000.6
Performance of the Hazard Analysis Verification (HAV) Task - Revision
1 (Mar 4, 2014; 29 pp)
Questions and Answers Related to Performance of the Hazard
Analysis Verification (HAV) Task (Aug 14, 2012)
9 CFR Part 417
Docket No. 00-022N - E. coli O157:H7 Contamination of Beef
Products
FSIS Directive 5020.1 - Verification of Salmonella Initiative Program
Page 101
FSIS PHIS Directive 5300.1 - Managing the Establishment Profile in
the Public Health Information System (PHIS)
FSIS PHIS Directive 13000.1 - Scheduling In-plant Inspection Tasks in
the Public Health Information System
Meat and Poultry Hazards and Controls Guide (Oct 4, 2005)
5000.8
Verifying Compliance with Requirements for Written Recall Procedures
(Dec 18, 2013; 2 pp)
5000.9
Verifying Video or Other Electronic Monitoring Records (Aug 26,
2011; 5 pp)
Compliance Guidelines for Use of Video or Other Electronic Monitoring
or Recording Equipment in Federally Inspected Establishments (Aug
26, 2011)
5010.1
Food Safety Related Topics for Discussion During Weekly Meetings
with Establishment Management - Revision 2 (Apr 17, 2014; 6 pp)
5020.1
Verification of Salmonella Initiative Program (Aug 12, 2011; 10 pp)
5100.1
Enforcement, Investigations, and Analysis Officer (EIAO)
Comprehensive Food Safety Assessment Methodology - Revision 4
(May 29, 2015; 23 pp)
Food Safety Assessment Tools
5100.2
Enforcement, Investigations, and Analysis Officer (EIAO)
Responsibilities Related to Recalls and Consumer Complaints (Oct 4,
2005; 6 pp)
Meat and Poultry Hazards and Controls Guide
5100.3
Administrative Enforcement Reporting (AER) System - Revision 2 (Oct
18, 2011; 18 pp)
5100.4
Enforcement, Investigations and Analysis Officer (EIAO) Public Health
Risk Evaluation (PHRE) Methodology - Revision 1 (May 22, 2015; 8
pp)
5220.1
Granting or Refusing Inspection; Voluntary Suspending or Withdrawing
Inspection; and Reinstating Inspection under PHIS - Revision 1 (Jan
30, 2013; 21 pp)
5220.3
Issuance of a Ten-Day Letter for Inactive Operations (Apr 11, 2011; 3
pp)
5300.1
Managing the Establishment Profile in the Public Health Information
System (PHIS) (Apr 13, 2011; 22 pp)
Page 102
6410.1
Verifying Sanitary Dressing and Process Control Procedures in
Slaughter Operations of Cattle of Any Age - Revision 1 (Nov 3,
2011; 23 pp)
6420.2
Verification of Procedures for Controlling Fecal Material, Ingesta and
Milk in Slaughter Operations (Mar 31, 2004; 14 pp)
PHIS FSIS Directive 6420.1
Questions and Answers on FSIS Directives 10,010.1, Revision 1,
5000.2, and 6420.2
Questions and Answers Regarding Directives 5000.2, 6420.2 and
10,010.1, Revision 1, and the Compliance Guidelines on E. coli
O157:H7
Workshops on E. coli O157:H7 Regulations
7520.2
Procedures for Condition of Canned Product Container Examination
(May 12, 1988; 10 pp)
7530.1
Handling a Process Deviation or Abnormal Container of Thermally
Processed, Commercially Sterile Canned Product - Revision 2 (Mar
25, 2010; 15 pp)
7530.2
Verification Activities in Canning Operations that Choose to Follow the
Canning Regulations (Oct 20, 2005; 22 pp)
10,010.1
Sampling Verification Activities for Shiga Toxin-Producing Escherichia
coli (STEC) in Raw Beef Products (Aug 20, 2015; 88 pp)
10,010.2
Verification Activities for Shiga Toxin-Producing Escherichia Coli
(STEC) in Raw Beef Products (Aug 20, 2015; 22 pp)
10,010.3
Traceback Methodology for Escherichia Coli (E. Coli) 0157:H7 in Raw
Ground Beef Products and Bench Trim (Jan 21, 2015; 16 pp)
Non-Food Safety Verification
5100.3
Administrative Enforcement Reporting (AER) System - Revision 2
(Oct 18, 2011; 18 pp)
7000.1
Verification of Non-Food Safety Consumer Protection Regulatory
Requirements (Dec 11, 2006; 24 pp)
7000.4
Verifying Certain Transferred Labeling (Dec 8, 2008; 4 pp)
Questions and Answers (Jan 7, 2009)
7110.1
Guidelines for Specified Cuts of Poultry (Feb 26, 1986; 2 pp)
Page 103
7110.3
Time/Temperature Guidelines for Cooling Heated Products-Revision
1 (Jan 24, 1989; 10 pp)
7111.1
Performance Standards for the Production of Certain Meat and
Poultry Products (Mar 3, 1999; 15 pp)
7120.1
Safe and Suitable Ingredients Used in the Production of Meat, Poultry
and Egg Products - Revision 20 (Sep 8, 2014; 69 pp)
Access additional information
7124.1
Standards of Identify or Composition--Use of Cooked or Cured
Product (Jul 28, 1986; 3 pp)
7220.1
Food Labeling Division Policy Memoranda (Aug 2, 2005; 133 pp)
7221.1
Prior Labeling approval - Revision 1 (Jan 6, 2014; 5 pp)
7235.1
Mandatory Safe Handling Statements on Labeling of Raw and
Partially Cooked Meat and Poultry Products (May 11, 1994; 10 pp)
7237.1
Labeling of Ingredients - Revision 1 Amendment 1 (Aug 9, 1994; 4 pp)
7270.1
Sampling and Testing Procedures for Raw Poultry Products Labeled
"Fresh"-Revision 1 (Aug 13, 1998; 5 pp)
7310.5
Presence of Foreign Material in Meat or Poultry Products - Revision 3
(May 30, 2003)
7320.1
Treatment of Certain Meat and Poultry Products Containing Pork to
Destroy Trichinae (Apr 27, 1993; 2 pp)
7355.1
Use of Sample Seals for Program Samples and Other Applications Revision 2 (Dec 3, 2002; 13 pp)
7620.3
Processing Inspectors' Calculations Handbook (Revised 1995; 138
pp)
Exempt Facility Review
5930.1
Custom Exempt Review Process - Revision 4 (Jul 15, 2009; 17 pp)
Poultry Slaughter Exemption Guideline
8010.1
Methodology for Conducting In-Commerce Surveillance Activities –
Revision 4 (Apr 24, 2014; 27 pp)
Component 3 – Program Sampling Related FSIS Directives and Compliance Guidelines
Page 104
FSIS Directives
10,010.1
Sampling Verification Activities for Shiga Toxin-Producing
Escherichia coli (STEC) in Raw Beef Products (Aug 20, 2015; 88
pp)
10,010.2
Verification Activities for Shiga Toxin-Producing Escherichia Coli
(STEC) in Raw Beef Products (Aug 20, 2015; 22 pp)
10,010.3
Traceback Methodology for Escherichia Coli (E. Coli) 0157:H7 in
Raw Ground Beef Products and Bench Trim (Jan 21, 2015; 16 pp)
10,200.1
Accessing Laboratory Sample Information via LEARN (Jul 19, 2001,
7 pp)
10,210.1
Unified Sampling Form - Amendment 1 (Jun 10, 1999; 31 pp)
Amendment 6 - Change Transmittal Sheet (Dec 18, 2003; 63 pp)
Amendment 5 - Change Transmittal Sheet (Feb 11, 2003; 9 pp)
Amendment 4 - Change Transmittal Sheet(Dec 19, 2002; 7 pp)
Amendment 3 - Change Transmittal Sheet (May 22, 2002; 25 pp)
Amendment 2 - Change Transmittal Sheet(Dec 12, 2001; 9 pp)
10,230.2
Procedures for Collecting and Submitting Domestic Samples for
Microbiological Analysis (Aug 6, 1992; 14 pp)
10,230.4
Salmonella Surveillance Program for Liquid and Frozen Egg
Products (Aug 6, 1992; 4 pp)
10,230.6
Submitting Tissue Specimens for Pathological or Diagnostic
Microbiological Evaluation to the Laboratory (Jan 10, 2006; 9 pp)
10,240.4
Verification Activities for the Listeria monocytogenes (Lm)
Regulation and the Ready-to-Eat (RTE) Sampling Program Revision 3 (Jan 10, 2014; 48 pp)
Attachments and Related Documents
10,240.5
Verification Procedures for Enforcement, Investigations and
Analysis Officers (EIAOs) for the Listeria monocytogenes (Lm)
Regulation and Routine Risk-Based Listeria monocytogenes (RLm)
Sampling Program - Revision 3 (Mar 28, 2013; 17 pp)
10,250.1
Salmonella and Campylobacter Verification Program for Raw Meat
and Poultry Products (Sep 20, 2013; 70pp)
FSIS Establishment Eligibility Criteria for the Salmonella Verification
Sampling Program and FSIS Scheduling Algorithm for the
Salmonella Verification Sampling Program for Raw Meat and Poultry
(Feb 2013; 4 pp)
Page 105
10,300.1
Intensified Verification Testing (IVT) Protocol for Sampling of
Product, Food Contact Surfaces and Environmental Surfaces for
Listeria Monocytogenes - Revision 1 (Mar 28, 2013; 19 pp)
10,400.1
Sample Collection from Cattle Under the Bovine Spongiform
Encephalopathy (BSE) Ongoing Surveillance Program (Apr 11,
2013; 6 pp)
10,630.1
Federal and Contract Servicing Laboratories for Domestic Food
Chemistry Samples (May 13, 1991; 4 pp)
10,700.1
Procedures for New Technology and Experimental Protocols for InPlant Trails (Jun 24, 2003, 10 pp)
Guidance Procedures for Notification and Protocol Submission of
New Technology | PDF (16 pp)
Other Related Documents
10,800.1
Residue Sampling, Testing and Other Verification Procedures under
the National Residue Program for Meat and Poultry Products Revision 1 (Mar 3, 2014; 43 pp)
KIS™ Test Instructions (Oct 13, 2011)
Examples of Official Ear Tags
Additional Related Documents
FSIS Compliance Guidelines
FSIS Revised Action Plan for Control of Listeria monocytogenes for the Prevention of
Foodborne Listeriosis (2000)
Best Practices Guidance for Controlling Listeria monocytogenes (Lm) in Retail
Delicatessens
FSIS Compliance Guideline: Controlling Listeria monocytogenes in Post-lethality
Exposed Ready-to-Eat Meat and Poultry Products (Updated Jan 2014; PDF Only)
FSIS Scheduling Criteria for Routine Lm Risk-Based (RLm) Sampling Program (Mar 21,
2008; PDF Only)
Verification Procedures for the Listeria monocytogenes Regulation and Microbial
Sampling of Ready-to-Eat (RTE) Products for the FSIS Verification - FSIS Directive
10240.4 (Feb 3, 2009; PDF Only)
FSIS Compliance Guideline for Validating Cooking Instructions for Mechanically
Tenderized Beef Products (Jun 2013; PDF Only)
Docket No. FSIS-2008-0017 | PDF (Aug 9, 2013)
Expert Elicitation on the Market Shares for Raw Meat and Poultry Products Containing
Page 106
Added Solutions and Mechanically Tenderized Raw Meat and Poultry Products (Feb
2012; PDF Only)
View Comments on regulations.gov
FSIS Compliance Guideline for Controlling Meat and Poultry Products Pending FSIS
Test Results (Feb 1, 2013; PDF)
FAQs: FSIS Hold and Test Conference Call with Industry held February 7, 2013 (PDF
Only)
Docket No. FSIS-2005-0044 - Not Applying the Mark of Inspection Pending Certain
Test Results | PDF (Dec 10, 2012)
Establishment Guidance for the Selection of a Commercial or Private Microbiological
Testing Laboratory (Revised Jun 2013; PDF Only)
Foodborne Pathogen Test Kits Validated by Independent Organizations | PDF
FSIS Guidance for Evaluating Test Kit Performance (PDF Only)
Compliance Guideline for Controlling Salmonella in Market Hogs
Docket No. FSIS-2012-0026 | PDF (Jan 6, 2014)
Baseline Data Reports
Salmonella Compliance Guidelines for Small and Very Small Meat and Poultry
Establishments that Produce Ready-to-Eat (RTE) Products (Sep 19, 2012; PDF Only)
Compliance Guideline for Controlling Salmonella and Campylobacter in Poultry Third
Edition May 2010 (May 10, 2010; PDF Only)
Review of FSIS Compliance Guidelines for Controlling Salmonella in Small and Very
Small Plants that Produce Raw Poultry Products (PDF Only)
Chemical Antimicrobials (Jun 29, 2009; PDF Only)
Component 4 – Administrative FSIS Directives
Staffing
12,700.1
Training
4200.2
4338.1
Supervision
2610.1
Operations Occurring Outside Approved Hours - Revision 1 (Nov 25,
2008; 4 pp )
New Employee Orientation (Jul 12, 2007; 9 pp)
Training as a Condition of Employment - Amendment 2 (Mar 1, 2013;
36 pp)
FSIS Issuance System - Revision 6 (Apr 23, 2012; 18 pp)
Page 107
4200.2
New Employee Orientation (Jul 12, 2007; 9 pp)
4315.2
Probationary Period (Mar 3, 1982; 4 pp)
4315.3
Probationary Period for Newly Appointed Supervisors and Managers Revision 1 (May 3, 1989; 17 pp)
4335.1
Merit Promotion Plan - Revision 2 (May 6, 1999; 84 pp)
4338.1
Training as a Condition of Employment - Amendment 2 (Mar 1, 2013;
36 pp)
4410.1
Employee Development- Revision 1 Amendment 2 (Dec 14, 2007; 15
pp)
4410.2
Career Development Program (Oct 18, 1982; 12 pp)
4430.1
Performance Evaluation Plan - Revision 6 (Dec 15, 2009; 31 pp)
4430.3
In-Plant Performance System (IPPS) - Revision 2 (Feb 19, 2010; 23
pp)
Component 5 - Humane Handling Related FSIS Directives
6030.1
Religious Exemption for the Slaughter and Processing of Poultry Revision 1 (Aug 10, 2005; 11 pp)
6900.2
Humane Handling and Slaughter of Livestock - Revision 2 (Aug 15,
2011; 40 pp)
6910.1
District Veterinary Medical Specialist (DVMS) - Work Methods Revision 1 (Dec 7, 2009;18 pp)
Component 6 – Compliance Related FSIS Directives
8010.1
Methodology for Conducting In-Commerce Surveillance Activities Revision 4 (Apr 24, 2014; 27 pp)
8010.2
Investigative Methodology - Revision 4 (Apr 24, 2014; 16 pp)
8010.3
Procedures for Evidence Collection, Safeguarding and Disposal Revision 4 (Apr 24, 2014; 18 pp)
8010.4
Report of Investigation - Revision 5 (Apr 24, 2014; 6 pp)
Page 108
8010.5
Case Referral and Disposition - Revision 4 (Apr 24, 2014; 6 pp)
8080.1
Recall of Meat and Poultry Products - Revision 7 (Sep 9, 2013; PDF;
41 pp)
8410.1
Detention and Seizure - Revision 6 (Apr 24, 2014; 12 pp)
8420.1
Transportation Accidents (Nov 7, 1985; 2 pp)
Component 7 – Relevant FSIS Laboratory Quality Assurance Compliance Guidelines
FSIS Form 5720-14, State Meat and Poultry Inspection Program Laboratory Quality
Management System Checklist
FSIS Form 5720-15, Laboratory Method Notification Form
FSIS Accredited Laboratory Program
USDA FSIS Chemistry Laboratory Guidebook
USDA FSIS Microbiology Laboratory Guidebook
FDA Bacteriological Analytical Manual
ISO Standards
AOAC Official Methods of Analysis
Establishment Guidance for the Selection of a Commercial or Private Microbiological
Testing Laboratory (Revised Jun 2013; PDF Only)
Foodborne Pathogen Test Kits Validated by Independent Organizations | PDF
FSIS Guidance for Evaluating Test Kit Performance (PDF Only)
FSIS Directive 10,800.1, Residue Sampling, Testing and Other Verification Procedures
Under The National Residue Program For Meat and Poultry Products
KISTM Test Instructions (Oct 13, 2011)
Examples of Official Ear Tags
Additional Related Documents
Component 8 – Federal Civil Rights Statutes, Regulations and Policies
Federal Statutes
Title VI of the Civil Rights Act of 1964, as amended, 42 U.S.C. 2000d (discrimination on
the basis of race, color or national origin)
Page 109
Section 504 of the Rehabilitation Act of 1973, as amended, 29 U.S.C. 794
(discrimination on the basis of disability)
Age Discrimination Act (ADA) of 1975, 42 U.S.C. 6102 (discrimination on the basis of
age)
Title IX of the Education Amendments of 1972, 20 U.S.C. Section 1681 (discrimination
on the basis of sex)
Regulatory and Executive Orders
7 CFR Part 15 Subpart A, Non-discrimination in Federally Assisted Programs
7 CFR Part 15 a, Education Programs or Activities Receiving or Benefitting from
Federal Financial Assistance
7 CFR Part 15 b, Non-discrimination on the Basis of Disability Programs and Activities
Receiving Federal Financial Assistance
45 CFR Part 91, Non-discrimination on the Basis of Age in Programs or Activities
Receiving Federal Financial Assistance from HHS
Executive Order 13166 on Limited English Proficiency, dated August 11, 2000
Departmental and Agency Policies
USDA Regulation 4330-002, dated March 3, 1999, Non-discrimination in Programs and
Activities Receiving Federal Financial Assistance from USDA
USDA Regulation 4300-3, dated November 16, 1999, Equal Opportunity Public
Notification Policy
FSIS Directive 1510.1, Equal Opportunity Notification on Material for the Public, dated
January 25, 2001
FSIS Directive 5720.3, Revision 1, dated March 14, 2011, Methodology for Performing
Scheduled and Targeted Reviews of State Meat and Poultry Inspection Programs; and
“At Least Equal to” Guidelines for State Meat and Poultry Cooperative Inspection
Programs, dated July 2008
Component 9 - Relevant Financial FSIS/USDA Regulations and Policies
Departmental and Agency Regulations
7 CFR Part
Uniform Administrative Requirements for Grants and Cooperative
3016
Agreements to State and Local Governments (previously known as the
Common Rule)
Page 110
FSIS Directive
3300.1
Fiscal Guidelines for Cooperative Meat and Poultry Inspection
Programs – Revision 2
Additional Compliance Guidelines
A Guide for the Preparation of the Cooperative State Meat and Poultry Inspection
Program Budget Submissions, dated September 2004
OMB Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments,
Revised 5/10/04 - Guidelines for the preparation and submission of Indirect Cost
Proposals
Page 111
| File Type | application/pdf |
| File Title | “At Least Equal To” Guideline for State Meat and Poultry Inspection Programs |
| Subject | At Least Equal To, Guideline, State Meat and Poultry Inspection Programs |
| File Modified | 2016-11-10 |
| File Created | 2016-11-10 |