Meat and Poultry: Improved Oversight and Training Will Strengthen New
Food Safety System (Letter Report, 12/08/1999, GAO/RCED-00-16).

Pursuant to a legislative requirement, GAO reviewed the Department of
Agriculture's (USDA) efforts to improve the safety of meat and poultry
products, focusing on whether: (1) the system adopted by USDA in its
regulations is consistent with the seven Hazard Analysis and Critical
Control Point (HACCP) principles endorsed by the National Advisory
Committee on Microbiological Criteria for Foods; (2) the HACCP training
program for USDA inspectors is adequate and science-based; and (3) there
is an adequate dispute resolution (appeals) process between plants and
USDA under the new HACCP inspection system.

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

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-00-16
     TITLE:  Meat and Poultry: Improved Oversight and Training Will
	     Strengthen New Food Safety System
      DATE:  12/08/1999
   SUBJECT:  Dispute settlement
	     Contaminated foods
	     Meat inspection
	     Meat packing industry
	     Human resources training
	     Quality control
	     Product safety
	     Safety standards
	     Safety regulation
IDENTIFIER:  FSIS Hazard Analysis and Critical Control Point System
	     USDA Appeals Tracking System

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Cover
================================================================ COVER

Report to Congressional Committees

December 1999

MEAT AND POULTRY - IMPROVED
OVERSIGHT AND TRAINING WILL
STRENGTHEN NEW FOOD SAFETY SYSTEM

GAO/RCED-00-16

Implementation of New Food Safety System

(150127)

Abbreviations
=============================================================== ABBREV

  FSIS - Food Safety and Inspection Service
  HACCP - Hazard Analysis and Critical Control Point
  USDA - U.S.  Department of Agriculture

Letter
=============================================================== LETTER

B-283823

December 8, 1999

The Honorable Thad Cochran
Chairman
The Honorable Herb Kohl
Ranking Minority Member
Subcommittee on Agriculture, Rural Development,
 and Related Agencies
Committee on Appropriations
United States Senate

The Honorable Joe Skeen
Chairman
The Honorable Marcy Kaptur
Ranking Minority Member
Subcommittee on Agriculture, Rural Development,
 Food and Drug Administration,
 and Related Agencies
Committee on Appropriations
House of Representatives

Food contamination may cause an estimated 76 million illnesses,
325,000 hospitalizations, and 5,000 deaths in the United States each
year, according to the Centers for Disease Control and Prevention. 
The U.S.  Department of Agriculture (USDA) estimates that the costs
associated with foodborne illnesses are as high as $37 billion
annually.  To reduce foodborne illnesses and improve the safety of
meat and poultry products, USDA issued regulations in July 1996
requiring that by January 2000 all meat and poultry plants adopt a
science-based production control system called Hazard Analysis and
Critical Control Point (HACCP).  The HACCP program is designed to
identify the steps in food production where contamination is most
likely to occur and then to establish controls that prevent or reduce
contamination.  The HACCP regulations also require that meat and
poultry slaughter plants regularly test for E-coli bacteria to verify
that their controls are sufficient to prevent fecal contamination. 
In addition, USDA's Food Safety and Inspection Service (FSIS) tests
for salmonella at plants that produce raw and ground meat and poultry
products to determine whether they are meeting USDA's salmonella
pathogen reduction performance standards. 

The mandatory implementation of HACCP systems fundamentally changes
the government's approach to ensuring the safety of meat and poultry
products:  It makes industry, not government, primarily responsible
for the safety of these products.  Moreover, industry has to
implement HACCP systems that identify and control biological,
physical, and chemical hazards throughout production.  HACCP systems
are designed to improve USDA's traditional inspections, which use
sight, touch, and smell to detect contaminated products.  USDA
inspectors based at meat and poultry plants are responsible for
overseeing the plants' implementation of their HACCP systems. 

The HACCP approach, which was recommended by USDA's National Advisory
Committee on Microbiological Criteria for Foods and endorsed by the
scientific community, is based on seven guiding principles.  The
principles center around the identification of biological, physical,
and chemical hazards that are reasonably likely to occur in meat and
poultry plants and the establishment of critical points in the
production process where controls can be applied to prevent,
eliminate, or reduce those hazards. 

Concerned about HACCP implementation, the Congress mandated that GAO
(1) determine whether the system adopted by USDA in its regulations
is consistent with the seven HACCP principles endorsed by the
Advisory Committee, (2) evaluate whether the HACCP training program
for USDA inspectors is adequate and science-based, and (3) determine
if there is an adequate dispute resolution (appeals) process between
plants and USDA under the new HACCP inspection system. 

As part of our review, we compared the HACCP principles endorsed by
the Advisory Committee with those included in the HACCP regulations
and visited 32 meat and poultry plants (out of about 2,600 that have
implemented HACCP programs) across the country to determine how the
principles were applied in their HACCP plans.  We did not evaluate
the plants' hazard analyses or how well they were implementing their
HACCP plans.  The selected plants produce a variety of meat and
poultry products through a number of different processes.  To
evaluate HACCP training for USDA inspectors, we reviewed USDA's HACCP
training curriculum, participated in USDA's HACCP training program,
reviewed and analyzed evaluations of training conducted by industry
and by USDA, and conducted our own nationwide telephone survey of
inspectors most recently trained in the HACCP system.  (App.  I
presents the results of this survey.) We also reviewed the
regulations concerning appeals and interviewed industry and
inspection personnel to obtain their opinions on how well the appeals
process is working.  Appendix II describes our methodology in detail. 

   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

USDA's HACCP regulations, along with implementing directives and
other guidance, are consistent with the seven HACCP principles
endorsed by the Advisory Committee.  The 32 plants we visited have
HACCP plans that are based on the principles; however, some plant
managers excluded certain hazards (such as metal contamination)
because they believed that existing quality control programs or good
manufacturing practices (such as routinely calibrating production
equipment) effectively controlled them.  To ensure appropriate
verification and oversight by USDA inspection personnel, however, the
regulations state that plants must identify all hazards reasonably
likely to occur in their HACCP plans and control those hazards
through their HACCP programs.  USDA regulations preclude the use of
non-HACCP programs to control hazards that are reasonably likely to
occur because the Department's inspectors focus on ensuring
compliance with HACCP regulations and have limited oversight over
non-HACCP programs. 

Generally, inspectors received the training needed to oversee plants'
implementation of HACCP programs, although many inspectors responding
to our nationwide survey reported that they would benefit from
refresher courses.  USDA's training program provided a basic
introduction to HACCP's science-based principles while emphasizing
the compliance aspects of the inspectors' HACCP duties.  However,
according to our review of USDA's HACCP training curriculum and the
results of our survey, several aspects of the training program need
to be clarified and reinforced in order to provide inspectors with
the tools they need to conduct consistent and effective inspections
of plants' compliance with HACCP requirements.  Many survey responses
suggested that the training was unclear about (1) inspectors'
authority to request that plants make changes to their HACCP plans,
(2) the correct frequency for microbial testing for salmonella, (3)
the actions inspectors can take if they become aware of microbial
contamination that a plant has identified as a hazard through
programs that are outside of its HACCP plan, and (4) situations in
which it is appropriate for inspectors to record instances of
noncompliance with the HACCP requirements by issuing noncompliance
notices (referred to as noncompliance records by FSIS).  USDA's own
evaluation of inspectors' training in 1998 identified areas of
training that should be strengthened. 

USDA's dispute resolution process provides industry with an
appropriate mechanism to appeal inspectors' enforcement actions.  All
of the plant managers we interviewed were generally aware of how the
process worked, and many had used it to appeal inspectors' findings
and decisions that, in their opinion, were erroneous.  These managers
questioned the accuracy of the information contained in the documents
that inspectors prepare when they believe that a plant has failed to
comply with one or more of the HACCP requirements.  For example,
managers said that inspectors at times document instances of
noncompliance by citing incorrect regulations or marking the wrong
trend indicators.  Plant managers said that they follow the advice of
industry associations, such as the National Meat Association, and
appeal noncompliance notices that appear to be inaccurate.  Recurring
instances of noncompliance can result in an FSIS determination that
the plant's HACCP system failed.  However, USDA regulations do not
explicitly state the number or types of noncompliance notices that
can result in such a determination.  Therefore, plant personnel want
to ensure that these notices of noncompliance are justified and
accurately documented.  We could not verify the accuracy of the plant
managers' observations because USDA's new automated appeals tracking
system contains incomplete and inconsistent information.  This report
contains a number of recommendations to the Secretary of Agriculture
designed to improve the HACCP plans, improve inspector training, and
ensure the reliability of information on plant appeals. 

   BACKGROUND
------------------------------------------------------------ Letter :2

For over a decade, scientific studies have highlighted the need for a
new approach to ensure food safety.  In 1983 and again in 1987, the
National Academy of Sciences reported on the need for improved
methods that focused on the prevention and reduction of microbial
pathogens.  The Academy and other organizations, including GAO,
endorsed the HACCP approach as an effective tool for preventing
and/or reducing hazards in the food supply.  Following the
recommendation of the National Advisory Committee on Microbiological
Criteria for Foods,\1 USDA issued the Pathogen Reduction and HACCP
rule in July 1996.  The rule establishes requirements for meat and
poultry plants to reduce the occurrence of pathogenic microorganisms
in their products, reduce the incidence of foodborne illness
associated with meat and poultry products, and provide a new
framework for the modernization of the current system of meat and
poultry inspection.  The HACCP rule applies to all federally and
state-inspected meat and poultry slaughter and processing plants in
the United States.  Table 1 summarizes the implementation schedule
for these plants.  In USDA, FSIS has overall responsibility for
overseeing HACCP implementation.  Within FSIS, the Office of Field
Operations oversees 18 district offices throughout the country that
conduct inspection and enforcement operations.\2

                                Table 1
                
                 HACCP Implementation Schedule for Meat
                           and Poultry Plants

                                                    Implementation
Plant size                      Number of plants    date
------------------------------  ------------------  ------------------
Large plants (500 employees or  Approximately 300   January 1998
more)                           plants

Small plants (between 10 and    Approximately       January 1999
499 employees)                  2,300 plants

Very small plants (less than    Approximately       January 2000
10 employees or annual sales    3,300 plants
of less than $2.5 million)
----------------------------------------------------------------------
To prepare its inspectors for their new responsibilities under the
HACCP rule, FSIS developed an 8-day HACCP training course.  As of
February 1999, about 4,100 inspectors (out of a total of about 4,500
to be trained in the HACCP program) had participated in the course. 
Two USDA facilitators--one representing FSIS management and one
representing the inspectors' union--led the training courses.  The
courses were offered on a ï¿½just-in-timeï¿½ basis to coincide with the
3-year HACCP implementation schedule.  The facilitators followed a
carefully scripted program, consisting primarily of videos as a
teaching tool, to ensure consistency among the classes given in
different locations. 

--------------------
\1 This committee provides scientific advice and recommendations to
the Secretaries of Agriculture, Commerce, Defense, and Health and
Human Services. 

\2 At the time of our review, FSIS Field Operations had 18 district
offices.  Subsequently, FSIS reorganized its field operations into 17
district offices.  Throughout this report, however, information on
appeals and survey responses is based on the 18-district office
structure. 

   USDA'S RULES EMBODY HACCP
   PRINCIPLES, BUT SOME PLANTS
   RELY ON OTHER PROGRAMS TO
   CONTROL HAZARDS
------------------------------------------------------------ Letter :3

USDA's final HACCP rules embody the seven HACCP principles endorsed
by the Advisory Committee.  While the HACCP plans we reviewed during
our visits to 32 plants were based on these principles, many were at
odds with USDA regulations requiring that HACCP plans be
self-contained documents.  USDA regulations require that all food
safety hazards that are reasonably likely to occur must be controlled
through their HACCP plans so that inspectors can verify that critical
limits are being met and that corrective actions are effective when
those limits are exceeded.  When hazards are controlled through
non-HACCP programs, USDA's ability to monitor the production of safe
food is limited. 

      USDA REGULATIONS ADOPT
      ADVISORY COMMITTEE'S HACCP
      PRINCIPLES
---------------------------------------------------------- Letter :3.1

As early as 1989, the Advisory Committee endorsed HACCP as an
effective and rational approach to ensuring the safety of meat and
poultry productsï¿½one that stresses preventing contamination before it
occurs rather than dealing with it after it is detected.  The
Advisory Committee 's HACCP Principles and Application Guidelines
served as the source document for USDA's July 1996 HACCP implementing
regulation:  Pathogen Reduction; Hazard Analysis and Critical Control
Point (HACCP) Systems.\3 Our analysis of USDA regulations and the
Advisory Committee's HACCP guidelines found little if any deviation
from the Advisory Committee's seven HACCP principles.  Table 2
summarizes these principles. 

                                Table 2
                
                         Seven HACCP Principles

Principle                       Description
------------------------------  --------------------------------------
Principle 1:                    Plants determine the food safety
Conduct a hazard analysis.      hazards that are reasonably likely to
                                occur and identify the preventive
                                measures they will apply to control
                                these hazards. Hazards can be
                                biological, chemical, or physical.

Principle 2:                    Plants identify a point, step, or
Identify critical control       procedure in a food production process
points.                         where controls can be applied to
                                prevent, eliminate, or reduce a food
                                safety hazard to an acceptable level.

Principle 3:                    Plants set the maximum or minimum
Establish critical limits for   value at which a biological, chemical,
each critical control point.    or physical hazard must be controlled
                                at each critical control point to
                                prevent, eliminate, or reduce the food
                                safety hazard to an acceptable level.

Principle 4:                    Plants establish monitoring activities
Establish monitoring            that will ensure the process is under
requirements.                   control at each critical control
                                point.

Principle 5:                    Plants define actions to be taken when
Establish corrective actions.   monitoring discloses a deviation from
                                an established critical limit.

Principle 6:                    Plants are required to maintain
Establish record-keeping        documentation of their hazard analysis
procedures.                     and HACCP plan, as well as records
                                documenting the monitoring of critical
                                control points, critical limits,
                                verification activities, and the
                                handling of processing deviations.

Principle 7:                    Plants establish verification
Establish verification          procedures to ensure that HACCP plans
procedures.                     accomplish their intended goal--
                                ensuring the production of safe
                                products.
----------------------------------------------------------------------
The HACCP regulations require plants to address each of the seven
principles during the development of their HACCP plans.  A food
safety hazard that is reasonably likely to occur is one for which a
meat or poultry plant would establish controls because the hazard has
occurred in the past or because there is a reasonable possibility
that it will occur in the absence of those controls.  Table 3
describes the three types of hazards that may occur in meat and
poultry plants. 

                                Table 3
                
                   Biological, Chemical, and Physical
                                Hazards

Type of hazard                  Definition
------------------------------  --------------------------------------
Biological                      Living organisms that can put human
                                health at risk: bacteria, parasites,
                                protozoa, and viruses. Some of the
                                major organisms that can cause
                                foodborne illness from eating meat and
                                poultry products are
                                salmonella,listeria, campylobacter,
                                and E.coli 0157:H7.

Chemical                        Naturally occurring substances, such
                                as aflatoxins and mycotoxins, and
                                added substances, such as pesticides,
                                fungicides, fertilizers, lubricants,
                                or cleaners.

Physical                        Foreign materials not normally found
                                in a food product that can cause
                                illness or injury, such as glass,
                                metal, and plastic.
----------------------------------------------------------------------
Since publishing its HACCP regulations in July 1996, USDA has issued
several clarifications and modifications, including a requirement
that all HACCP plans must contain at least one critical control point
and must be self-contained documents that do not reference good
manufacturing practices as mechanisms for controlling hazards. 

In addition to requiring the development of HACCP plans, plants must
comply with the following other requirements of the regulations: 

  -- Plants must develop and implement written Sanitation Standard
     Operating Procedures as a prerequisite to HACCP
     implementation.\4

  -- Slaughter plants must regularly test for the presence of E. 
     coli bacteria to verify the adequacy of their process controls
     for preventing and removing fecal contamination and associated
     bacteria. 

  -- Plants that produce raw or ground beef, raw or ground chicken,
     ground turkey, or raw pork products must meet certain pathogen
     reduction performance standards for salmonella.  This provision
     sets targets for reducing the incidence of salmonella
     contamination and requires that products sampled and tested for
     salmonella not test positive at rates exceeding the standard for
     each class of product.  For example, the maximum number of
     positive tests allowed per 55 hogs tested are 6 (or 8.7
     percent), while the maximum number allowed per 51 chickens is 12
     (or 20 percent).  The salmonella performance standards provide a
     substantive basis for judging the effectiveness of HACCP
     programs, according to USDA. 

In its totality, USDA's HACCP regulatory framework exceeds the
requirements of the seven principles of the HACCP approach as
endorsed by the Advisory Committee. 

--------------------
\3 9 CFR Part 304, et al. 

\4 These procedures describe all sanitation procedures that meat and
poultry plants conduct before and during daily operations to prevent
direct contamination of their products. 

      HACCP PLANS FOLLOW SEVEN
      PRINCIPLES, BUT SOME PLANTS
      CONTROL HAZARDS THROUGH
      MECHANISMS OTHER THAN HACCP
---------------------------------------------------------- Letter :3.2

In our on-site review of 57 HACCP plans at 32 plants, we found that
each plan was developed using the seven principles and included at
least one critical control point for controlling biological
hazards.\5 Because HACCP plans are proprietary documents, many of the
plants did not authorize us to make copies of their HACCP plans for
further analysis.\6 However, according to our analysis of the 28
plans that we were allowed to study in detail, 13 contained
statements indicating that a particular food safety hazard was not
reasonably likely to occur because it was controlled through good
manufacturing practices.  Thus, these HACCP plans were not the
self-contained documents that USDA has required since January 1998. 
For example, one plan included a statement that microbial hazards
were not reasonably likely to occur during product storage because
the storage temperature and condition of the coolers was sufficiently
controlled through good manufacturing practices. 

USDA inspectors do not have the authority to approve HACCP plans. 
They have only the authority to verify that the plans establish
critical control points for controlling the food safety hazards that
plants identified during the hazard analysis phase of developing
their HACCP plans.  Some inspectors told us that they cannot verify
other control mechanisms, such as good manufacturing practices, even
though they are referenced in the plant's HACCP plans.  When
inspectors learn that plants are referring to good manufacturing
practices in their HACCP plans, they are instructed to refer these
cases to FSIS district management for further review.  District
managers can then request the plants to reassess their HACCP plans
within 30 days to bring them into compliance with HACCP requirements. 
However, USDA directed the plants to reassess only one of the 13
HACCP plans that we had identified as making reference to good
manufacturing practices. 

Furthermore, plant managers representing 12 of the 32 plants we
visited told us that they identified and controlled one or more food
safety hazards through process control mechanisms other than their
HACCP plans.  For example, some managers said they have metal
detectors to control the incidence of metal contamination in their
products; however, they elected not to include those in their HACCP
plans.  Other managers reported controlling the condition and
temperature of the incoming product, the final shipment temperature,
and chemical contamination through total quality control programs and
good manufacturing practices.  One manager told us that his plant had
originally included several critical control points in its HACCP
plan, but because USDA inspectors were finding too many instances of
noncompliance, the control points were moved to the plant's overall
quality control program.  Another manager said that he controls the
temperature of all products awaiting shipment from his plant through
good manufacturing practices because doing so under the plant's HACCP
plan would require a large amount of time-consuming paperwork and
would require the plant to include the control in its pre-shipment
reviews. 

Plants may be opting to control some hazards through programs other
than HACCP systems in part because of the National Advisory Committee
and the industry's support of the use of such an approach.  The
Advisory Committee maintains that the production of safe food
products requires a HACCP system to be built on a solid foundation of
other control programs, such as good manufacturing practices, quality
control programs, and standard operating procedures.  It further
states that such programs are often proprietary and established and
managed separately from a HACCP plan.  Industry supports the use of
good manufacturing practices to control hazards that are reasonably
likely to occur.  For example, industry representatives said that in
a facility with well-functioning prerequisite programs that control
product temperature, bacteriological hazards are not likely to occur
and thus should be excluded from a HACCP plan.  On the other hand,
industry representatives acknowledge that in a facility without such
prerequisite programs or where such programs are not well managed,
the loss of temperature control could allow the growth of
microbiological hazards that can be better managed through a HACCP
plan. 

USDA recognizes the usefulness of prerequisite programs, such as
quality control programs and good manufacturing practices, in the
production of safe products.  However, USDA maintains that to ensure
the effective oversight of HACCP systems, it must be able to verify
plants' compliance with HACCP regulations, and inspectors cannot
verify non-HACCP plans.  Therefore, USDA requires plants to identify
and control through their HACCP plans all hazards reasonably likely
to occur.  HACCP plans that refer to such programs as good
manufacturing practices limit federal oversight and thus are not in
compliance with the regulations. 

--------------------
\5 The regulations state that plants may have one or more HACCP plans
addressing various production processes or products.  Accordingly,
some of the 32 plants we visited had more than one HACCP plan. 

\6 All 32 plants allowed us to look at their HACCP plans during our
visits.  In total, we reviewed 57 plans. 

   INSPECTORS GENERALLY REPORTED
   SATISFACTION WITH HACCP
   TRAINING BUT ALSO IDENTIFIED
   WEAKNESSES
------------------------------------------------------------ Letter :4

According to USDA inspectors and our review of the training
materials, inspectors generally received the training they needed to
verify that meat and poultry plants comply with HACCP principles.  In
addition, their training provided a basic introduction to the
scientific principles of the HACCP approach while focusing on the
compliance aspects of their duties.  Nearly two-thirds (65 percent)
of the inspectors responding to our survey indicated that the
training they received adequately prepared them for their HACCP
duties; however, as many inspectors also indicated that they would
benefit from refresher courses.  Survey responses also identified
training weaknesses in the following areas:  (1) inspectors'
authority to ask for changes to a plant's HACCP plan, (2) frequency
of salmonella sample collections, (3) inspectors' authority to take
action when a plant's microbial testing program not cited in the
plant's HACCP plan detects contamination, and (4) inspectors'
issuance of noncompliance notices.  In its 1998 evaluation of
inspection activities during the first phase of HACCP implementation,
USDA also identified areas of training that should be strengthened.\7

--------------------
\7 Evaluation of Inspection Activities During Phase One of HACCP
Implementation, Food Safety and Inspection Service, United States
Department of Agriculture, July 1998. 

      INSPECTORS' TRAINING
      EMPHASIZES COMPLIANCE
---------------------------------------------------------- Letter :4.1

The HACCP system shifts the responsibility for ensuring the safety of
meat and poultry products from USDA to industry.  Therefore, HACCP
training programs for industry and for USDA inspectors reflect their
different roles and responsibilities.  The regulations require that
plant managers in charge of HACCP operations be trained in the
application of the seven HACCP principles, including the development
of a HACCP plan.  USDA's role, on the other hand, is to ensure that
plants comply with HACCP regulations.  Thus, the Department's
inspector training emphasizes compliance rather than the development
and implementation of HACCP plans. 

In 1994, the International HACCP Alliance was formed to help the meat
and poultry industry prepare for HACCP implementation by, among other
things, standardizing HACCP training for plant personnel.\8 The
Alliance is not involved in training; rather, it reviews and approves
HACCP training curricula before accrediting other organizations'
training programs.  The curriculum for industry includes courses on
how to recognize the relationship between the HACCP principles and
food safety; how to identify and control hazards; how to design
control measures to prevent, reduce, or minimize hazards; and how to
identify critical control points using valid scientific criteria. 
Individuals who complete an Alliance course are said to be
HACCP-certified, although there is no requirement for such
certification in the HACCP regulations.  Nor is there a requirement
for industry HACCP personnel to provide proof of such training to
USDA inspection personnel. 

In contrast with industry's training, USDA's training of its
inspection workforce is in-house, and its program focuses on how
inspectors verify plants' compliance with their HACCP plans.  Because
the inspectors' responsibilities under the HACCP regulations are to
document breakdowns in plant-established controls, their training
includes only an introduction to the science-based HACCP principles;
it does not stress the scientific basis behind hazard analyses,
critical control points, and critical limits.  Of the 12 separate
modules offered in USDA's HACCP training program, only one covers the
science-based HACCP principles. 

--------------------
\8 The HACCP Alliance includes over 100 members from industry
associations, educational foundations, professional societies,
universities, government agencies and related private companies. 

      USDA INSPECTORS WERE
      GENERALLY SATISFIED WITH
      TRAINING BUT IDENTIFIED SOME
      WEAKNESSES
---------------------------------------------------------- Letter :4.2

Nearly two-thirds of the respondents to our nationwide survey rated
their overall preparation for work as HACCP inspectors after training
as good or excellent, while as many said that they would benefit from
refresher courses.  Over two-thirds rated their course facilitators
as good or excellent, and more than half said that the training was
provided just in time.  However, only 28 percent of the respondents
said that the real-life examples used during training were very
useful. 

To examine in more detail the strengths and weaknesses of USDA's
training, we asked inspectors to rate their understanding of several
specific HACCP concepts addressed in training.  Most respondents (81
to 85 percent) rated their understanding of various aspects of the
microbial testing required by the HACCP regulations as good or
excellent.  However, fewer respondents (53 to 59 percent) rated their
understanding of how to recognize a HACCP system failure and how
HACCP plans are developed as good or excellent.  Table 4 summarizes
the inspectors' responses to these questions. 

                                Table 4
                
                 Understanding HACCP Concepts Discussed
                              in Training

Understanding of HACCP concepts rated ï¿½goodï¿½ to
ï¿½excellentï¿½                                                    Percent
--------------------------------------------------  ------------------
The proper method for E. coli sampling                              85
The proper method for salmonella sampling                           85
The purpose of collecting E. coli and salmonella                    84
 samples
Inspectors' responsibilities regarding salmonella                   82
 sampling
Inspectors' responsibilities regarding E. coli                      81
 sampling
The difference between the old inspection system                    72
 and the new HACCP system
What it means to verify a HACCP plan                                63
The difference between the old and the new                          63
 Performance-Based Inspection System
The changes in standard sanitation operating                        62
 procedures inspections
The difference between basic inspections and                        61
 system inspections
How to recognize a HACCP system failure                             59
How plants develop their HACCP plans                                53
----------------------------------------------------------------------
Note:  161 inspectors responded to these questions. 

We also asked the inspectors to rate their preparation for performing
specific HACCP-based inspection tasks after their training.  Over
three-quarters of the respondents (77 percent) reported that their
preparation for conducting day-to-day HACCP compliance activities was
good to excellent, but fewer (56 percent) said that their preparation
for using the appropriate trend indicators was good to excellent. 
USDA uses trend indicators to categorize the specific types of
noncompliance identified by inspectors in HACCP plants.  For example,
if an inspection procedure revealed that a plant employee had not
initialed and dated an entry on a record required by the HACCP plan,
the inspector would mark the record-keeping trend indicator on the
noncompliance record.  USDA also uses trend indicators to determine
whether additional regulatory or administrative actions should be
taken.  Table 5 summarizes the inspectors' responses to the group of
questions dealing with preparation for HACCP duties after training. 

                                Table 5
                
                   Preparation for HACCP Duties After
                                Training

Preparation for HACCP duties rated as ï¿½goodï¿½ to
ï¿½excellentï¿½                                                    Percent
--------------------------------------------------  ------------------
Day-to-day verification of plant compliance                         77
The resources to use if uncertain about HACCP                       77
 principles
Taking action in cases of noncompliance                             70
Verifying that the HACCP plan complies with                         69
 requirements
Handling disputes over noncompliance notices                        68
Tracking changes to the HACCP plan                                  63
Responding to appeals by plants                                     61
Overseeing plants' testing for E. coli                              59
Using trend indicators when issuing noncompliance                   56
 notices
----------------------------------------------------------------------
Note:  161 inspectors responded to these questions. 

Inspectors' responses to another set of questions showed a
significant degree of confusion.  We asked inspectors about three
specific situations covered in training that appeared to be unclear
or ambiguous in the HACCP courses we attended.  In each case, we
asked the inspectors to select the response closest to what they had
learned in training.  Furthermore, we asked the FSIS Technical
Services Center to provide us with what it considers to be the
correct response to each of the questions.\9 The following summarizes
the inspectors' responses to the three questions and the percent that
selected the correct answer to each question, according to the
Technical Services Center: 

  -- Are inspectors allowed to ask for changes to the HACCP plan when
     they conduct basic HACCP compliance procedures?  According to
     the Technical Services Center, the correct response is that
     inspectors are not allowed to request plants to make changes to
     their HACCP plans, even if they believe changes are necessary. 
     Sixty-one percent of the respondents to our survey selected the
     correct response, 21 percent said that inspectors are allowed to
     ask for changes, and 17 percent were uncertain.  In total, about
     one-third of the respondents were uncertain or provided the
     incorrect response to this question. 

  -- How frequently should inspectors collect salmonella samples at
     the plant after being notified by their USDA district management
     office to begin taking samples?  According to the Technical
     Services Center, the correct answer is that salmonella samples
     should be collected every day the product is produced. 
     Sixty-five percent of the respondents to our survey selected the
     correct response, 12 percent said ï¿½as time permits,ï¿½ and 20
     percent were uncertain.  In total, about one-third of the
     respondents provided the incorrect answer to this question or
     were uncertain. 

  -- Are inspectors allowed to take action if they become aware of
     microbial contamination identified through testing programs
     (other than E.coli and salmonella) that are not part of the
     HACCP plans?  According to the Technical Services Center, the
     correct answer is that inspectors have the authority to take
     whatever action they deem necessary when they suspect product
     contamination, whether or not the plant has included testing for
     microbiological hazards (other than E-coli and salmonella) in
     its HACCP plan.  Thirty-two percent of the respondents selected
     the correct response, 44 percent selected the incorrect
     response, and 21 percent were uncertain.  Nearly two-thirds (65
     percent) of the respondents gave the incorrect answer or were
     uncertain. 

In summary, the responses to these three questions indicate
considerable confusion about these aspects of an inspector's HACCP
duties.  For example, only 13 percent of the inspectors selected the
responses that the Center provided as the correct answers to all
three questions, and one-third provided the correct response to only
one of the three questions. 

There is also confusion concerning how the training program that
inspectors attended addressed their responsibilities for HACCP
compliance.  Specifically, we asked the inspectors whether they were
taught to (1) issue a noncompliance record as soon as a noncompliance
is detected or (2) allow the HACCP system to work first.  Recording
instances of noncompliance with HACCP systems is a very important
aspect of the inspectors' duties, and the training courses we
attended suggested that inspectors should allow the HACCP system to
work first.  However, the Technical Services Center said that there
is no definitive answer.\10 Accordingly, the inspectors responses
varied--67 percent said they should give a HACCP system a chance to
work first in a noncompliance situation, 25 percent said they should
issue a noncompliance record immediately when noticing a
noncompliance with HACCP requirements, and 8 percent were either
uncertain or had other responses. 

During our plant visits, inspectors recommended that HACCP training
place more emphasis on when and how to prepare noncompliance notices
and how to use noncompliance trend indicators.  Plant managers also
frequently stated that inspectors should do a better job of
documenting instances of noncompliance and selecting the appropriate
trend indicators for each instance.  Finally, a 1998 USDA evaluation
of HACCP implementation pointed out that inspection personnel
expressed a need for further understanding of how to use trend
indicators.  Appendix I presents inspectors' responses to our
nationwide survey. 

--------------------
\9 In June 1997, FSIS established the Technical Service Center to
provide accurate and consistent information regarding the development
and implementation of inspection programs to inspection personnel and
industry. 

\10 The Technical Services Center told us that there is no definitive
response to this question, and other FSIS officials said that the
answer depends on the type of HACCP inspection being conducted.  That
is, if inspectors conducting a basic verification procedure find an
instance of noncompliance, they should immediately take action.  On
the other hand, when conducting a procedure to verify an entire HACCP
system, inspectors should allow the HACCP system to work first. 

   DISPUTE RESOLUTION PROCESS IS
   WORKING, BUT THE TRACKING
   SYSTEM HAS CERTAIN WEAKNESSES
------------------------------------------------------------ Letter :5

The appeals process under the HACCP regulations for plants charged
with noncompliance appears to provide an adequate avenue of redress. 
The plant managers and inspectors we interviewed generally knew how
the process worked.  However, about half of the plant managers had
concerns about the accuracy of the information contained in the
inspectors' noncompliance notices and said that they tend to appeal
noncompliance findings they believe are inaccurate.  We could not
determine the nature and extent of these appeals because FSIS'
Industry Appeals Tracking System lacks complete and consistent data. 

      APPEALS PROCESS UNDER HACCP
      REGULATIONS APPEARS ADEQUATE
---------------------------------------------------------- Letter :5.1

Inspectors are required to issue noncompliance notices to plants
failing to comply with HACCP regulations.  Multiple, recurring
findings of noncompliance without successful interventions to correct
a problem can result in additional enforcement actions, such as the
suspension of inspection, which could result in slowing production or
shutting down the plant. 

The right to appeal enforcement actions and the process for making
such appeals have not changed since the HACCP regulations were
implemented, and, as before, the existing mechanism provides plants
ï¿½due processï¿½ as required by law.  That is, the plants have an avenue
to appeal enforcement actions that they believe are incorrect.  The
regulations give the plants the right to appeal inspectors' findings
and decisions orally or in writing.\11 An appeal must first be
submitted to the inspector with the most immediate jurisdiction over
the appealï¿½in most cases, the inspector-in-charge.  If an appeal is
rejected at this level, the plant can appeal further through the FSIS
chain of commandï¿½circuit supervisor, district manager, Assistant
Deputy Administrator for District Inspection Operations, and Deputy
Administrator for the Office of Field Operations.  All of the
inspectors and plant officials we interviewed were aware of their
plants' right to appeal, and almost all were familiar with the
process and how it works.  FSIS officials and inspectors said that
with the implementation of HACCP requirements, FSIS has made a
concerted effort to inform plants of their right to appeal
enforcement actions and the process for doing so. 

While the appeals procedures have not changed under the HACCP
regulations, some inspectors and plant officials perceived that the
process is more formal now than it used to be.  For example, several
managers told us that under the old inspection system, plants
generally made oral appeals, but now because of FSIS' preference,
plants generally submit written appeals.  Similarly, inspectors said
they used to explain orally why an appeal was rejected or granted,
but now they are encouraged to provide plants with written
explanations. 

--------------------
\11 9 CFR 306.5 and 9 CFR 381.35. 

      CONCERNS OVER INACCURATE
      NONCOMPLIANCE NOTICES RESULT
      IN PLANT APPEALS
---------------------------------------------------------- Letter :5.2

When issuing noncompliance notices, inspectors are required, among
other things, to cite the applicable regulation that was violated and
to identify the trend indicator that specifies the type of
noncompliance observed.  Inspectors review noncompliance notices
periodically to identify noncompliance trends, such as a plant's
repeatedly failing to monitor a critical control point or repeatedly
failing to take effective corrective actions.  However, about half of
the 32 plant managers we interviewed expressed concerns about the
accuracy of the information contained in the noncompliance notices
issued to their plants.  Some managers also told us that inspectors
often issue noncompliance notices for violations that are in the
process of being corrected, as outlined in their HACCP corrective
action plans, before the corrective action had a chance to work. 

Accurately prepared noncompliance notices are essential because USDA
uses trend data to decide whether additional enforcement action at a
plant is necessary.  Plant managers are concerned because USDA has
not issued guidance on the use of trend data or clarified how many
instances of noncompliance would result in a plant's being shut down. 
Accordingly, 17 plant managers said they appeal inspectors'
noncompliance notices when they contain factual errors, incorrect
regulatory citations, improper trend indicators, and/or when they
were issued before the plant was allowed adequate time to implement
the corrective action.  For example, one manager emphasized that his
plant had never appealed a noncompliance notice prior to the HACCP
regulations, but now he appeals because there is no guidance on the
number of noncompliance notices that could result in USDA's slowing
down production or shutting the plant.  Similarly, three other plant
managers said that the National Meat Association told them to appeal
all noncompliance notices for the aforementioned reasons. 

      DATA IN THE APPEALS TRACKING
      SYSTEM ARE INCOMPLETE AND
      INCONSISTENT
---------------------------------------------------------- Letter :5.3

During 1998, USDA established the automated Industry Appeals Tracking
System to monitor industry appeals.  Inspectors are required to
submit appeals information to their district offices weekly for
compilation into this tracking system.  The information is to include
the names and addresses of the plants making the appeals; the dates
the appeals were made, resolved, and closed; the numbers of related
noncompliance notices, descriptions of the decisions or actions that
a plant is appealing; and explanations of the resolution.  FSIS'
instructions for completing the tracking report provide inspectors
with an example of the information that should be submitted. 

While data in the appeals tracking system are incomplete and
inconsistent, they still show that plants make use of the appeals
system.  For example, from June 6, 1998, through September 7, 1999,
234 plants made a total of 1,564 appeals.  Of the 1,564 appeals,
1,051 were denied, 449 were granted, and 64 were under review. 
Plants located in 6 of the 18 FSIS districts--Springdale, Des Moines,
Jackson, Alameda, Dallas, and Raleigh--filed 1,099 of the appeals. 
Table 6 summarizes these data. 

                                         Table 6
                         
                         Appeals Data from FSIS Industry Appeals
                          Tracking System, June 6, 1998, Through
                                    September 7, 1999

                                       Number
                                           of              Number    Number
                             Number    plants                  of        of     Number of
                                 of  appealin     Total   appeals   appeals       appeals
FSIS district    States      plants         g   appeals    denied   granted  under review
---------------  --------  --------  --------  --------  --------  --------  ------------
Springdale       AR, LA,        120        27       251       184        64             3
                  OK
Des Moines       IA, NE         140        26       202       131        69             2
Jackson          AL, MS,        157        23       190       144        44             2
                  TN
Alameda          CA             298        23       129       106        22             1
Dallas           TX             181        22       208       118        77            13
Lawrence         KS, MO          90        17        78        40        37             1
Chicago          IL, IN         224        11        83        54        28             1
Raleigh          NC, SC         107        11       119        81        33             5
Atlanta          FL, GA         147        10        82        70        12             0
Minneapolis      MN, MT,         91        11        50        33        17             0
                  ND, SD,
                  WY
Beltsville\a     DE, MD,         80         9        46        18         7            21
                  VA
Philadelphia     PA             154         9        25        21         4             0
Madison          MI, WI         132         9        25        16         6             3
Boulder          AZ, CO,         77         7        37        13        14            10
                  NM, NV,
                  UT
Albany           NJ, NY         233         7        12         7         5             0
Pickerington     KY, OH,        118         5        17        12         5             0
                  WV
Boston\b         CT, ME,         99         5         6         3         2             1
                  MA, NH,
                  RI,VT
Salem\c          AK, HI,        107         2         4         3         0             1
                  ID, OR,
                  WA
=========================================================================================
Total                         2,555       234     1,564     1,051       449            64
-----------------------------------------------------------------------------------------
\a Includes the District of Columbia. 

\b Subsequent to our review, the Boston District Office was closed
because FSIS reorganized its field office operations. 

\c Includes American Samoa and Guam. 

When we attempted to analyze the extent to which plants appeal
noncompliance notices they believe to be inaccurate, we found that
the data contained in the Industry Appeals Tracking System were
inconsistent and incomplete.  Inspectors and district managers do not
always submit thorough descriptions and explanations of the appeal
cases.  For example, some district offices provided only a
description of the noncompliance notice being appealed, but no
explanation of the basis for granting or denying the appeal.  Other
district offices provided only partial descriptions or did not
include any kind of description.  Furthermore, in comparing the
appeals listed on the appeals tracking report with the lists of
appeals provided by seven of the plants we visited, we found that the
tracking report excluded 9 of the 64 appeals one plant had made and 7
of the 25 appeals another plant had made.  In addition, the appeals
tracking system did not contain any data for five plants, although
these plants had received written appeals determinations from FSIS. 

These irregularities can be attributed in part to (1) inspectors' not
submitting appeals data to their respective district offices for
entry into the tracking system, (2) inspectors' time constraints, or
(3) FSIS data entry errors.  For example, an inspector and a circuit
supervisor told us that they did not submit such information to the
district office because they did not know they were required to do
so.  Another inspector said that he did not have sufficient time to
complete the required data submissions and that the instructions were
too confusing.  Finally, some district offices submitted inaccurate
entries to FSIS headquarters for entry to the tracking system, and
some entries were incorrectly entered into the system at the
headquarters level. 

   CONCLUSIONS
------------------------------------------------------------ Letter :6

USDA's adoption of the HACCP system is designed to prevent or reduce
contamination in meat and poultry plants and thus enhance the safety
of the products they produce.  USDA regulations implementing the
HACCP system are consistent with the seven HACCP principles endorsed
by the National Advisory Committee on Microbiological Criteria for
Foods but also contain regulatory provisions to ensure USDA's
oversight.  Although USDA does not discourage plants from using
quality control or good manufacturing practices programs, it expects
them to identify and control food safety hazards that are reasonably
likely to occur thorough their HACCP plans.  USDA does not allow
plants to refer to good manufacturing practices in their HACCP plans
as mechanisms for controlling such hazards.  However, some meat and
poultry plants continue to rely on non-HACCP programs to control
these types of hazards.  This practice limits the consistent
implementation of the HACCP system nationwide as well as USDA's
oversight of food safety at these plants. 

HACCP training for inspectors was for the most part sufficient to
prepare them for their new inspection duties.  However, weaknesses in
the training program--such as whether inspectors have the authority
to ask for changes to a HACCP plan, when they should collect
salmonella samples, and when it is appropriate to issue noncompliance
notices--affect USDA's ability to ensure the consistent and effective
oversight of the HACCP system. 

USDA's process for resolving disputes provides industry with an
avenue to appeal enforcement actions.  However, inconsistent and
incomplete data preclude FSIS from effectively analyzing the types of
HACCP-related noncompliance actions that are appealed or the extent
to which plants appeal inaccurate noncompliance notices. 

   RECOMMENDATIONS TO THE
   SECRETARY OF AGRICULTURE
------------------------------------------------------------ Letter :7

To enable USDA to oversee all aspects of food safety at meat and
poultry plants, we recommend that the Secretary of Agriculture direct
the Administrator of FSIS to review all HACCP plans to verify that
plants are identifying and controlling food safety hazards that are
reasonably likely to occur through their HACCP programs.  This review
will ensure that USDA appropriately oversees the HACCP system. 

To ensure the consistent inspection of HACCP programs, we recommend
that the Secretary direct the Administrator of FSIS to provide
clarification and additional training for inspectors in the following
areas: 

  -- inspectors' roles, responsibilities, and authorities for
     reviewing and verifying HACCP plans;

  -- inspectors' responsibilities for microbial sampling and the
     frequency of salmonella testing;

  -- inspectors' responsibilities for how and when to file
     noncompliance notices and how to select the correct trend
     indicators. 

To ensure that FSIS has complete and accurate information for
analyzing industry appeals of noncompliance actions under the HACCP
system, we recommend that the Secretary of Agriculture direct the
Administrator of FSIS to (1) issue instructions to FSIS' district
offices clearly stating that inspectors must provide complete,
accurate, timely, and consistent appeals data for the automated
appeals tracking system and (2) periodically review the accuracy and
completeness of the data in the appeals tracking system. 

   AGENCY COMMENTS AND OUR
   RESPONSE
------------------------------------------------------------ Letter :8

We provided USDA with a draft of this report for review and comment. 
We met with USDA officials, including FSIS' Deputy Administrator,
Field Operations.  Overall, USDA concurred with the conclusions and
recommendations contained in the report and found it accurate and
balanced.  USDA also stated that FSIS has recently established a
cadre of HACCP experts who will review HACCP plans to ensure that
plants are identifying and controlling the hazards that are
reasonably likely to occur.  USDA also noted that the Administrator
of FSIS has recently appointed a committee to address the role of
training and education in FSIS, including issues related to HACCP
training.  Beyond these overall observations, USDA provided minor
technical suggestions, which we incorporated into the report as
appropriate. 

We conducted our review from February through November 1999 in
accordance with generally accepted government auditing standards. 

---------------------------------------------------------- Letter :8.1

We will send copies of this report to the congressional committees
with jurisdiction over food safety issues; the Honorable Dan
Glickman, Secretary of Agriculture, the Honorable Thomas Billy,
Administrator, Food Safety and Inspection Service; and other
interested parties.  We will also make copies available to others on
request. 

If you have any questions about this report, please contact me at
(202) 512-5138.  Key contributors to this report are listed in
appendix III. 

Lawrence J.  Dyckman
Director, Food and
 Agriculture Issues

RESULTS OF TELEPHONE SURVEY OF
INSPECTORS
=========================================================== Appendix 1

This appendix presents a copy of the telephone questionnaire used to
survey 161 inspectors nationwide and the results of that survey. 

   TELEPHONE SURVEY
--------------------------------------------------------- Appendix 1:1

Hello, my name is _______________.  I am with the U.S.  General
Accounting Office.  GAO is an independent agency of the U.S. 
Congress, and we are not associated with USDA.  As part of a study we
are conducting on the new HACCP program for meat and poultry plants,
we are conducting a telephone survey of inspectors.  We are calling
inspectors who attended the HACCP training to ask how well that
training prepared them for the new program.  Your name appears on a
nationwide list of inspectors who attended HACCP training for small
plant inspectors.  Is that correct?  (If caller answers no, thank
inspector and terminate interview.) This interview will take about
twenty minutes depending on your answers. 

OK.  Let me read our introduction.  Your name was one of a sample
drawn randomly to represent the views of inspectors nationwide on the
training program, so it is very important that I follow our interview
format.  If you have any other comments about the HACCP program, I'd
like to hold those comments until we've finished the survey
questions.  At the end of the interview, we can discuss any other
issues relating to the HACCP implementation.  If there is any
question in this interview that you prefer not to answer, just tell
me and we'll skip on to the next question, OK? 

----------------------------------------------  ----------------------
1. I'd like to start our interview by asking    29% October 1998
about the two-week HACCP training you attended  26% November 1998
for small plant inspectors. In what month and   24% December 1998
year did you complete that HACCP training?      21% Other months
N=161

2. Were you able to complete the entire         96% Entire training
training program or did you miss 1 day or more  3% Missed 1 day or
of the training? N=161                          more
                                                1% Other
----------------------------------------------------------------------
                                Excellent                                      No opinion
                                      (1)    Good (2)    Fair (3)    Poor (4)         (5)
-----------------------------  ----------  ----------  ----------  ----------  ----------
3. Training for new programs
 such as HACCP is often
 challenging because the
 ideas are new and
 unfamiliar. This next set of
 questions asks you to rate
 the understanding you gained
 for new concepts covered in
 the HACCP training. As I
 read each item, please tell
 me how well you would rate
 your understanding of that
 concept just after you
 completed your training. Our
 categories for these
 questions are excellent,
 good, fair, poor, and no
 opinion.
a. The major differences              12%         60%         22%          4%          2%
 between the previous
 inspection system and the
 new HACCP inspection system
 N=161
b. The differences between            11%         52%         26%          9%          3%
 the old Performance Based
 Inspection Systemï¿½PBISï¿½and
 the revised one N=161
c. The difference between             14%         47%         33%          6%          1%
 basic requirements and other
 requirements for compliance/
 noncompliance actions. That
 is, the difference between
 01 and 02 procedures N=160
d. What it means to verify a          12%         51%         32%          5%          0%
 HACCP plan N=161
e. How to recognize a HACCP           14%         45%         33%          8%          1%
 system failure N=161
f. How plants develop their           18%         35%         35%         11%          1%
 HACCP plans N=161
g. The purpose of collecting          33%         51%          9%          4%          3%
 E. coli and salmonella
 samples N=160
h. The inspector's                    23%         58%         12%          7%          1%
 responsibilities regarding
 E. coli sampling N=161
i. The proper method for E.           29%         56%         11%          2%          3%
 coli sampling N=160
j. The inspector's                    24%         58%         13%          4%          2%
 responsibilities regarding
 salmonella sampling N=161
k. The proper method for              29%         56%         12%          2%          1%
 salmonella sampling N=160
l. The changes in SSOP                12%         50%         29%          6%          4%
 inspections N=161
-----------------------------------------------------------------------------------------
                                      Excellent                                No opinion
                                            (1)  Good (2)  Fair (3)  Poor (4)         (5)
-----------------------------------  ----------  --------  --------  --------  ----------
4. We talked about how well you
 understood new concepts just after
 the HACCP training. Now we'd like
 to talk about the time period when
 you started using the HACCP
 training on the job. We want to
 know how well the training
 prepared you as you started
 implementing your HACCP duties in
 the plant. As I read a list of
 items, I'll ask you to rate your
 preparation to do each one. Again,
 our categories are excellent,
 good, fair, poor, and no opinion.
a. What actions I need to take to           14%       55%       26%        5%          1%
 verify that a HACCP plan at my
 plant complies with requirements
 N=161
b. What day-to-day activities I             13%       64%       16%        6%          1%
 should conduct to verify
 compliance with the plant's HACCP
 plan N=161
c. What actions I need to take in           21%       49%       19%       10%          1%
 cases of noncompliance N=161
d. How I handle disputes over               17%       51%       18%       11%          3%
 noncompliance at the plant N=161
e. What I need to do if there is an         17%       44%       24%       10%          4%
 appeal of a noncompliance record
 N=161
f. What I should do to oversee the          14%       45%       22%        9%         11%
 plant's testing for E. coli N=161
g. How I should use the NR trend            10%       46%       30%       12%          1%
 indicators to track the plant's
 HACCP system performance N=161
h. What I need to do to keep up on          12%       51%       29%        6%          2%
 the plant's changes to the HACCP
 plan N=161
i. What resources I can use if I am         27%       50%       18%        4%          1%
 uncertain about HACCP compliance
 N=160
-----------------------------------------------------------------------------------------
-------------------------------------------------  --------------------------------------
5. Now I'd like for you to think about all         9% Excellent
aspects of the HACCP program and how < well the    b>56% Good
training prepared you, overall, for your work as   27% Fair
a HACCP inspector. Again, our categories are       7% Poor
excellent, good, fair, poor, and no opinion. How   1% No opinion
do you rate your overall preparation for work as   1% Other
a HACCP inspector? N=161

6. In this next set of questions, we'd like to     58% Just in time
ask about some general aspects of the HACCP        17% Too soon
training you attended. First, we'd like to know    17% Not soon enough
how you would rate the timeliness of your HACCP    8% Cannot say
trainingï¿½that is, whether the timing was right     0% Other (Describe.)
for you to conduct your responsibilities as an
inspector. Which category best fits your
situationï¿½just in time, too soon, not soon
enough, or can't you say? N=161

7. Another aspect of training is how well the      37% Excellent
facilitators are able to respond to questions      32% Good
from the audience. Overall, how would you rate     22% Fair
the skill of the training facilitators in          9% Poor
answering questions that came up during your       0% No opinion
training sessions? Would you rate that as          1% Other
excellent, good, fair, poor, or would you say no
opinion? N=161

8. Training is usually more helpful when ï¿½real-    28% Very useful
lifeï¿½ examples are used to practice new concepts.  48% Moderately useful
We'd like to ask how useful such real-life         19% Not very useful
examples were during the training you attended.    4% No opinion
Would you say the examples used at your training   1% Other (Describe.)
were very useful, moderately useful, not very
useful, or would you say no opinion?