6 replies to this topic

[EHam]

As per 9 CFR 417.5 ( c ), prior to shipping product, establishments are required to review the records associated with the production of that product to ensure completeness, including the determination that all critical limits were met, and, if appropriate, corrective actions were taken, including proper disposition of product.
 
Also see FSIS Notice 74-13: http://www.fsis.usda...pdf?MOD=AJPERES

 

Would anyone be interested in sharing an example of a Preshipment Review Procedure that they have in place? I believe it should include the review process for all prerequisite programs that are associated with the production of of a specific lot. I have a draft that is in the beginning stages and I'm not getting a lot of feedback in-house. The USDA inspectors are expecting us to have something in place in the very near future for their direct observation review.

 

Thank you!

[seafood]

We have a bacon wrapped shrimp and scallops in our facility that undergoes USDA inspection.  Like you have stated, you would need to review all the records associated with the product in all facets not only those in prerequisite programs.  For us this means the following:

1.  That the bacon being used is stamped with USDA certified for trichinae in house by the inspector himself reviewing records of adequate freezing temperature/time critical limits as well as doing a direct observation of the bacon entering the blast freezer. 

2.  Receiving and shipping records.

3.  Any in-process packing or raw materials associated with the creation of the product.

4. SSOP and Pre-operational sanitation have been filled out and verified.

5. Metal detection records.

6.  Finished product label checking for allergens and that the label is the one approved by the USDA.

7.  No outstanding corrective actions with regard to any part of the process flow associated with the product.

8.  Cooler temperature verification, even though we have continuous electronic monitoring.

 

There is possibly something I am forgetting but that is a start.  Although all of those are checked our pre-shipment review form is on a form identifying all the raw materials going into the product and a single line written as "Records review: Acceptable (yes or no), time and a signature of the monitor.

[EHam]

seafood,

 

Are these the only items that you produce at your facility? Seems easily doable if so. This is not so easy for our establishment. We produce over 500 items overall and as many as 20 items produced per day.

 

[Setanta]

We have a single CCP and we use simliar language to  "Records review: Acceptable (yes or no), time and a signature of the monitor." on our HACCP form that is verified the next day.

 

We have many, if not all of the same Prerequisite Programs, and they are also verified the next day.  This has been acceptable to our USDA inspector.  We produce frozen foods.

 

Setanta
 

Edited by Setanta, 05 December 2013 - 07:28 PM.

[Charles.C]

Dear Eham,

 

We produce over 500 items overall and as many as 20 items produced per day

 

Well, the number of entries in yr (Excel?)  "list" is probably going to be related to the number of HACCP plans you are using ?

 

Rgds / Charles.C

[seafood]

We produce around 30 different products non-inclusive of what we sell fresh.  Only the 4 different bacon wrapped products we produce are USDA inspected.  If everyone is doing what they are supposed to and you or whomever is designated to review the facility's records is doing so daily it should not be an issue.  I think what might be the easiest option is to have a daily processing batch/lot log and have a records review sign off as previously outlined at the bottom of the page.  Again, documentation should not be the issue, it is when the direct observation takes place the records review is performed correctly.  Our inspector is always willing to help us out and if he can't he will ask his superior or FSIS directly for input. 

[Charles.C]

Dear Eham,

 

No direct experience with USDA in-house monitoring procedures / requirements but yr description of the pre-shipment expectations in yr OP sounds very similar to what everyone else calls a positive release step/ form ( effectively a review for the specific product that all HACCP monitoring requirements have been done correctly and recorded results are satisfactory / any related  corrective actions have been closed out).

Perhaps the verification of such a step is included within the USDA Inspector's brief (which I presume you are handsomely paying for).

As per previous line, I would hv expected a "free" consultative service for this kind of requirement (as indicated in previous post.)

 

Rgds / Charles.C