USDA & No Gloves

I work for a beef jerky company in the USA and our oversight is USDA. We are also BRC certified.

Every morning we are required to have our inspector do a pre-operations check before we start our normal daily operations. We have recently noticed that our inspector is not using gloves even though he is in RTE areas and touching food contact surfaces. 

This is the response from our inspector:

"He stated that because the pre-op inspection in organoleptic, it is necessary to use bare hands. The biofilm or residue left behind by proteins, marinade and other fluids cannot be felt through the gloves. It is believed that proper handwashing SSOPs prior to inspection should eliminate any risks. He stated that this is also how pre-op is done at all of the other plants he and the other inspectors visit."

I'm looking to get others thoughts. Is this what USDA inspectors do at your facility? If so, do you then have to sanitize the food contract surfaces again? 

Thank you.

In my previous facility inspectors wore gloves when handling surfaces, and used high-power flashlights at an angle to the surfaces to look for residues as well as wiping them with sanitized, gloved, hands. Residues were obvious on stainless steel and other surfaces using this method.

There may be other resources the inspector calls upon, but the FSIS directive concerning the pre-op inspeciton task states:

IPP are to assess the cleanliness of areas or equipment that, if insanitary, would present the greatest risk of transferring pathogens or other contaminants to product (e.g., direct food contact surfaces that are difficult to clean or that may serve as harborage sites). When assessing pre-op sanitation conditions, IPP are to use professional judgment in determining whether the establishment‟s pre-op measures have resulted in a clean and sanitary environment.

 

No instructions not to use gloves, but it does say that they're to use their best judgement in how they determine the equipment is good to go.

HOWEVER, if you have a consistent, written policy that product contact equipment is touched only with gloved hands, your IPP has to comply with your rules per Directive 5060.1 which is current as of September, 2016.

This directive instructs inspection program personnel (IPP) to comply fully with the sanitary and hygiene procedures and biosecurity measures put in place by an official meat or poultry establishment, an egg products plant, or an official import inspection establishment that these facilities also require of all of their employees. FSIS previously issued these instructions in FSIS Notice 17-15, FSIS Program Personnel Hygiene and Biosecurity Practices.

 

*Politely* share that directive with him and make him wear gloves as long as you require it of your other employees, after all, it's your product and reputation, not his. If he still disagrees that you're preventing him from doing his job, it's up to you if it's worth reaching out to your regional office for a final ruling.

Given his statement in your post, I imagine this conversation in general won't buy you any goodwill.

PSC - This has little to do with your post, but I'm looking for some input from individuals familiar with USDA, specifically with jerky.  I posted an item in the USDA section and if you could have a look and let me know your thoughts I would appreciate it.  I would have messaged you directly, but I can't seem to figure out how.

http://www.ifsqn.com...jerky/?p=110430

Thanks.

PSC - This has little to do with your post, but I'm looking for some input from individuals familiar with USDA, specifically with jerky.  I posted an item in the USDA section and if you could have a look and let me know your thoughts I would appreciate it.  I would have messaged you directly, but I can't seem to figure out how.

 

http://www.ifsqn.com...jerky/?p=110430

 

Thanks.

With due respect, this seems like sort of a roundabout  BUMP.

Access to the pm system requires >10 Posts.

Hi PSC,

I deduce the inspector did not require a repeated cleaning/sanitization of the "self-contaminated" locations.

i suggest that a polite approach to the Inspector's quoted response might be to simply request a validation of their hygienic opinion. (For example, are USDA Inspectors internally validated as not being carriers ?)

Offhand, the response sounds like Professional back-covering (= Judgement).

But, as already noted, and particularly if the original response turns out to unvalidatable/incorrect, subsequent official cooperation may become "problematic". It depends on your assessed importance in the future Grand Scheme of Things.

With due respect, this seems like sort of a roundabout  BUMP.

 

Access to the pm system requires >10 Posts.

  My apologies.

  My apologies.

Hi swmalone,

No problem.

It is undeniable that the USDA, meat, RTE,  L.mono requirements are impressively thorough but also of maze-like intricacy. :smile:

Then again, historical USA statistics/events provide substantial justification.

We actually had a similar situation with a relief inspector.  We ended up writing up a dress code GMP for our production areas for pre-op inspections.  If it is in the GMP's then the Inspectors are expected to follow them too.

Hmm...must be a super inspector if he/she can "feel" biofilm. I also assume the inspector, as part of his/her organoleptic check is licking food contact surfaces to see if he/she determines any off taste?

As mentioned previously, politely inform the USDA person that if they want to touch food contact surfaces, they need to wash and sanitize hands (preferably with a swab test to ensure efficacy), prior to possibly contaminating your facility.

Marshall