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Pre-shipment Review 9 CFR 417.5

HACCP Pre-shipment Review 9 CFR 417

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#1 SausageGuy

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Posted 24 July 2019 - 03:00 PM

Hello, all.

 

My company is in an odd situation that I'd rather not get into the long details about. Long story short, we are a fairly new (<5 years old) raw sausage manufacturer that shares a facility with another meat processing company (this other company manufactures many other products that we do not process, ie cut steaks, ground beef, chicken, etc). When we originally started our company a few years ago (prior to me taking over the QA department), our USDA inspector wanted both companies to operate under the HACCP Plan already in place for the other company. Fast forward a few years. Our process, including hazards and CCPs, differs from the company we share space with. I wrote our own HACCP Plan according to our process and flow chart. This was my first HACCP I have ever written, and excluding the HACCP Certification class I took a couple years ago, I had zero help/support with this task. Don't even get me started on the nightmare it has been with SQF and our shared space/HACCP. Apparently I wrote our Food Safety and Quality Manual for the SQF code well enough for us to get certified regardless of the glaring HACCP issues.

 

Now that the "short version" of our history has been told, I need your help! We received an NR from our new USDA Inspector for not having a Pre-shipment Review. Her and I had a nice talk today where I explained our whole situation and she was very understanding regarding the very basic HACCP plan I put together and how it is currently a work in progress.

 

Does anyone have a basic example of a Pre-shipment Review they are willing to share? I need to do my Corrective Action for this but I really have no idea what I should have on here. I plan on having the Pre-shipment Review done daily at the end of the production shift and prior to the finished product being shipped to an offsite freezer facility.

 

Please Help!!!

 

Thanks in advance.

 

Ricky



#2 The Food Scientist

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Posted 24 July 2019 - 03:20 PM

If I am not mistaken, I believe since you are SQF (or going there), this falls under "Product Release". Where you are releasing product from production out the door and by that you are confirming its identity, integrity and compliance to release to the public. Prepare a product release form, you can search here on this forum for forms. 


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#3 SQFconsultant

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Posted 24 July 2019 - 03:48 PM

Ricky,

If you are SQF already you would have a pre-release procedure in place... do you?


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#4 SausageGuy

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Posted 24 July 2019 - 05:20 PM

We do have a product release policy and procedure developed and in use, however our inspector wanted something different than that. That's where I am running into issues because I'm not sure what sort of form I am supposed to have if it's different than my product release.



#5 The Food Scientist

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Posted 24 July 2019 - 05:49 PM

I found this: 

 

Q3. What is the difference between the pre-shipment review required by 9 CFR 417.5© and the review of HACCP records required by 9 CFR 417.4(a)(2)(iii)?

 

A3. Pre-shipment review, as described in 9 CFR 417.5 ©, involves a review of records associated with a specific production of product or establishment designated lots before it is shipped into commerce. The review includes a check to ensure that all critical limits at all CCPs have been met, and that any required corrective actions have been taken. Conversely, an establishment’s review of its HACCP records required by 9 CFR 417.4(a)(2)(iii) is an on-going review of records not specifically tied to a production lot. The review under 9 CFR 417.4(a)(2)(iii) provides a snapshot of the broader operation. This ongoing record verification is used by the establishment to ensure that the HACCP records are being completed as designed in their HACCP plan [9CFR417.2©(6)] and to ensure that the records demonstrate compliance with 9 CFR 417.5(a)(3) requirements.

Finally, it is used to ensure that the plant’s HACCP system is operating appropriately and is under control.

 

 

https://askfsis.cust...review-records?


Edited by The Food Scientist, 24 July 2019 - 05:50 PM.

Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#6 Peaches

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Posted 24 July 2019 - 05:52 PM

Ah yes USDA and GFSI don't always play well together or speak the same language! I've attached an example of what we have in place - we do our pre-shipment review 3x per day on our CCP paperwork (I have removed a lot of information from the form as it is proprietary information to our company).  The person performing the preshipment review simply reviews the CCP information, then circles P2, P3, records their signature, date, and time and it is complete!  Hope this helps! 

Attached Files



#7 QUALITY22

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Posted 24 July 2019 - 06:11 PM

PEACHES IS 100% CORRECT. USDA/FDA/GFSI does not matter. USDA WANTS THERE OWN DOCS AND HACC PLANS. I love the USDA :) You can always used AskFSIS also. 

 

This form can be as simple as:

 

Lot #                                 Date:                    HACCP Category:                              All CCPs Met? Y/N                   ALL SSOPs Met? Y/N                      Who Reviewed:

2424xx                           7/24/19                     Heat Treated Shelf Stable                  Y                                                        Y                                                 Jimmmy

 

 

They want a simple cover sheet for your daily records to provides a overview and sign that your ccps and ssop requirements under FSIS have been met. Most inspectors will only review this day-today depending on the amount of  companies in their territory. 

 

Make sure to keep 90 production batches as ur USDA validation also. Preshipment review, ccps, sanitaiton dodcs, and batch records. Life of HACCP PROGRAM



#8 SausageGuy

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Posted 25 July 2019 - 01:15 PM

Okay, I am attaching what I came up with. Please review and give feedback.

 

Thanks for all input!

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#9 Peaches

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Posted 25 July 2019 - 02:21 PM

I think your form looks good! Minor detail - I would add in 'record' before review and then there is no confusion that all records are being reviewed as well.  USDA likes their record review when it comes to CCP/Preship reviews.  



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#10 SausageGuy

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Posted 25 July 2019 - 02:59 PM

I think your form looks good! Minor detail - I would add in 'record' before review and then there is no confusion that all records are being reviewed as well.  USDA likes their record review when it comes to CCP/Preship reviews.  

 

Thanks, Peaches! I did make that change.







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