SWINE HIMP AUDIT
In October 1999, FSIS initiated the HACCP Inspection Models Project (HIMP) project in volunteer slaughter establishments to determine if new government slaughter inspection procedures, along with new plant responsibilities, could improve food safety and increase consumer protection. Under HIMP employees of slaughter establishments sort carcasses on the slaughter line before they reach FSIS on-line inspectors; the goal of the establishment is to remove those issues that are not related to food safety, known as “other consumer protection” and identifying and removing true food safety issues. The role of the USDA FSIS inspectors in the facility are to verify that the establishment is removing both OCP and food safety issues from the system prior to the affected products entering commerce. So the big question is, how does your HIMP System compare to traditional inspection?
What we do
We will perform a full performance audit against traditional swine inspection with the intent of helping you improve your food safety and production performance.
We will review all aspects of your operations and provide you a comprehensive report and recommendations. The report can be made available to your clients assuring them that you are exceeding product quality and safety compared to traditional inspection.
Our proprietary Audit Methodology will give you the ability to know exactly how you compare to traditional inspection; and it was developed by former USDA FSIS officials who know what the traditional standards are as well as the HIMP standard.
In developing the baseline that is used to audit against we used multiple sets of criteria that are discussed below however one set of data, sorter failure rates used in the Post-Mortem determination had to be extrapolated from other data as the USDA does not collect data on how often its inspection personnel “miss” or fail to identify food safety or OCP items. For example condemnation rates noted in the USDA FSIS Evaluation of HACCP Inspection Models Project (HIMP) for Market Hogs*6 does not address the rate at which USDA FSIS inspection personnel make errors, this is one of the strengths of HIMP that is very hard to quantify. Those that attack the Swine HIMP system often fail to identify this overarching fact. By having an extra inspector reviewing personnel that are performing the traditional inspection functions any errors made by personnel performing said functions still have an opportunity to be prevented from entering commerce, no such safety net exists in traditional inspection. Further when the USDA FSIS developed food safety and OCP standards they used standards that are more stringent than those standards used by traditional inspection.
The baseline used to determine equivalency with traditional inspection for the establishments training program included USDA FSIS training documents as well as those from the HACCP Alliance: Slaughter Food Safety Standard date 2-18-2015*1, Livestock antemortem Inspection dated 3-21-2013*2, Livestock Plant Familiarization dated 4-2014*3, and Livestock Postmortem Inspection dated 01-19-2012*4, etc.
The baseline to determine equivalency with traditional inspection for the establishments Ante- Mortem and post-mortem programs was made by reviewing USDA FSIS employee standards in both traditional and HIMP facilities as well as reviewing the requirements found in 9 CFR, etc.
The baseline to determine equivalency with traditional inspection for the establishments Food Safety, Record Keeping, Humane Handling, and Fabrication programs is the proprietary Food Safety Audit & Assessment Pro! ™ system*7. Additional information reviewed included the World Health organization HACCP-Based Inspection Models Project*8, HACCP-Based Inspection Models Project: Diseases and Conditions Observable in Meat and Poultry*10, FSIS-Inspection and Enforcement Activities at Swine Slaughter Plants audit report 24601-0001-41*9, 9 CFR, etc.
We then use our proprietary Food Safety Audit & Assessment Pro! ™ system. This includes reviewing the design of the food safety system, (to include the support for decisions, programs, etc.), implementation at all levels, the facility (Onsite only) to include structural components, equipment, personnel, supporting programs, implementation, etc.
If critical issues arise or are noted they are immediately communicated to establishment management and recommendations for corrections will be given at that time as well as being documented in the summary section; we do not recommend sharing the Assessment worksheets as they will have trade secret as well as proprietary information documented in them. The summary section includes all deficiencies that were noted and that will have an impact of food safety or regulatory compliance.
Monthly Vulnerability Reports
Clients utilizing the Food Safe Pro!® L3 electronic record keeping system are assigned a consultant who reviews their programs and records. On a monthly basis the consultant reviews records input by establishment personnel and analyzes data for trends, for example higher temperatures noted on products, deviations from critical limits, etc. and they then submit a vulnerability report to the establishment for review. Utilizing a data management system allows the consultant to quickly and efficiently review the data collected, often times identifying negative trends before they become a concern allowing the client to make the necessary changes to their systems to preclude problems, and ultimately allowing them to maintain focus on food safety.
Monthly vulnerability reports are reviewed as part of both the Desktop and Onsite Audits however they are not to be confused with an audit. The vulnerability report is just that, it is a report on potential vulnerabilities as identified during data reviews. They are typically limited to a 1 month time period as such they don’t give the total picture of the establishment.
The Audit consists of two parts, onsite and desktop
Desktop audits consists of reviewing your food safety programs, records that you are generating, and supporting documentation in the Food Safe Pro!® L3 system. For those that don’t utilize electronic record keeping we can perform this function at your facility or alternately make copies during the onsite portion and review them when we return to our offices. We develop a comprehensive report based on our findings focusing on food safety and regulatory vulnerabilities.
The onsite portion of the audit is conducted as the name implies, onsite. The auditor review all of your processes, records keeping, programs (HACCP, GMP, Pre-Reqs, etc.), implementation, regulatory compliance, food safety system implementation, etc. WRFS auditors complete the audit before leaving the establishment, providing the client with general findings. If critical issues arise they will be immediately communicated to establishment management and recommendations for corrections will be given to the Client. The Establishment size, number of Hazard Analysis and Critical Control Point (HACCP) processes employed, pre-requisite programs, physical layout, and complexity of the assessment will affect the time necessary to complete an Audit. Nonetheless, WRFS auditors should be able to complete the audit in 3 to 5 days or less. In the event that an extended amount of time will be needed to complete the audit, the auditor will explain the reasoning with the client and a decision will be made by the Client if they would like to proceed.
The purpose of the audit is to give a complete picture of the operation identifying regulatory, food safety, business practices, and program as well as facility and personnel weaknesses so that the operator can focus resources to improve the operation in the most efficient and cost effective manner.
Our goal is to give you an audit report that you can use to meet regulatory compliance, provide to your clients and others as verification that you exceed traditional inspection as well as assist you in planning for the future. The recommendations contained in the audit are strictly that; we encourage each client to review the audit in detail and make those changes that they deem necessary to produce a safe and wholesome product and meet their regulatory and customer requirements.
In order to be found compliant your facility may not have any derogatory findings that the auditor determines may cause a food safety, regulatory, or customer requirement failure. In essence upon completion of the audit you will either pass or fail. The reason for this approach is simple, your end customers either have food poisoning or they don’t, your regulator finds you compliant or they find you are not, and your direct customers either purchase from you or they don’t. The real world doesn’t give you a feel good score and neither do we.
The audits are performed by our staff and are not “farmed out” to other consulting or audit groups unless specifically requested by the client. The auditor will have extensive background and knowledge of the audit process, food safety, federal regulations, and best practices. The auditor has an extensive network of colleagues within our consulting group whom they can call on for assistance should they come across something unique to their experience. Our audit team includes Food Technologists, Veterinarians, former government regulators, etc. We are uniquely positioned to provide our clients with world class service; no other organization has the mix of talents and experience that we offer. The audit findings are the property of the client and are not disclosed outside of our company or our clients company, and then only to those employees whom the client has authorized. We insist on utilizing a non-disclosure agreement prior to any work being accomplished, we are insured, and we require all clients to maintain the confidentiality of the Food Safety Audit & Assessment System Pro!™ process.