Sanitation guidance vary by regulatory agency for small and very small meat and poultry establishments


November 20, 2019 - Jeannine Schweihofer, , Sheena Fate and Tina Conklin,

Regulatory guidance are recommendations that facilities can use to justify certain actions. Regulatory requirements need to be followed to comply. Michigan State University Extension compiled sanitation guidance for ready-to-eat food establishments based on the Food and Drug Administration (FDA) the U.S. Department of Agriculture (USDA), Food Safety and Inspection Service (FSIS), and the Michigan Department of Agriculture and Rural Development (MDARD) to evaluate establishment practices. Guidance provided contained expansive sanitary recommendations. Some regulating bodies employed a more stringent approach by way of food law rather than guidance. The FDA and FSIS use regulatory enforcement requiring facilities to employ control measures and environmental testing by way of 9 Code of Federal Regulations (CFR) part 430, the Listeria Rule and the Food Safety Modernization Act in effort to prevent product adulteration.  Processors in Michigan who are not inspected by USDA FSIS or FDA are subjected to state regulations in the Michigan Modified Food Code and enforced by MDARD. Currently, MDARD does not require scheduled pathogen testing as a method to assess sanitary practices, however, facilities are encouraged to conduct their own environmental tests.  

Regulatory guidance can present challenges to small and very small RTE processors with structural and financial limitations. These limitations result in varying degrees of implementation as a result of limited specialized resources.  Additionally, many small and very small processors are not federally regulated resulting in reduced verification such as testing. MSU Extension used the compiled checklist  to assess current sanitation practices within the industry and make recommendations for improvements.



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