Regulations / Legislative
Regulations & Legislation

Assessing 'reassessment' of HACCP plans

HACCP reassessmentPeriodically, the Food Safety and Inspection Service (FSIS) will announce its expectation that establishments reassess their HACCP plans in addition to the annual reassessment expected by the regulations. The reason for the announcement could be a change in agency policy, such as declaring six non-O157 STECs as adulterants, or in response to lessons learned from an outbreak recall or other regulatory action.

Following the announcement, the agency will verify that the establishments have indeed conducted a reassessment. Notwithstanding the agency expectation, there are establishments which fail to reassess their HACCP plans. Yet, in many of these cases, the establishment actually did reassess its plan but simply had failed to understand that they had done so, or, failed to document the reassessment. Conversely, there are establishments which modify the plan, even though such modification is not necessary.

Reassessment is the thought process by which an establishment reviews its total food-safety system to determine if the new hazard identified by FSIS is adequately addressed. A reassessment need not result in any changes to the plan. The problem is that many establishments perceive that "reassessment" equates to mandatory change, so they will implement a change, needed or not. Other establishments may not make a change - either because the system currently addresses the hazard raised by the agency or the hazard does not occur in the operation. However, they erroneously assert that they do not have to reassess because the requirement "does not apply to them." What these establishments really should say is that they have reassessed and determined no change is needed.

To avoid unneeded changes or regulatory entanglements, an establishment should set out, in writing, its thought process in these situations. In determining whether the hazard is adequately addressed, establishments should review the food-safety system with special attention to:

  • Supplier Programs - many times a hazard can only be controlled at the supplier's location. Does the establishment have a supplier program in place and do the requirements control the newly identified hazard? If not, reach out to the supplier.
  • Control Programs - if the establishment already addresses the same basic hazard, such as enteric pathogens, are the programs equally effective for the new specific hazard? Please note, this may require validation sampling of finished product for the new hazard to ensure the control programs are indeed being effectively implemented.
  • Intended Use - FSIS may have identified a hazard in raw products; does the establishment only sell for processing into ready-to-eat products or is the class of customers, e.g., chain restaurants, adequate to mitigate against the hazard?

To complete this activity, the establishment needs to meet the other regulatory reassessment requirements in 9 CFR _ 417.4. First, the reassessment be conducted by a trained individual. Second, the reassessment be documented (a new requirement from last year).

When FSIS expects a reassessment, establishments need to comply. By making their thought processes more transparent, establishments can meet this requirement without unnecessary additions and without regulatory non-compliance.

Recent Articles by Dennis Johnson

You must login or register in order to post a comment.



Image Galleries


Brenneman analyzes Butterball’s new animal care, well-being program

Rod Brenneman, CEO of Butterball, discusses his company's new Animal Care and Well-Being Program, his company's certification by the American Humane Association and further animal-handling initiatives, all officially announced in September 2013.

More Podcasts

National Provisioner


February 2015

The February 2015 issue of NP features cover story: Power Surge, a look at J Bar B Foods.

Table Of Contents Subscribe

Independent Processor


February 2015

The February issue of IP features cover story: The great speckled bird. 

Table Of Contents Subscribe

Provisioner Store

The National Provisioner Source Book

The Sourcebook is an exclusive buyer’s guide and reference tool for product and supplier information in the meat, poultry and seafood marketplace.

More Products


A complete reference guide to supplies. Go to NP's Sourcebook now to check out the latest and greatest in the meat and poultry processing business.


Facebook icon Twitter icon  YouTube iconLinkedIn icon google +


Provisioner Prime is a twice weekly electronic newsletter created by the editors of The National Provisioner. Provisioner Prime appears in your inbox every Tuesday and Thursday with a recap of the week's top news and trends. Provisioner Prime also offers you exclusive access to industry analysis, blogs, events, podcasts, videos, webinars and The National Provisioner feature articles. 

Sign up for Provisioner Prime HERE.