Unfortunately, that’s where the industry stands at the moment. FSIS has issued a Draft Guidance on HACCP Systems Validation. This proposal would require companies to conduct in-plant testing to verify that their HACCP systems do what they say they do, instead of allowing a company to refer to established scientific resources.
If a company has a beef slaughter operation, FSIS estimates it will require 78 microbial tests to validate the plan. If it slaughters other animals, that’s an additional battery of tests. If it produces a variety of products, there could be a series of tests for each product. Along with the initial costs, there will be the costs for on-going verification.