To assist its members in understanding how to effectively conduct critical review of FSIS Non-Compliance Records (NRs) and formulate appeals which have a likelihood of success, NMA is hosting this webinar covering "Critical Evaluation and Appeal of NRs."
FSIS is in the process of implementing the Public Health Information System (PHIS), with the initial phase scheduled to be completed in early 2012. Within this new framework, FSIS will use an automated system to monitor datastreams to identify those establishments that may pose an increased risk to public health. One of their primary sources will be day-to-day inspection verification procedures conducted in-plant.
In addition to obvious triggers for increased inspection (such as pathogen positives), noncompliance with specific laws and regulations and/or performance that is worse than peer establishments with respect to FSIS inspection findings will also be used to determine where increased inspection activities are scheduled.
Because of this, it is even more important than in the past that each Federal Establishment conducts critical review of all correspondence from FSIS personnel, most notably NRs, and appeal whenever the noncompliance is not warranted. Even when only part of the NR is incorrect, but especially when inappropriate regulatory citations are used, appeals are going to be of major and increasing importance.
The webinar will be facilitated by NMA Director of Regulatory Issues Norm Robertson. Prior to joining NMA over three years ago, Robertson worked for FSIS in Field Operations for 18 years and has extensive expertise in proper documentation of noncompliance and the appeal process from both sides of the regulatory fence.
NMA is offering this seminar for $99 per login to NMA members; $149 for non-members; and $25 for students, with a valid student ID. All participants will receive a PDF copy of the presentation and may attend online or by phone. For more information, visit www.nmaonline.org or call (510) 763-1533.