Provisioner logo
Provisioner logo
search
cart
facebook twitter linkedin youtube
  • Sign In
  • Create Account
  • Sign Out
  • My Account
Provisioner logo
Provisioner logo
  • NEWS
    • Industry News
    • Supplier News
    • Case Studies
    • Recalls
    • Regulations
    • New Consumer Products
  • EXCLUSIVES
    • Newsletters
    • Source Book
    • Sponsored Insights
    • Events
    • Webinars
    • Classifieds
    • White Papers
    • Provisioner Store
    • Market Research
  • MEAT PROCESSING
    • SUSTAINABILITY
    • Processing
    • Packaging
    • Ingredients
    • Formulation
    • Food Safety
    • Special Reports
    • Commentary
  • PROFILES
    • Processor Profiles
    • Processor of the Year
    • Top 100 Processors
  • MEDIA
    • Videos
    • Podcasts
  • DIRECTORY
  • MIHOF
  • INDEPENDENT PROCESSOR
  • EMAG
    • eMagazine
    • ARCHIVE ISSUES
    • Contact
    • Advertise
  • JOIN!
Fight for Food Safety

The validation vex

By Shawn K. Stevens
September 6, 2012
The Food Safety and Inspection Service (FSIS) has been working for months now on a new approach to validate the effectiveness of existing Hazard Analysis Critical Control Point (HACCP) systems.

To clarify its validation expectations, FSIS is issuing additional directives for inspectors and guidance materials for industry. Collectively, these materials will better define existing requirements relating to whether an establishment has appropriately validated its HACCP plan.

Validation under 9 CFR 417.4(a)(1) requires that an establishment rely upon scientific or technical support for its HACCP plan, and direct operational evidence, which demonstrates that the establishment satisfying the critical operational parameters necessary to achieve the goals of the plan. The underlying scientific or technical support can include: (1) published processing guidelines; (2) scientific articles from a peer-reviewed journal; (3) challenge or inoculated pack studies designed to determine the lethality or stabilization of a process; (4) data gathered in-house; and/or (5) regulatory performance standards. In turn, an establishment must also produce operational data which demonstrates it is meeting each of the critical operating parameters on an on-going basis.

From a regulatory standpoint, it has been less than clear how establishments were expected by FSIS to demonstrate that their HACCP plans had been appropriately validated. Although FSIS defines validation as the process of demonstrating that a HACCP system, if operating as designed, can adequately control identified hazards and consistently produce a safe product, even this simple definition is less than clear. When federal regulations, rules and policy statements are indefinitely worded (such as is the case here), confusion often results. This, of course, has proven true with FSIS’ less-than-uniform efforts, at least in the past, to effectively enforce existing validation and verification standards.

In any event, to enhance the effectiveness of HACCP generally, and to avoid inconsistent enforcement (for which the agency should be applauded), FSIS is now working to better instruct and train FSIS field personnel to interpret and enforce the agency’s emerging validation and verification standards in an accurate and consistent manner. So, while the agency struggles to eliminate confusion, and begins to focus more attention on the technical aspects of HACCP, rest assured that you will survive if you can show that your system is — at its most basic level — controlling hazards and producing a safe product.

KEYWORDS: FSIS haccp

Share This Story

Looking for a reprint of this article?
From high-res PDFs to custom plaques, order your copy today!

Shawn stevens 200x200

Shawn Stevens is the founding member of Food Industry Counsel LLC, a law firm formed in 2014 to represent the food industry exclusively in regulatory and other matters involving food safety and quality. Contact Stevens at (920) 698-2561 or stevens@foodindustrycounsel.com, or visit his Web site, www.foodindustrycounsel.com.

Recommended Content

JOIN TODAY
to unlock your recommendations.

Already have an account? Sign In

  • Double Charburger

    Premiumization drives burger category

    Shoppers seek out premium meat offerings to fulfill...
    Special Reports
    By: Sammy Bredar
  • JJS Adult Pekin duck

    Poultry Report 2025: Convenience propels poultry at retail

    Despite continued economic pressures, the poultry...
    Meat and Poultry Industry News
    By: Sammy Bredar
You must login or register in order to post a comment.

Report Abusive Comment

Manage My Account
  • eMagazine Subscriptions
  • Manage My Preferences
  • Newsletters
  • Online Registration
  • Subscription Customer Service
  • Connect with The National Provisioner

More Videos

Sponsored Content

Sponsored Content is a special paid section where industry companies provide high quality, objective, non-commercial content around topics of interest to the The National Provisioner audience. All Sponsored Content is supplied by the advertising company and any opinions expressed in this article are those of the author and not necessarily reflect the views of The National Provisioner or its parent company, BNP Media. Interested in participating in our Sponsored Content section? Contact your local rep!

close
  • A smiling man carrying a grocery basket is reaching down to pick up a package of meat in a grocery store.
    Sponsored byPIC

    The Green Light: New Data Shows 12-to-1 Support for Pork from PRRS-Resistant Pigs

  • Close up of a grocery cart full of groceries, a cropped image of a couple pushing the cart and a blurred background of the vegetable aisle.
    Sponsored byPIC

    New Market Research Finds Consumers in Eight Key Pork Markets Are Likely to Purchase Pork from Gene-Edited Pigs

  • Close up of a young pig with a blurred background.
    Sponsored byPIC

    New Research Forecasts Significant Economic and Market Impacts with PRRS-Resistant Pig Adoption

Popular Stories

Spam Dog

Hormel rolls out Spam hot dog for foodservice applications

Various new Primal snack sticks on a table amongst pencils, apples, a pair of glasses, lunch bags and a water bottle.

Protein demand drives snacking occasions

Several cuts of beef, pork and chicken on a wooden board, cast iron pan and salt.

Validated thermal lethality data and a new tool for ensuring safety of RTE meats

2026 Top 100 Meat & Poultry Processors Report

Events

June 11, 2026

From Fresh to Frozen in 3 Minutes Flat: Unlocking the Secrets to Temperature Control

Join Tony Vacaro, Foods Industry Manager, and Emile Klein, Foods Market Strategy Manager at Air Products and Chemicals, Inc. , as they tackle key questions surrounding heat removal in food processing. 

January 1, 2030

Webinar Sponsorship Information

For webinar sponsorship information, visit www.bnpevents.com/webinars or email webinars@bnpmedia.com.

View All Submit An Event

Products

Food Crime: An Introduction to Deviance in the Food Industry

Food Crime: An Introduction to Deviance in the Food Industry

See More Products
From Fresh to Frozen in 3 Minutes Flat: Unlocking the Secrets to Temperature Control Webinar Sponsored by Air Products

Related Articles

  • AMSA to Co-Host the Validation and Verification Procedures and Guidelines Workshop

    See More
  • Register for the AMSA Validation and Verification Procedures and Guidelines Workshop

    See More
  • HACCP validation - The time to speak up is now

    See More

Events

View AllSubmit An Event
  • November 7, 2013

    Food Plant of the Future: The Future of Wastewater Management

    Available On-Demand Effective management of wastewater is becoming increasingly critical to food and beverage processors as the cost for incoming water increases...
View AllSubmit An Event
×

Stay ahead of the curve. Unlock a dose of cutting-edge insights.

Receive our premium content directly to your inbox.

SIGN-UP TODAY
  • RESOURCES
    • Advertise
    • Contact Us
    • Directories
    • Store
    • Want More
  • SIGN UP TODAY
    • Create Account
    • eMagazine
    • Newsletter
    • Customer Service
    • Manage Preferences
  • SERVICES
    • Marketing Services
    • Reprints
    • Market Research
    • List Rental
    • Survey/Respondent Access
  • STAY CONNECTED
    • LinkedIn
    • Facebook
    • YouTube
    • X (Twitter)
  • PRIVACY
    • PRIVACY POLICY
    • TERMS & CONDITIONS
    • DO NOT SELL MY PERSONAL INFORMATION
    • PRIVACY REQUEST
    • ACCESSIBILITY

Copyright ©2026. All Rights Reserved BNP Media, Inc. and BNP Media II, LLC.

Design, CMS, Hosting & Web Development :: ePublishing