“Due to the complexity of the issue and its potential impact on the meat industry, we felt as though more time should be granted,” said Dr. Jay Wenther, A.A.M.P. executive director.
A.A.M.P. has been working with other national meat trade organizations and has also been diligently working to keep many entities up to date with more information regarding the validation issue, he added. The organization has been in continued communication with the its board of directors and membership, 32 affiliate organizations, state meat-inspection directors of the 27 state meat inspection programs, the Niche Meat Processor Assistance Network (N.M.P.A.N.) and numerous university extension professors throughout the U.S., Mr. Wenther said.
“A.A.M.P. has developed a webpage specifically for the validation issue,” he continued. “Individuals can go directly to the A.A.M.P. web site (www.aamp.com). From the homepage, they can click on the first hot topic (Validation of H.A.C.C.P. System Information) and that will take them to all the information A.A.M.P. has collected thus far. The specific address iswww.aamp.com/Validation.php.”
The web site contains:
? An overview of validation (AAMPlifier – October 1, 2008)
? A summary of where the issue stands currently (Capitol Line-Up – April 1, 2010)
? Template letter – generic (where companies can simply include their name and submit it on their letterhead)
? Template letter – detailed (where companies can include specific information as to their H.A.C.C.P. food-safety systems, number of H.A.C.C.P. plans, number of products produced, potential costs, etc.)
? Talking points
? Validation cost calculator for initial validation and ongoing verification microbial testing – an interactive Microsoft EXCEL spreadsheet
? Draft validation guidance documents
? A.A.M.P.’s request for extension of the comment period
? A link to other validation guidance material provided by F.S.I.S.
The validation cost calculator is an interactive Microsoft Excel spreadsheet and is one of the most useful tools to demonstrate the potential costs associated with initial validation and ongoing verification testing, Mr. Wenther said. A.A.M.P. has developed this spreadsheet in conjunction with A.A.M.P. former President Jason Jennings, who is a small independent processor.
The first sheet provides and overview and key assumptions that were made. The second sheet is a user-friendly spreadsheet that allows establishments to choose which H.A.C.C.P. plans they are using within their facility and they can also input the amount of products within each H.A.C.C.P. plan that may have to be validated.
“Microbial testing costs were provided by one third-party microbiological laboratory so they are legitimate, but the establishment can change those figures if they have the costs from the laboratory they utilize,” he added. “The establishment can modify the shipping costs as well. Of course some assumptions needed to be made in the development of the spreadsheet.”
These assumptions included the initial sampling amount, the ongoing sampling amount, and when sampling would occur, Mr. Wenther said.
“In the opinion of A.A.M.P., the draft guidance document clearly outlines that extensive microbial sampling will be required to validate each establishment’s products,” he said. “Depending on how the draft compliance guide on H.A.C.C.P. systems validation is interpreted by the establishment owner and inspection personnel of the Food Safety and Inspection Service (F.S.I.S.), this validation initiative could potentially be devastating for the affected group of inspected (state and federal) independent very small and small processors.”
Information on the A.A.M.P. web site is open to the general public. “The A.A.M.P. board of directors felt as though this issue is so very important that it must get into the hands of all processors as quickly and efficiently as possible,” Mr. Wenther said.
“Thus far, A.A.M.P. has requested an extension to the comment period, but has not gotten any written grant of extension,” he said. “Therefore, it is strongly advised that comments be submitted by April 19."
Anyone wanting to comment should submit comments to the e-mail address DraftValidationGuideComments@fsis.usda.gov or to the Docket Clerk, U.S.D.A., F.S.I.S., Room 2-2127, 5601 Sunnyside Avenue, Beltsville, Md. 20705.
After April 19th, F.S.I.S. will begin its review on the comments it receives and its process of deciding how it will proceed with respect to the validation of H.A.C.C.P. systems.