N.A.M.P. is also concerned that F.S.I.S. field personnel will see the guidance document as regulations and they will force plants to conduct additional microbial testing. The document should be changed to focus on specific F.S.I.S. concerns, rather than blanket the entire industry with suggestions to conduct additional, widespread in-plant validation activities, according to N.A.M.P.
“I would like to say we understand and support the need for meat and poultry establishments to have validated food-safety systems,” Kimball said. “However, the draft guidance document should be changed to address any specific needs or issues that F.S.I.S. sees, rather than blanketing the entire industry with recommendations to conduct additional validation activities, which consist mainly of additional in-plant microbiological testing.
“The agency should consider and share what food-safety gains will be realized, particularly in light of the impact on the small and very small meat processing industry,” he concluded.