“NAMP supports the concept of test and hold, and was part of an industry-wide effort to develop guidelines for holding tested product until test results are received,” NAMP said. “We believe these guidelines serve as a useful tool for the industry and that the practice of test and hold is widely adopted, as evidenced by information presented in the FSIS Notice.
“However, we do note that there has not been 100 percent adoption of these guidelines, and that recalls have resulted from plants that have not held tested product,” NAMP added. “It is in the best interest of both the industry and FSIS to take actions that will reduce the numbers of meat and poultry recalls.”
NAMP asked FSIS to take particular considerations when sampling at small and very small plants producing fresh ground beef for same-day or next-day delivery.
“For these types of establishments, the prior notice given by FSIS is the key to being able to hold product while still meeting their daily customer orders,” NAMP relayed. “Often, these orders are placed in the morning for an afternoon delivery or the evening before for a next day delivery. As an additional hurdle, many of these establishments are physically limited by their size, and do not have the cooler or freezer space to hold large amounts of raw materials in order to create a new lot of product on short notice in the event of an FSIS test.
“FSIS must work with these companies very closely, and the FSIS inspectors in these plants must have adequate training to understand the challenges of taking a sample in which all product can be held pending test results. These plants may often require more than 48 hours of prior notification,” NAMP concluded.
NAMP further requested that samples from small and very small establishments producing fresh product receive priority status once they arrive at the FSIS laboratory.
To read the entire comments, visitwww.namp.com.