The U.S. Department of Agriculture’s Food Safety and Inspection Service
(FSIS) has issued instructions for inspection program personnel (IPP) to
follow “when verifying that large official establishments (with 500 or more
employees) that produce meat and poultry products have prepared and are
maintaining required written recall procedures.” According to FSIS, the notice
complies with a May 8, 2012, final rule outlining requirements for notifying
the agency of adulterated or misbranded products and maintaining written
recall procedures. It also calls on IPP to remind large establishments “of the
availability of food defense plan guidance because food defense plans also
facilitate the removal of adulterated products from commerce.”

Although food defense plans are currently voluntary, FSIS has stressed that their purpose is to help meat and poultry companies “respond to intentional contamination of products” and may be used with other recall systems. Written recall procedures, however, must “specify how the official establishment will decide whether to conduct a product recall and the procedures it will follow should it decide that one is necessary.” Establishments do not need to file these procedures with FSIS but must make them available to inspectors upon request.

About The Author

For decades, manufacturers, distributors and retailers at every link in the food chain have come to Shook, Hardy & Bacon to partner with a legal team that understands the issues they face in today's evolving food production industry. Shook attorneys work with some of the world's largest food, beverage and agribusiness companies to establish preventative measures, conduct internal audits, develop public relations strategies, and advance tort reform initiatives.

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