Edited by Jeremy Russell
September 7, 1999
Some Mega Relief
By Steve Sayer, Alpha Meat Co.
Generally, whenever one gets a headache or any other form of body aches, there is usually an over the counter medicine that can safely be taken for relief. But what can one apply to relieve or at least truncate work-related aches in the guise of government regulations?
By now any USDA Inspected Company that is presently operating under the 1996 Mega Reg decree could very well be in need of some Mega relief. The same could be said for the very small companies that will be coming on line next January with regards to their "Mega anticipation and expectations".
For facilities which are presently operating under the Mega Reg, just maintaining one’s head afloat while battling the daily grind of requisite paper work and verification procedures can at times prove to be both stifling and nerve racking for even the most impassive person.
Utilize and guide the intrinsic pro-activism of your established Good Manufacturing Practices (GMP’s) to act as your company’s remedy of relief for both your SSOP and HACCP Systems. Though GMP’s cannot substitute directly for Critical Control Points they can nevertheless dulcify the way. And ... an old misplaced and forgotten gemstone from the FSIS’ archives can help.
Just over a quarter of a century ago on April 5, 1972 the FSIS developed and introduced a Planned Improvement Program (PIP) (MPI-W-Notice 47) that was intended for the Establishments themselves to identify deficiencies/deviations and to initiate and document corrective actions to their facilities, equipment and possibly to general operations in some instances. This indirect pre-cursor to the HACCP philosophy, although intended for facility and equipment improvements and not situations where contamination of products is a potentiality, advocated that the Establishments themselves become more preventive in nature and more accountable for the conditions and actions of their operations.
Previous articles in Lean Trimmings and other reputable publications have emphasized time again that a true Science based HACCP System is preventive in nature. Secondly HACCP is designed to bring deviations and/ or deficiencies back up to acceptable levels. So does the old PIP Program of yesteryear. Both Systems requires dates, signatures and verifications all filed in chronological order for any future review. When used concurrently in today’s environment they make a most formidable defensive team.
Utilizing the elderly but venerable PIP program and expanding it with your myriad well-spring of GMP’s will doubly ensure your Inspector that your plant and its operations are being properly monitored and maintained by management. Use creativity to your PIP Program. For example present "Pictorial PIP’s" to your Inspector. Inexpensive Polaroid or digital instant pictures of projects that have been completed or have yet to be completed.
By planning and generating even slight revisions in your company’s personal hygiene practices or Pest Control Program, a plant will be perceived as being pro-active while at the same time further augmenting the ever important communications line between Establishment and the Inspector-In-Charge. Becoming pro-active via your GMP’s will spell relief not only for your company but also, in most instances you’ll be delighted to discover, for your Inspector.