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Recommendation 9a: To close Recommendation 9a, which pertains to improving the consistency of FSIS's application of MPI policies and regulations, we have provided Enclosure 10, which includes instructions for completing FSIS Form 8110-2a, the Establishment Review and Assessment Worksheet, and the revised glossary used to complete the forms associated with the establishment review system.

As you know, many of our committments are in the early stages of development or implementation. Completion of these efforts should contribute to the improvement of the overall inspection program.

Enclosures (10)

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There are presently two Office of Inspector General audit reports in the Food Safety and Inspection Service (FSIS) that will not meet the legislatively mandated 6-month deadline for resolution. The Inspector General has recently provided you with a summary of these audits for your review and action. FSIS provided some additional information to the Inspector General after that summary was provided, so ar updated summary is being provided here for your use and discussion with FSIS.

The Inspector General's spring 1987 Semiannual Report to Congress is now in the final stages of preparation. The status of audit resolution can be updated until April 15, 1987. It is, therefore, urgent that necessary corrective actions or resolutions be established for these audits.

I would appreciate it if you would work directly with FSIS to bring about the necessary corrective actions in these audits. Please provide the Inspector General with an audit resolution plan by April 15, 1987.

PETER C. MYERS
Deputy Secretary

Attachment

1.

FOOD SAFETY AND INSPECTION SERVICE

Domestic Meat and Poultry Inspection Program
(38607-1-At) Issued September 26, 1986

Only three areas remain unresolved: (1) recalling unsafe products, (2) plant sanitation prior to operation, and (3) controls over pesticide and chemical usage in meat and poultry plants.

(1) Because "Class I" recalls involve products that, by definition, may cause serious health consequences or death, we questioned FSIS's decision not to issue press releases or make other public notifications for all Class I recalls.

Prior to our audit, FSIS had recognized the need for this public notification in these situations and issued Recall Directive 8080.1 which required the issuance of press releases in all Class I recalls.

In response to our recommendation that the Agency follow these provisions, the Agency provided a policy statement which included exceptions to this requirement for public notification. We agree that some limited exceptions may be appropriate. One would be when the firm responsible can / provide reasonable assurance that all of the recalled product has been returned or is accounted for. However, prompt public notification is FSIS's only method of warning consumers not to use recalled products. Therefore, FSIS should make the policy statement more specific to ensure that the length of time granted a firm to provide assurance of the return of recalled products does not exceed 48 hours. The policy statement should also provide for public notification in all areas where the recalled produce is likely to have been distribute.

Our recommendations concerning controls over the recall process were partially implemented through a revised Training Guide for Compliance Officers. However, FSIS has not agreed to take other prompt action, such as product seizure, when firms do not provide the reasonable assurance that recalled product has been removed from commerce.

(2) The preoperative sanitation procedures originally used only in poultry slaughter plants will also be used in red meat slaughter plants and processing plants. Because of the problems our audit disclosed in large poultry slaughter plants, we believe that FSIS should establish effective control over the review process before the Agency applies the procedures in other types of facilities. FSIS responded to our recommendation, that internal administrative controls be established over this procedure, by designating a twomember training team in each region. This does not provide an adequate basis for audit resolution.

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(3) In response to our recommendations concerning the need for control over pesticide and chemical usage in meat and poultry plants, PSIS is developing proposed regulations to require plants to maintain records of chemicals and pesticides they use. These proposed changes may increase the industry recordkeeping burden, and consequently may require lengthy review. Because the rulemaking process may take many months to complete, we believe that the agency should issue a Notice or other statement of policy requiring all inspectors to maintain a list of chemicals, pesticides, and lubricants approved for use in the plant. This interim measure will allow FSIS to establish effective control over the use of chemicals and ensure that only approved compounds are used.

FSIS has provided copies of a draft Directive that they believe address the need for interim action. This pest control directive appears to apply only to plants with Integrated Pest Management (IPM). Additionally, we have been advised by FSIS personnel that the reference to a companion directive addressing the full range of chemicals and scheduled for publication in late summer was made in error and no such directive is planned. Therefore, FSIS's actions are not adequate for audit resolution.

2.

Indirect Cost of the Wisconsin Department of Agriculture (38092–1‐Ch) Issued August 20, 1986

This audit is not resolved because FSIS has not agreed to adjust 1984 and 1985 indirect cost rates for unallowable legal expenses. The Agency agreed that legal expenses

should not be included as indirect costs and to make necessary adjustments for future fiscal years. However, we believe the rates for the previous years should also be adjusted.

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