Commonly Asked Questions from Small and Very Small Plants Regarding
Noncompliance Records (NR) (1)
Question 1a: When should inspection program personnel write a
noncompliance record (NR)?
Answer 1a: A NR is to be completed whenever inspection program personnel
determine that an establishment has failed to meet one or more regulatory
requirements.
Question 1b: Do Enforcement Investigation and Analysis Officers (EIAO)
write NRs, or do they instruct inspection program personnel to write them?
Answer 1b: It is not the role of an EIAO to issue an NR or to instruct inspection
program personnel to issue an NR. However, EIAOs can recommend that
inspection program personnel write an NR to document regulatory
noncompliance observed during a Food Safety Assessment.
Question 2: Is there a specific number of NRs that inspection program
personnel are supposed to write?
Answer 2: No, inspection program personnel will document only the regulatory
noncompliances that they observe on NRs.
Question 3: How much time can pass before an NR should not be linked to
another NR?
Answer 3: Inspection program personnel should consider several factors in
deciding whether to link NRs including whether:
•
the noncompliance is from the same cause
• a trend is developing
•
the establishment’s further planned actions were not implemented
•
the establishment’s further planned actions were not effective in reducing
the frequency of the noncompliances (if there was a substantial period of
compliance since previous NR)
•
the establishment finds it necessary to continue to evaluate and
implement measures to address recurring noncompliances on an ongoing
basis
If any of these factors apply to the situation, NRs can be linked without regard
to time limitations.
Commonly Asked Questions from Small and Very Small Plants Regarding
Noncompliance Records (NR) (1)
Question 4: Are all NRs with the same procedure code linked?
Answer 4: No, NRs are linked because they involve the same cause. The
procedure code is