Commonly Asked Questions from Small and Very Small Plants on Corrective
Actions (1)
Question 1: Am I required to document SSOP and HACCP corrective actions
on the NR, or do I have to write them on my company record?
Answer 1: The requirement in 9 CFR 416.16 and 417.3(c) is that you document
Sanitation SOP and HACCP corrective actions. The establishment can document
these corrective actions on its records or on the NR. If the documentation is on the
NR, the NR becomes part of the HACCP or Sanitation SOP records and is required to
meet the recordkeeping requirements of those regulations.
Question 2: If I find a noncompliance and take appropriate corrective
actions, would the inspection program personnel also complete an NR?
Answer 2: No. If the establishment finds noncompliance and brings itself into
compliance with the regulatory requirements, inspection program personnel should
not issue an NR.
Question 3: If I write that I will retrain employees as my preventive
measure in response to a NR that was written as a result of my SSOP failing
to prevent direct contamination or adulteration of product, will all NRs with
this preventive measure be linked?
Answer 3: A thorough process should be carried out to determine the cause of each
noncompliance. If the establishment determines the cause of the subsequent
sanitation noncompliance is lack of, or insufficient, employee training, the NRs
should be linked as they are issued and discussed with establishment management
at the weekly meetings. These criteria are listed in the answer to Question 3 of the
Commonly Asked Questions from Small and Very Small Plants Regarding
Noncompliance Records (NR) (1) posted at the following link.
http://www.fsis.usda.gov/Help/FAQs_TSC_NR/index.asp.
Question 4: Do inspection program personnel have to agree with SSOP
corrective actions before removing the retain/rejected tag?
Answer 4: Inspection program personnel have been trained not to remove the
regulatory control acti