Evaluation Report - Feedback on FSIS Directive on Microbial Sampling of Ready-
To-Eat (RTE) Products, Revision 1 and Amendment 1
Final Report
06/15/01
Introduction
This brief report summarizes the comments of
field inspection personnel regarding the FSIS
Directive on Microbial Sampling of Ready-To-
Eat (RTE) Products, Revision 1 (10,240.2) and
Amendment 1 (issued on 12/00, followed by
the Amendment issued 2/01). These comments
were gleaned from a telephone survey of a
sample of 47 IICs in plants producing RTE
products supplemented with a sample of 8
directors of state cooperative programs. Also
analyzed were questions on this Directive
received by the Technical Service Center and
Headquarters staff. Results are reported as
follows: key findings, clarity concerns for the
main content sections of the Directive, the
questions and answers section, the table,
obtaining help for clarification, and distribution
problems. The results for the Amendment are
included with the appropriate sections of the
Directive. The responses from both federal and
state inspectors are similar unless noted.
Key Findings
Overall, respondents felt the Directive and
Amendment were sufficiently clear. Hands-on
experience with a positive test result helped
inspectors to understand the Directive better, as
did unit meeting discussions. Releasing the
Amendment
shortly
after
the Directive
succeeded in clarifying some difficult topic
areas.
Nevertheless, respondents raised questions
about the appropriateness of sampling and
testing procedures for very small plants that
produce small and intermittent amounts of
product.
Inspectors would like additional detail on the
definition of RTE products, along with specific
examples.
The Amendment clarified some
issues of definition regarding products such as
lard and pork popped skins, but a number of
questions remain.
Inspectors remain uneasy with plants that add a
label requiring cooking in a perceived effort to
avoid
RTE
microbiological
testing
requirem