Excellent advice on how poultry processing plants should approach their relationships with the Food Safety and Inspection Service (FSIS) was presented by Vanessa Smith, quality assurance manager, Pilgrim's Inc., Douglas, Ga., at the 2013 Poultry Processor Workshop. Her presentation, "Answering NRs: All while maintaining a cordial relationship with USDA," listed things plant personnel should do - and not do - when Noncompliance Records (NRs) are received from FSIS.
Tip 1: Obtain the facts and stick to them
- First, determine if there was, in fact, noncompliance.
- If there was noncompliance, begin compiling the facts.
- First and foremost -- What was the noncompliance?
- What time did the noncompliance occur?
- Who observed the noncompliance (hourly workers, supervisors, managers)?
- What was done to correct the noncompliance?
- What was put in place to prevent the noncompliance?
Tip 2: Be familiar with the regulations
Knowing the regulations in 9 CFR is the first step in avoiding Noncompliance Records, but at the very least know where to go to find them (http://bookstore.gpo.gov).
Tip 3: Strive to be neat and clear, not messy and jumbled in written responses to Noncompliance Records
There is nothing wrong with hand-written responses to the Noncompliance Record, but typed information is easier to read.
Things to avoid doing
To effectively build and/or maintain productive working relationships with USDA refrain from answering Noncompliance Records using statements such as the following:
- We were already doing X when USDA took control …
- If the inspector had done …
- Plant management told us …
- Another inspector said …
- This is how we've always done …
Will following Williams' advice ensure good working relationships with FSIS? There are no guarantees. After all, any relationship is a two-way street. However, plants that violate the advice can be pretty sure the results won't be as desired.