Burden of Proof

Lorentz Take: In 2016, FSIS is going to focus on reviewing the requirement that plants validate their HACCP plans.  Over the 17 years HACCP plans have existed, validation has depended heavily on theoretical research, such as academic papers.  Plants, especially small plants, find that theory does not always line up with practice.  In those situations, a plant must then show through internal studies that their system does indeed protect food safety.  In talking to organizations throughout the country looking to expand USDA processing in their area, Mike Lorentz has often said USDA is not the biggest hurdle they face in launching a business.  However, this validation requirement does indeed put a lot of strain on already limited resources for small USDA facilities, increasing the cost of entry for new processors entering the market.  Sad to say, but depending on the outcome of FSIS’s review, USDA may indeed have placed insurmountable obstacles for some small processors.

FSIS is leaning on processors to prove their HACCP controls are working, but theory and practical application are two different things.

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