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Slaughter Food Safety Standard 

Objectives 

After completion of this module, the participant will be able to: 

1. List the three contaminants covered by the food safety standard in livestock 

slaughter. 

2. Identify the carcass parts that must be free of the three contaminants covered 

by the livestock food safety standard. 

3. Identify the location where FSIS verifies the food safety standard for livestock 

carcasses. 

4. Identify the contaminant covered by the food safety standard in poultry 

slaughter. 

5. Identify the location where FSIS verifies the food safety standard for poultry 

carcasses. 

6. Describe how to perform the livestock zero tolerance verification task. 

7. Describe how to perform the poultry zero tolerance verification task. 

8. List the actions IPP take when they find a zero tolerance failure during the 

performance of the poultry and livestock zero tolerance verification tasks. 

9. Document zero tolerance verification tasks in PHIS. 

10.Describe the enforcement actions when repetitive zero tolerance 

noncompliance is documented in PHIS. 

Introduction 

The Food Safety and Inspection Service (FSIS) published in FR 97-067N 

notification that the Agency views its ‘‘zero tolerance’ for visible fecal material as 

a food safety standard. In slaughter establishments, fecal contamination of 

carcasses is the primary avenue for contamination by pathogens including Shiga 

toxin producing E. coli (STECs), Salmonella, and Campylobacter. These 

pathogens may reside in fecal material, both in the gastrointestinal tract and on 

the exterior surfaces of the animal or bird going to slaughter. Without proper 

handling and sanitary dressing of carcasses during slaughter, the edible portions 

of the carcass can become contaminated with bacteria capable of causing illness 

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in humans. The organisms may spread directly from carcass to carcass or 

indirectly by hands, utensils, or equipment. 

Because fecal material is a vehicle for pathogens, and because virtually all 

slaughter establishments recognize that contamination of meat by pathogenic 

microorganisms from fecal material, ingesta, or milk is a food safety hazard that 

is reasonably likely to occur in the slaughter production process, IPP are to verify 

that slaughter establishments have implemented process controls that are 

effective in reducing the occurrence of pathogens. To determine the 

effectiveness of the establishment’s controls, FSIS enforces a “zero tolerance” 

standard for visible fecal material on poultry carcasses and visible fecal, ingesta, 

or milk material on livestock carcasses, head, cheek, and weasand meat at 

inspected establishments that slaughter poultry or livestock at a specific point in 

the process. 

Now let’s discuss the slaughter food safety standard for livestock and poultry 

postmortem and how it is verified. 

Enforcing Food Safety Standard for Livestock Postmortem 

References: FSIS PHIS Directive 6420.2, Regulations: 9 CFR 310.17(a), 

310.18(a), and Part 417. 

On-Line Livestock (Cattle including Veal, Swine, Sheep and Goat)

Inspection 

On-line IPP verify the removal of contamination while examining heads, viscera, 

carcasses, and carcass parts during post-mortem inspection. If on-line IPP 

observe contamination on heads, viscera, carcasses and carcasses parts, IPP 

do not pass the carcass or part until all the contamination is promptly removed in 

a satisfactory manner. IPP verify that livestock slaughter establishments are 

complying with 310.17(a), and 310.18(a). 

310.17(a) states: 

Lactating mammary glands and diseased mammary glands of cattle, sheep, 

swine, and goats shall be removed without opening the milk ducts or sinuses. If 

pus or other objectionable material is permitted to come in contact with the 

carcass, the parts of the carcass thus contaminated shall be removed and 

condemned. 

9 CFR 310.18(a) states: 

Carcasses, organs, and other parts shall be handled in a sanitary manner to 

prevent contamination with fecal material, urine, bile, hair, dirt, or foreign matter; 

however, if contamination occurs, it shall be promptly removed in a manner 

satisfactory to the inspector. 

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On-line inspectors inspect carcasses and parts using the livestock inspection 

procedures outlined in FSIS Directive 6100.2. On-line IPP focus their attention on 

carcass by carcass or product examination and determine whether or not the 

establishment is meeting the regulatory requirements in the regulations 

referenced above. 

Carcass Inspection 

On-line IPP in livestock establishments inspect each carcass to ensure each 

carcass and attached parts are free of fecal material, milk, ingesta, urine, bile, 

hair, dirt, or foreign matter contamination as part of the final rail post-mortem 

inspection. When on-line inspectors find feces, ingesta, or milk on livestock 

carcasses, the establishment reexamines and removes all contamination from 

the entire carcass. On-line inspectors take a regulatory control action and 

stop the slaughter line unless: 

• The establishment has provided a rail-out loop; and 

• The IIC has determined that the establishment’s rail-out loop is adequate 

and operated in a manner to maintain sanitary conditions (i.e., prevents 

carcass-to-carcass contact or cross contamination due to carcasses 

accumulating on the rail-out loop) 

Note: The rail-out loop allows the establishment to rail contaminated 

carcasses off-line for trimming of the carcass off-line. On-line IPP 

reinspect the railed out carcasses trimmed by the establishment after the 

establishment places them back on-line before the on-line inspection 

station. 

Additionally, on-line inspectors are to notify the IIC or, if unavailable, other off-line 

IPP when they believe that: 

• An establishment’s slaughter or sanitary dressing processes are not under 

control, for example, when there is repetitive presentation of carcasses 

contaminated with fecal material, ingesta, or milk at the rail inspection 

station; or 

• An establishment’s rail-out procedure is inadequate to prevent carcass 

accumulation and cross-contamination of other carcasses. 

Head Inspection 

IPP inspect heads that the establishment has prepared in a sanitary manner and 

are ready for inspection based on the method of presentation that has been 

approved by the FLS or IIC. The method may vary with the species of livestock. If 

the on-line head inspector finds contamination on any surface of the head during 

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inspection, the on-line head inspector is authorized to stop the line until such 

contamination is removed and the inspection is completed. Before inspecting and 

passing the head, the on-line head inspector verifies on-line that the 

establishment removes the contamination (on-line or off-line) in a safe and 

sanitary manner. On-line IPP also verify that the establishment properly disposes 

of heads that do not pass inspection. 

On-line head inspectors notify the IIC or, if unavailable, other off-line IPP when 

they believe that the establishment’s slaughter process is not under control (e.g., 

repeated presentation of heads contaminated with fecal material, ingesta, or milk 

during postmortem inspection). To determine the effectiveness of the 

establishment food safety system, off line IPP are to perform a livestock zero 

tolerance task, sanitary dressing procedure task, and verify other regulatory 

requirements as needed. 

Weasand Meat Inspection 

While performing viscera inspection, if the on-line inspector finds contamination 

on weasand meat during the harvesting step, the on-line inspector is to verify the 

contamination is removed before the weasand meat can be passed. On-line 

viscera inspectors notify the IIC or other off-line IPP when they believe that the 

establishment’s slaughter process on the table or at viscera inspection is not 

under control, e.g., repeated presentation of weasand meat, other parts, or 

carcasses contaminated with fecal material, ingesta, or milk for postmortem 

inspection. To determine the effectiveness of the establishment food safety 

system, off line IPP are to perform a livestock zero tolerance task, sanitary 

dressing procedure task, and verify other regulatory requirements as needed. 

Note: On-line IPP who retain carcasses or carcass parts for veterinary 

disposition are not to authorize establishment trimming until final inspection by a 

Public Health Veterinarian (PHV) has been made per 9 CFR 310.3. IPP are to 

notify off-line IPP or PHV if there are any concerns over the identity, location, or 

sanitary handling of retained carcasses and associated parts. Retained 

carcasses and associated parts are identified using devices in 9 CFR 312.6(a). 

Requirements for inspection facilities, handling of contaminated or retained 

carcasses and parts, and the reinspection of livestock and poultry carcasses or 

parts to ensure such carcasses or parts are not adulterated or misbranded are 

specified in 9 CFR 307.2(g), 310.3, 310.17(a), 310.18(a), 318.2(b) and (d), 

381.65(f) and 381.91. Any retained carcass or part that passes inspection by

the PHV is subject to reinspection and zero tolerance verification.

Livestock (Cattle including Veal, Swine, Sheep and Goat) Food Safety 

Standard Verification 

Off-line IPP verify that an establishment has adopted controls in its food safety 

system that it can demonstrate are effective in reducing the occurrence of 

pathogens, including the controls that prevent contamination of carcasses and 

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carcass parts with fecal material, milk and ingesta. Off-line IPP follow 

instructions, perform verification or inspection tasks, and take enforcement 

actions as described in FSIS PHIS Directives 5000.1and 5000.6. When off-line 

IPP verify the adequacy of the establishment’s procedures in preventing the 

contamination of carcasses and head, cheek, and weasand meat with fecal 

material, ingesta, or milk, they follow the instructions and verification methods 

including performing Livestock Zero Tolerance tasks as outlined in FSIS Directive 

6420.2. 

IPP verify the food safety standard for visible fecal, milk, and ingesta 

contamination on livestock carcasses at or after the postmortem rail inspection 

station and before any additional trimming, washing, or application of carcass 

interventions by performing the Livestock Zero Tolerance verification task. The 

establishment’s CCP for pathogen contamination or visible contaminants may be 

at other locations as supported by the hazard analysis. For example: 

• The establishment may locate the CCP after the postmortem rail 

inspection station. 

• In other cases, the establishment may have a CCP prior to the 

postmortem rail inspection station. 

Note: Regardless of the location of the establishment’s CCP, FSIS off-line IPP 

will verify compliance with the livestock zero tolerance food safety standard at or 

immediately after the rail inspection station and before any additional trimming, 

washing, or application of any interventions. 

Head meat, check meat and weasand meat may be used in the production 

ground beef products. If the meat from these parts is contaminated; it represents 

a way of importing pathogens, including E. coli O157:H7, other Shiga toxin 

producing E. coli (STECs), and Salmonella spp., into ground beef products. 

Hence, to reduce the possibility of E. coli O157:H7, other Shiga Toxin producing 

E. coli (STECs), and Salmonella contamination, establishments must also meet 

the food safety standard for no visible fecal, milk, or ingesta contamination on 

head meat, cheek meat, and weasand meat. This verification takes place after 

the establishment has implemented all of its controls and interventions, and at 

the point of final packaging or when product is placed in a container for storage 

which is considered to be the end of the harvesting process. 

IPP verify hearts, oxtails, market heads, stomachs, intestines, livers, and other 

meat by-products not attached to the carcass are clean and harvested in a 

sanitary manner. These organs are not subject to zero tolerance verification 

unless they are attached to the carcass. When these carcass parts are 

contaminated, IPP verify other regulatory requirements such as sanitary dressing 

9 CFR 416.1 and 416.4(d) and slaughter HACCP requirements in 9 CFR Part 

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417 to determine whether the establishment’s control measures and sanitary 

dressing procedures prevent contamination during the production process. 

Livestock heads, tails, or other parts attached to the carcass at the final rail are 

subject to zero tolerance verification and are inspected with the carcass when 

IPP perform the zero tolerance task. 

Livestock parts separated from the carcass and not subject to livestock zero 

tolerance verification are subject to slaughter HACCP verification. 

Livestock (Cattle including Veal, Swine, Sheep and Goat) Zero Tolerance 

Verification Task 

Frequency of the Verification Task 

Off line IPP are to perform the Livestock Zero Tolerance Verification task on 

carcasses and head, cheek, and weasand meat at a minimum of one time per 

slaughter shift. Each livestock zero tolerance verification task includes 

examination of not only carcasses but also head, cheek and weasand meat. IPP 

may verify the slaughter food safety standard on carcasses and head, cheek, 

and weasand meat at the same or at different times during the shift. 

IPP perform additional directed zero tolerance tasks whenever the 

establishment’s slaughter process and sanitary dressing appear out of control. 

Off-line IPP make such a determination based on: 

• Notification by on-line IPP that there is repetitive presentation of 

carcasses, heads or viscera contaminated with fecal material, ingesta, or 

milk during postmortem inspection; 

• Observations or findings of insanitary dressing which confirm on-line IPP 

observations; 

• Observations of insanitary dressing made on the slaughter or processing 

floor (e.g., head boning); or 

• Previous findings of zero tolerance noncompliance. 

Livestock Carcass Verification 

Off-line IPP verify zero tolerance on a pre-determined number of carcasses 

selected after postmortem inspection and at or after the postmortem rail 

inspection station but prior to additional trimming, washing, or application of 

interventions to the carcass. Off-line IPP verify the selected carcasses are not 

contaminated with visible fecal material, ingesta, or milk. If necessary, IPP retain 

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the selected carcasses to ensure the establishment does not continue to trim the 

carcasses while off-line IPP are completing their verification. 

Off-line IPP follow the steps below when verifying the establishment’s food safety 

system is controlling fecal material, ingesta, or milk contamination on livestock 

carcasses during the zero tolerance task. 

1. Determine the expected slaughter volume for the shift (i.e., the total number 

of animals to be slaughtered on the shift). 

2. Based on the expected slaughter volume for the shift, determine the number 

of carcass units (whole carcasses, carcass sides, or equal numbers of hind 

and forequarters) to be examined depending on what can be done safely and 

efficiently within a particular establishment and by using the following table. 

For example, if the table instructs IPP to examine 12 whole carcasses (12 

carcass units), they could alternately examine 24 sides or 24forequarters and 

24 hind quarters. 

Slaughter Volume (# of animals 

pershift) 

# of Carcass Units 

(1 Unit = whole 

carcass) 

# of Sides 

100 or less 2 4 

101 to 250 4 8 

251 to 500 8 16 

More than 500 12 24 

Note: For each zero tolerance task performed, it is not necessary to examine 

all of these units at the same time. 

3. Select the carcass units at or after the postmortem rail inspection station 

for examination on-line regardless of the location of the establishment’s 

CCP. IPP select the carcass units for the slaughter food safety standard 

verification as follows: 

• After trimming of contamination identified by the on-line inspector, 

• After the on-line inspector completes carcass inspection, 

• Before washing of the carcass, 

• Before application of post final rail carcass antimicrobial interventions, 

• Before disassembly of the carcass, and 

• In a random manner. 

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Note: In certain situations, such as those related to worker safety, the IIC with 

concurrence of the FLS may develop appropriate alternative or temporary 

procedures with establishment management for carcass inspection to be 

properly and efficiently conducted until such deficiencies can be permanently 

addressed. 

4. Examine the outside of the selected carcass units using the same method 

that on-line IPP use at the postmortem rail inspection station. 

Note: For hide-on veal calves, IPP are to perform zero tolerance on all 

exposed (i.e., not covered by hide) and internal surfaces 

5. Identify fecal material or ingesta using the color and texture characteristics, 

and milk using the color and consistency characteristics provided in Directive 

6420.2 and Attachment 3 of this handout. 

6. Keep the PHV-IIC or supervisor aware of the establishment’s process control 

status as needed. 

Note: IPP in one-inspector assignments perform livestock zero tolerance 

verification tasks when acting in the off-line inspector role, i.e., the IPP "changes" 

roles from “on-line inspector” to “verification inspector” when verifying the 

slaughter food safety standard. IPP use the same carcass selection criteria 

described above. 

Head Meat, Cheek Meat, and Weasand Meat Verification 

As part of each Livestock Zero Tolerance verification task performed, off-line IPP 

also verify that head, cheek, and weasand meat are not contaminated with visible 

fecal material, ingesta, or milk when the product is ready for final packaging or to 

be placed in storage. Off-line IPP follow the steps below when verifying that head 

meat, cheek meat, and weasand meat are free of feces, ingesta, and milk during 

the zero tolerance task. 

1. Review the HACCP plan. 

2. Examine the same amount of product as the establishment has listed in the 

HACCP plan for its monitoring procedure. 

Note: 9 CFR 417.5(a)(2) requires that the establishment maintain a written 

HACCP plan, including decision-making documents associated with the 

selection and development of the CCPs and critical limits, and documents 

that support both the monitoring and verification procedures selected and the 

frequency of those procedures. Because the establishment is required to 

have documents to support the monitoring procedures (amount of product 

examined), IPP should examine the same amount of product as the 

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establishment has listed in the HACCP plan for the monitoring procedure. If 

the establishment does not have documents supporting the monitoring 

procedures, sample size, and frequency, there is noncompliance with 9 CFR 

417.5(a)(2). 

3. Select product at the final packaging step or when the product is placed in a 

container for storage after all of the establishment controls and interventions. 

4. Examine all outer surfaces of the product selected for fecal material, ingesta, 

or milk. Identify fecal material or ingesta using the color and texture 

characteristics, and milk using the color and consistency characteristics 

provided in Directive 6420.2 and Attachment 3 of this handout. 

Enforcing the Food Safety Standard for Poultry Postmortem 

References: FSIS , FSIS Directive 6420.5, FSIS Regulation 381.65(f), and part 

417. 

Verifying that Establishments Prevent Carcasses Contaminated with Feces 

from Entering the Chilling System 

IPP inspect birds for wholesomeness and verify establishment systems are 

adequate and effective in controlling food safety hazards and producing safe 

wholesome product. FSIS enforces a food safety standard of zero for visible 

fecal material on poultry carcasses through postmortem inspection and 

reinspection activities at poultry slaughter establishments. 

9 CFR 381.65(f) states: 

Official poultry slaughter establishments must develop, implement, and maintain 

written procedures to ensure that poultry carcasses contaminated with visible 

fecal material do not enter the chiller. Establishments must incorporate these 

procedures into their HACCP plans, Sanitation SOPs, or other prerequisite 

programs. 

IPP do not allow poultry carcasses with visible feces to enter the chiller or the 

chill step. FSIS views preventing carcasses with visible fecal contamination from 

entering the chilling tank as critical to preventing the cross-contamination of other 

carcasses. 

Note: FSIS Directive 6420.5 and this handout provide instructions for conducting 

verification activities to determine whether an official establishment is complying 

with 9 CFR 381.65(f). This directive does not affect or change the requirements 

associated with the inspection, reinspection, or disposition of poultry carcasses 

observed to have pathological conditions per 9 CFR 381.81 to 381.93. 

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Note: Poultry major portions and parts are not subject to poultry zero tolerance 

verification but are subject to slaughter HACCP verification. 

Poultry Zero Tolerance Verification Task 

IPP assigned to establishments that operate under Streamlined Inspection 

System (SIS), New Line Speed Inspection System (NELs), New Turkey 

Inspection System (NTIS), or Traditional Inspection systems are to perform 

scheduled and unscheduled Poultry Zero Tolerance verification tasks off line to 

verify that the establishment is preventing carcasses with fecal material from 

entering the chiller (9 CFR 381.65(f)). 

Frequency of the Verification Task 

Off-line IPP are to conduct at least two fecal contamination checks for each 

evisceration line for every shift (i.e., the number of checks will total at least 2 

times the number of lines per shift) and as scheduled by the Public Health 

Veterinarian. For example, in a four evisceration line poultry slaughter 

establishment, IPP will perform and document 8 poultry zero tolerance 

verification checks for each shift. In establishments with multiple slaughter lines, 

IPP may need to schedule directed tasks in PHIS above the routine number of 

Poultry Zero Tolerance Verification Tasks assigned by PHIS to meet the two 

fecal contamination checks for each evisceration line for every shift requirement. 

For example, if the establishment has four lines and two routine zero tolerance 

verification tasks were already scheduled for the day, then at least six additional 

zero tolerance tasks should be performed as directed tasks. 

Poultry Carcass Verification 

Off-line IPP are to verify the establishment’s dressing process prevents poultry 

carcasses with visible fecal contamination from entering the chilling system (air, 

ice or tank chilling). Off-line IPP follow the steps below when performing poultry 

zero tolerance verification tasks. 

1. Randomly select 10 carcasses using an established FSIS method after the 

final wash and prior to entering the air or tank chiller. 

2. Examine the selected carcasses off line, at either: 

• The pre-chill testing station; or 

• Any location after final trim prior to the chiller tank in establishments 

operating under traditional inspection. 

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3. Examine the selected carcasses using the following inspection method: 

• For the outside back – While holding the carcass, with the back of the 

carcass toward the observer, start at the hock area and observe the 

hocks, back part of the legs, tail area, back of the carcass and top side of 

the wings. 

• For the outside front – Turn the carcass and observe the bottom side of 

the wings, breast, and front part of the legs 

• For the inside – Observe the inside surfaces of the carcass and the 

abdominal flaps and fat. 

• For the neck flap area – Observe the neck flap and the thoracic inlet area. 

4. Identify fecal material using the color, consistency and composition 

characteristics provided in Directive 6420.5 and in Attachment 1 of this 

handout. 

Note: For poultry carcasses ingesta found during zero tolerance or FPS 

verification is “extraneous material” that may contribute to development of 

insanitary conditions in the chiller; it is not a zero tolerance noncompliance. If 

ingesta is observed during the zero tolerance task, the establishment should 

be notified of the finding and remove it from the carcass or part. IPP are to 

evaluate any findings of ingesta contamination with respect to the 

establishment’s sanitary dressing and to consider the possible sources of the 

ingesta contamination when performing their verification activities. 

Documentation of Livestock and Poultry Zero Tolerance

Verification Results in PHIS 

IPP must verify either 9 CFR 310.18(a) or 9 CFR 381.65(f) while performing the 

zero tolerance task. IPP may also verify any of HACCP regulations in Part 417 

while performing the task. After verifying the regulations, off-line IPP document 

the results in PHIS. IPP select the “review and observation” verification activity 

radio button on the “Activity” tab of the Inspection Results page for each zero 

tolerance task performed. 

Documenting Compliance with the Zero Tolerance Task 

When IPP do not observe any fecal material, ingesta, or milk on livestock 

carcasses or on head, cheek, or weasand meat, or feces on poultry carcasses 

during the verification, and no other regulatory noncompliance is observed, they 

select the mandatory regulation and any HACCP regulations they verified on the 

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“Regulations” tab. IPP mark the zero tolerance task as ‘Inspection Completed’ at 

the bottom of the Inspection Results page. 

Documenting Noncompliance with the Zero Tolerance Task 

If IPP find feces, ingesta, or milk on livestock carcasses or head meat, cheek 

meat, or weasand meat while performing the livestock zero tolerance verification 

task, or find feces on poultry carcasses while performing the poultry zero 

tolerance verification task, IPP are to: 

• Verify regulatory requirements associated with 9 CFR 310.18(a), or 

381.65(f) and any HACCP regulations verified during zero tolerance 

verification task, 

• Notify the establishment that a zero tolerance noncompliance with 9 CFR 

310.18(a) or 381.65(f) exists. If the zero tolerance finding is on a livestock 

carcass after the postmortem rail inspection station, or on a poultry 

carcass after the pre-chill testing station, and at or past the 

establishment’s zero tolerance CCP, IPP inform the establishment that a 

deviation from a critical limit has occurred, 

• Document the noncompliance on an NR citing 9 CFR 310.18(a) or 

381.65(f) and 9 CFR 417.2(c)(4) if a deviation from a critical limit has 

occurred (the establishment failed to adequately monitor at a CCP to 

ensure compliance with the critical limit), 

• For poultry zero tolerance failures include a statement that the 

establishment is not preventing feces from entering the chiller on the NR, 

• Document noncompliance with any additional HACCP regulations that 

were verified during the zero tolerance task on the same NR, and 

• Select the mandatory 9 CFR 310.18(a) or 9 CFR 381.65(f) regulation plus 

any HACCP regulations that were verified while performing the task on the 

“Regulations” tab of the Inspection results page. 

Note: When IPP determine zero tolerance noncompliance while performing the 

zero tolerance verification task, they are to perform a Slaughter HACCP 

Verification task to verify that the establishment performs corrective actions for 

the affected product in accordance with 9 CFR 417.3(a). 

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HACCP System Verification after Positive Zero Tolerance 

Findings 

After notifying the establishment of the zero tolerance noncompliance, off-line 

IPP are to: 

• Schedule either a directed Slaughter HACCP or Operational SSOP 

Review and Observation verification task in PHIS, 

• Indicate “zero tolerance noncompliance” as the reason for performing the 

directed task in PHIS, and 

• Verify the establishment has performed all the required corrective actions 

in accordance with 9 CFR 417.3(a), 417.3(b), or 416.15(b) and 417.3(b) 

and is properly implementing its HACCP system. 

Which Corrective Actions Requirements Must be Met? 

If controls in HACCP plan: When the establishment has a zero tolerance CCP 

in a HACCP plan, IPP are to verify the establishment has met the HACCP 

requirements in while performing the directed (follow-up) Slaughter HACCP 

verification task. The establishment has, per 9 CFR 417.3(a): 

• Identified and eliminated the cause of the deviation, 

• Ensured that the CCP is under control after the action is taken (e.g., 

another zero tolerance failure is not likely to be detected if the task were 

performed again), 

• Established measures to prevent recurrence, and 

• Ensured that no product that is injurious to health enters commerce. 

o The sampled carcasses are restored to a wholesome, unadulterated 

condition before they continue on the line or re-enter the chiller (air or 

tank), and 

o The affected product (carcasses and parts) represented by the sample 

is safe, wholesome, and not adulterated. This usually involves isolating 

all product back to the establishment’s last acceptable zero tolerance 

check and restoring wholesomeness or another “supportable” action. 

If controls in SSOP: For poultry establishments that have incorporated 

procedures for preventing carcasses with visible fecal material from entering the 

chiller into the Sanitation SOP, IPP are to verify the establishment has met the 

SSOP and the HACCP unforeseen hazard corrective action requirements while 

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performing the directed (follow-up) Operational SSOP Review and Observation 

verification task. The establishment has, per 9 CFR 416.15(b): 

• Ensured appropriate disposition of contaminated product, 

• Restored sanitary conditions, and 

• Prevented recurrence of direct contamination or adulteration of products, 

And, the establishment has, per 9 CFR 417.3(b): 

• Segregated and held affected product, 

o The affected product usually involves isolating all product back to the 

establishment’s last acceptable zero tolerance check or another 

“supportable” amount of product. 

• Determined acceptability of affected product for distribution, 

• Ensured that no product injurious to health enters commerce, and 

• Performed a reassessment. 

If controls in Prerequisite Program: For poultry establishments that have 

incorporated procedures for preventing carcasses with visible fecal material from 

entering the chiller into another prerequisite program, IPP are to verify the 

establishment has met the HACCP unforeseen hazard corrective action 

requirements while performing the directed (follow-up) Slaughter HACCP 

verification task. The establishment has, per 9 CFR 417.3(b): 

• Segregated and held affected product, 

o The affected product usually involves isolating all product back to the 

establishment’s last acceptable zero tolerance check or another 

“supportable” amount 

• Determined acceptability of affected product for distribution, 

• Ensured that no product injurious to health enters commerce, and 

• Performed a reassessment. 

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Verify the Establishment’s HACCP System Implementation and 

Recordkeeping 

IPP are to use the review and observation, recordkeeping, or both verification 

components during the Slaughter HACCP or Operational SSOP verification task 

to verify that the establishment is meeting the regulatory requirements. 

IPP may directly observe carcasses (hands-on examination) at the 

establishment’s zero tolerance CCP (9 CFR 417.8), or the point in the process 

identified in the Sanitation SOP or other prerequisite program; review the 

establishment’s slaughter HACCP plan, Sanitation SOP, or other prerequisite 

program, and observe establishment personnel: 

• Performing the establishment’s zero tolerance monitoring procedure at the 

specified frequency in the plan (9 CFR 417.2 (c)(4), Sanitation SOP 

(416.13(b)) or other prerequisite program (417.5(a)(1)), 

• Performing the establishment’s verification, direct observation of 

monitoring procedure, observing the establishment employee conducting 

the zero tolerance monitoring procedure at the specified frequency (9 CFR 

417.2(c)(7)), or 

Note: The establishment’s direct observation of the employee performing 

the zero tolerance check verifies the individual is finding and correctly 

identifying all feces, ingesta, or milk on carcasses or parts. Establishment 

verification procedures also verify carcasses found to be contaminated are 

restored to wholesome unadulterated state. 

• Performing corrective actions (9 CFR 417.3 and/or 416.15) 

Note: The establishment should start corrective actions upon being 

notified of the zero tolerance failure. For poultry carcass zero tolerance 

failures, the establishment’s corrective actions are likely to address 

carcasses already in the chiller, about to enter the chiller, the chiller media 

(if the chiller is a tank), and the carcasses that have exited the chiller. 

IPP may review establishment records related to its zero tolerance CCP, or the 

procedures for preventing poultry carcasses contaminated with fecal material 

from entering the chiller in the Sanitation SOP or other prerequisite program. IPP 

should seek the answers to the following questions. 

1. Does the establishment have documentation that supports the location of 

the zero tolerance CCP, and the development of the monitoring and 

verification procedures and frequencies according to 9 CFR 417.5(a)(2) or 

support for the development of the monitoring and frequencies in the 

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Sanitation SOP or other prerequisite program according to 9 CFR 

417.5(a)(1)? 

2. Does the establishment have records that document the results of its zero 

tolerance monitoring and verification procedures? 

3. Does the establishment document all corrective actions performed in 

accordance with 9 CFR 417.5(a)(3) or 416.16(a)? 

Note: IPP are to refer to FSIS Directive 5000.1 for instructions on determining 

SSOP and HACCP noncompliance. 

Documenting the Result of the Slaughter HACCP or Operational SSOP 

Review and Observation Verification Task in PHIS 

When the establishment is in compliance with the regulations, IPP select the 

mandatory HACCP regulations, or Sanitation SOP regulations, and any other 

regulation they verified on the “Regulations” tab and mark the task as ‘Inspection 

Completed’ at the bottom of the Inspection Results page. 

If IPP find noncompliance with a HACCP regulation, Sanitation SOP regulation or 

any other regulatory requirement, they are to notify the establishment and 

document the noncompliance on an NR citing the appropriate regulation per 

FSIS Directive 5000.1. For instance, if a poultry establishment has incorporated 

procedures to prevent carcasses with visible fecal contamination from entering 

the chiller into the Sanitation SOP, and does not monitor the daily implementation 

of such procedures, the IPP would issue an NR citing 9 CFR 416.13(c) and 

381.65(f). 

If a poultry establishment does not have written procedures to prevent carcasses 

with visible fecal contamination from entering the chiller or has not incorporated 

the procedures into its HACCP system, IPP are to issue an NR citing 9 CFR 

381.65(f). 

Note: If IPP find zero tolerance failures on livestock carcasses past the final rail 

or on poultry carcasses, major portions, or parts at or beyond the pre-chill testing 

station while performing inspection tasks other than the zero tolerance task 

(stumble-on occurrences), they are to document the noncompliance under the 

appropriate PHIS task (Slaughter HACCP or Operational SSOP Review and 

Observation verification task). IPP are to verify that the establishment 

implements corrective action that meets the requirements of 417.3(a), 417.3(b), 

or 416.15(b) and 417.3(b) and that the establishment’s is properly implementing 

its HACCP system during the performance of this task. Off-line IPP may need to 

perform a directed instance of the routine verification task unless the verification 

task is already scheduled for that day and it has not been completed. 

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Enforcement 

Association of Noncompliance 

• If IPP find repeated zero tolerance noncompliance and determine that 

these findings are from the same cause, the current NR is to be 

associated with a most recent zero tolerance or related NR. 

• For each NR, IPP are to use the NR reporting tools in PHIS to identify 

previous NRs that might be associated with the current NR. IPP are to 

refer to the PHIS Users Guide for instructions on how to use the PHIS 

tools for this purpose. When associating NRs for the same cause, IPP are 

to follow the methodology set out in FSIS PHIS Directive 5000.1 

• If the findings do not show the same cause, IPP are not to associate the 

NRs. 

Note: FSIS PHIS Directive 5000.1 and 6410.1 indicate noncompliance with SPS 

requirements can be associated to Sanitation SOP or HACCP noncompliance for 

the same cause including the zero tolerance NRs. 

The System Approach in Enforcement 

When evaluating the overall effectiveness of the food safety system, IPP have 

access to the results of any establishment testing and of any monitoring activities 

that may have an impact on the establishment’s hazard analysis (See FSIS 

Directive 5000.2 and FSIS Directive 5000.6). IPP are to review establishment 

testing results on at least a weekly basis while performing the PHIS “Review of 

Establishment Data” task. 

When IPP have concerns about whether the documented zero tolerance 

noncompliance is repetitive and indicative a system failure, the IIC is to consider 

repeated and associated zero tolerance findings in NRs with other inspection 

results or establishment records support a need for additional enforcement 

actions. 

The IIC is to factor in any trends of zero tolerance noncompliance with results 

from HACCP, SSOP, sanitary dressing, and SPS verification. IPP are to also 

compare any trends in noncompliance as they relate to FSIS and establishment 

testing. The IIC is to determine whether the findings show that there have been 

isolated incidents of zero tolerance noncompliance, or if the findings are 

evidence of a systemic problem with the food safety system. 

Such an evaluation is to consider the following: 

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1. Evidence or lack of evidence that the establishment has implemented all 

required parts of its HACCP system (e.g., HACCP, SSOP, sanitary dressing, 

or pre-requisite programs). 

2. The rate of HACCP, SSOP, Sanitary Dressing or SPS noncompliance. 

• Compliance with HACCP (9 CFR 417) requirements, 

• Sanitation SOP compliance (FSIS PHIS Directive 5000.1), 

• Sanitation Performance Standard compliance (FSIS PHIS Directive 

5000.1), and 

• Sanitary Dressing compliance (FSIS Directive 6410.1) 

3. Any trend in the rate of noncompliance over time (increase or decrease). 

4. Supporting documentation (9 CFR 417.5(a)(1)) or verification results (9 CFR 

417.5(a)(2)) that the establishment’s corrective actions and preventive 

measures (e.g., antimicrobial interventions) are effective or not effective . 

5. Relevant laboratory testing results in conjunction with records such as: 

• Any other establishment testing data (FSIS Directive 5000.2 Rev. 2), 

• Generic E. coli (or other indicator organism) results from establishment 

testing or carcasses, or parts that indicate increasing microbial 

contamination, and 

• FSIS microbiological testing results (e.g. Salmonella test results and 

multiple positive STEC results in raw beef manufacturing trimmings from 

FSIS routine and follow-up sampling). 

6. The association of zero tolerance and related NRs with evidence of 

inadequate implementation of the food safety system (HACCP, SSOP, 

Sanitary Dressing, and SPS) or laboratory testing can lead to a determination 

that the food safety system is less than adequate. If so, the IIC is to alert the 

Frontline supervisor (FLS) and follow the methodology set out in FSIS PHIS 

Directive 5000.1, Chapter VI, Rules of Practice 1. Enforcement Actions, to 

determine the appropriate enforcement action. 

Note: Off-line IPP must be aware that zero tolerance noncompliance may be 

indicative of insanitary dressing procedures prior to final inspection or packaging. 

IPP need to consider what regulatory requirements can also be verified closer to 

the source or origin of the contamination. 

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Attachment 1 

Identification of Feces for Poultry 

To determine whether an establishment is preventing poultry carcasses with 

visible fecal material from entering the chilling tank (as required by 9 CFR 

381.65(f)), inspection program personnel who examine carcasses must be able 

to properly identify feces. 

Three factors—color, consistency, and composition—are essential in identifying 

fecal material on the inside or outside of poultry carcasses. 

• The color of feces ranges from varying shades of yellow to green, brown, and 

white. 

• The consistency of feces is characteristically semi-solid to a paste. 

• The composition of feces may or may not include plant material. Inspection 

program personnel must take care to distinguish feces from ingesta. 

• The color of ingesta varies with the diet. 

• The consistency of ingesta is characteristically solid or granular; digestive 

fluids sometimes are present. 

• The composition of ingesta is identifiable plant material. 

(9 CFR 381.65(f) does not apply to ingesta. However, inspection program 

personnel who find ingesta during fecal contamination checks are to notify 

establishment management to remove ingesta from affected carcasses.) 

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Attachment 2 

Livestock Carcass Examination 

Based on the expected slaughter volume for that shift (number of animals), IPP 

determine the number of carcasses or carcass sides to be examined, using the 

following table. 

Number of Animals 

Slaughtered 

Number of carcasses to 

be Sampled 

Number of sides to be 

Sampled 

100 or fewer 2 4 

101 to 250 4 8 

251 to 500 8 16 

More than 500 12 24 

a. Select the appropriate number of carcass units randomly. 

b. Examine the selected carcass units using the same systematic technique 

that inspection IPP use at the post-mortem rail inspection station. 

c. IPP performing zero tolerance verification may separately and 

independently examine the designated number of hind quarters and 

forequarters to verify the appropriate number of sides or carcasses. 

d. IPP may use the above table when slaughtering multiple livestock species 

provided carcasses are selected randomly. 

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Attachment 3 

Identification of Contaminants for Livestock 

To verify the proper removal of contamination from carcasses or carcass parts, 

IPP assigned to verify that the sanitary dressing procedures are effective must be 

able to properly identify feces, ingesta, or milk. IPP are to verify the presence of 

feces, ingesta, or milk by color, texture, and consistency. 

The actual appearance of feces and ingesta reflect the diet, age of the animal, 

type of animal (functioning rumen; non-ruminant)and regional feeding practices. 

Therefore, the descriptions below are guidelines and are not absolute. The PHVIIC in each official establishment is the final arbiter regarding any disputed 

findings of feces, ingesta, or milk representing a zero tolerance noncompliance. 

A. Livestock Feces and Ingesta 

IPP are to identify foreign material as feces or ingesta based on two factors: color 

and texture. 

Livestock Feces and Ingesta Contamination Identification Chart 

Cattle Swine Sheep and

Goat 

Color Cattle; and 

Heavy Calf 

(ruminating) 

Calf 

(non 

ruminating) 

Yellow, tan, 

brown, or green. 

Green, 

brown, to 

black 

Yellow, 

green, or 

brown 

White, 

yellow, tan 

Texture Fibrous or 

plant-like 

texture; may 

include 

grain 

particles 

depending 

on diet. 

Pasty May include 

identifiable grain 

particles or 

fibrous plant 

material. 

Fibrous or 

plant-like; 

feces or 

ingesta may 

also be 

tarry. 

Size: The size or quantity of feces or ingesta is largely unimportant 

in identifying fecal or ingesta contamination. However, as 

size decreases, color and texture become more difficult to 

discern. 

NOTE: Bile is a contaminant on carcasses and parts per 9 CFR 310.18 but 

is not counted as a zero tolerance defect. 

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B. Milk 

Inspection program personnel are to identify foreign material as milk based on 

two factors: color and consistency. 

Milk, if present, tends to be found on the midline, during or after removal of 

mammary glands (udder) from lactating animals. 

Criteria for Identification of Milk on Livestock Carcasses 

Beef Swine Sheep and Goat 

Color clear to white to light yellow 

Consistency watery to ropy or curdy 

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Workshop: Food Safety Standard in Slaughter 

Refer to the handout to complete the following questions. 

1. What contaminants are covered by the food safety standard in livestock 

slaughter? 

2. What parts must be free of these contaminants? 

3. At what location will FSIS verify the food safety standard for livestock 

carcasses? 

4. Where will FSIS verify the food safety standard for head meat, cheek meat, 

and weasand meat in livestock slaughter operations? 

5. If a livestock slaughter establishment has a CCP for visible contaminants for 

livestock carcasses at the final washer, where would FSIS verify compliance 

with the food safety standard? 

6. A GS-7 inspector is performing on-line inspection at the rail inspection station 

in a large beef slaughter establishment. He notices a fecal smear on the 

hindquarter of a carcass. The establishment has a rail-out procedure. 

a. What action would he take? 

b. What action would he take if the establishment had no rail-out procedure? 

c. What is expected of the establishment? 

d. Would a Noncompliance Record (NR) be completed by the on-line 

inspector? By the off-line inspector if he or she was functioning as the online inspector? 

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e. If the GS-7 found repeated instances of contaminated carcasses during 

his time at the rail inspection station, what would he do? 

7. A GS-8 off-line slaughter inspector is assigned to a large beef slaughter 

establishment that kills 2000 head per shift. He is performing a Livestock Zero 

tolerance verification task to verify compliance with the slaughter food safety 

standard. 

a. How many sides would be selected for examination? 

b. Where, and with what technique, would the sample sides be examined? 

c. If ingesta were found on one carcass side, what action would he take? 

8. What contaminants are covered by the food safety standard in poultry 

slaughter? 

9. At what location will FSIS verify the food safety standard for poultry 

slaughter? 

10. If the establishment has a CCP at the antimicrobial rinse after the pre-chill 

FPS inspection location and just prior to the chiller, where would FSIS verify 

compliance with the slaughter food safety standard? 

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11. A new GS-8 off-line slaughter inspector is assigned to a large poultry 

slaughter operation that has 4 lines and slaughters 160,000 per shift. The 

establishment has two shifts. 

a. How many fecal contamination checks would need to be performed for 

one shift including all lines? 

b. How many birds are examined at each check? 

c. How are the birds selected at the pre-chill inspection station? 

d. If she found identifiable fecal material, what actions would she take? 

e. If she does not find any fecal material in any of the checks, what actions 

would she take? 

12. While performing a Poultry Zero tolerance task to verify the slaughter food 

safety standard on line 2, the IPPfound feces on chicken carcass, verified the 

establishment corrective actions, and documented noncompliance on an NR. 

About an hour after the establishment performed corrective actions and 

restarted line 2; he notices feces on a carcass on line 2 after the washer and 

prior to the chiller. The establishment tells him since this fecal contamination 

finding was not part of the Poultry Zero tolerance verification task, his finding 

was not a slaughter food safety standard (zero tolerance) failure. 

Note: The establishment has incorporated written procedures that prevent 

poultry carcasses contaminated with visible fecal material from entering the 

chiller into a HACCP plan). 

a. Is the establishment correct? 

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b. Is there noncompliance? If so, what inspection task should be used to 

document the noncompliance? 

c. If you determine that there is noncompliance with the regulatory 

requirements, what regulations should be cited on the NR? 

13.How do off-line IPP determine the amount of product to inspect when 

performing the Livestock Zero Tolerance verification task in a livestock 

slaughter establishment to verify that the meat from heads, cheeks, and 

weasands are not contaminated with fecal material, ingesta, or milk? 

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Zero Tolerance Verification Task Hands-on Exercise 

General Instructions 

• Read the General information and answer the question, 

• Schedule the directed poultry fecal zero tolerance verification tasks on the 

task calendar, 

• Read each scenario and document the result of the poultry zero tolerance 

verification task in PHIS based on the findings, and 

• Schedule a Slaughter HACCP verification task to document your 

verification of the establishment compliance with all parts of 417.3(a) and 

that the establishment is properly implementing its slaughter HACCP 

system. 

Establishment Information 

You are Cindy Soundly the off line IPP assigned to Novosibar which is a poultry 

slaughter establishment. Novosibar operates two 8 hour shifts, 5 days a week. 

The establishment has 4 evisceration lines but only two lines are operating on 

the day shift today. You decide to schedule one poultry zero tolerance task as 

routine and the remainder as directed. 

Note: The establishment has incorporated written procedures that prevent 

poultry carcasses contaminated with visible fecal material from entering the 

chiller into its HACCP plan, i.e., it has zero tolerance CCP). 

How many directed instances of the routine poultry zero tolerance task should be 

scheduled for today? 

Schedule Poultry Zero Tolerance Tasks in PHIS 

Add the one routine task and the number of directed poultry zero tolerance 

verification tasks that should be scheduled for today to the task calendar. 

Use the PHIS Quick Reference GUIDE as needed. 

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Poultry Zero Tolerance Verification Task Scenarios 

Scenario 1: The Routine and One of the Directed Task Findings 

At approximately 8:10 a.m., you randomly selected 10 birds from line 1 for the 

routine task and at approximately 8:40 a.m. you randomly selected 10 birds from 

line 2 for the first directed task. You examined the carcasses at the pre-chill 

finished product standards station. You did not observe any identifiable fecal 

material on the poultry carcasses during your verification, and no other regulatory 

noncompliance was observed. 

Scenario 2: Second Directed Task Findings 

At approximately 11:25 a.m., you randomly selected 10 birds from line 1. You 

examined the carcasses at the pre-chill finished product standards station. In the 

neck area of the 3rd carcass selected, you observed a 1⁄2 inch by 1⁄4 streak of 

yellowish granular material. In the same area of 8th carcass selected, you 

observed a 3⁄4 inch by 1⁄4 streak of greenish granular material. You determine that 

these defects are ingesta and notify the kill floor supervisor, Mr. Hurbert Jones. 

The ingesta was trimmed from the carcasses. You did not observe any 

identifiable fecal material on the poultry carcasses and no other regulatory 

noncompliance was observed. 

Scenario 3: Third Directed Task Findings 

At approximately 1:00 p.m., you randomly selected 10 birds from line 2. You 

examined the carcasses at the pre-chill finished product standards station. On 

the outside back of the 7th carcass selected, you observed a 1⁄2 inch by 1⁄4 brown 

pasty smear with plant material. You determine that the defect is fecal material. 

You notify the establishment kill floor supervisor, Mr. Hurbert Jones, and the 

evisceration supervisor, Jane Fontana, of the fecal contamination. Mr. Jones is 

shown the contamination and states “this is ingesta not feces“. Your supervisor 

PHV-IIC, Dr. Phyllis Isaacs, is shown the carcass and confirms the fecal 

contamination finding. You observe Ms. Fontana remove the contaminated 

carcass and take it to reprocessing where it was rinsed with 20-30 ppm 

chlorinated water. 

You stay in the area while the establishment performs corrective actions on the 

remaining affected product. Ms. Fontana determined that the vent machine was 

out of adjustment and the following corrective actions were taken. 

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• Maintenance stopped the line to readjust the vent machine; 

• All product between the vent machine (after it was readjusted) and the 

chiller was retained for reconditioning and reprocessing; 

• The overflow in the chill system for the carcasses was increased; 

• The level of chlorine in the chiller was increased from 20 ppm to 40 ppm; 

• All surfaces of the carcasses from the last acceptable monitoring check 

(approximately 40 minutes of production) were rinsed with 20-30 ppm 

chlorinated water; and 

• After the line was restarted, a QC technician sampled and examined 

carcasses entering the chill system for visible fecal material. 

Scenario 4: The Slaughter HACCP Verification Task 

Schedule the Slaughter HACCP Verification Task 

Since the establishment has a zero tolerance CCP in their HACCP plan, and IPP 

find identifiable fecal material on a carcass or carcass part while performing a 

Poultry Zero Tolerance task, IPP are to perform a directed Slaughter HACCP 

verification task to verify the establishment has performed all required HACCP 

corrective actions per 9 CFR 417.3(a) and is properly implementing its Slaughter 

HACCP system. 

Schedule a directed Slaughter HACCP verification task. Use “zero tolerance 

noncompliance” as the justification. 

Task Findings 

You directly observed some of the establishment’s corrective actions at the time 

the establishment implemented them (see scenario #3 above). Near the end of 

the shift, you review the establishment’s corrective action record in the HACCP 

coordinator’s office. In addition to the corrective actions you observed above, you 

find the following entries. 

• Maintenance personnel will inspect the functioning of the vent machine at 

first break; lunch and second break for each shift and make adjustments 

as needed. The result of each check will be documented on the fecal 

monitoring record. 

• Three fecal checks instead one check were performed per clock hour for 

the remainder of the shift. The additional fecal checks were documented 

on the fecal monitoring record. 

You ask the HACCP coordinator for the fecal monitoring record for the shift. He 

gives you all of the monitoring records for the shift which includes the chlorine log 

for the chilling CCP. You note that the establishment documented 6 fecal checks 

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for the last 2 hours for the shift. In addition, you see that the establishment has 

documented the vent machine check for the second break. You decide to review 

all the monitoring entries on the both the fecal and chlorine records. The 

establishment is monitoring at the frequency stated in the HACCP plan and the 

results are within the critical limit for each CCP. 

Note: Before this task can be completed, you must verify the monitoring, 

verification, corrective action, and recordkeeping requirements at all CCPs for the 

specific production. 

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Document the Inspection Results of the Zero Tolerance Tasks 

and Slaughter HACCP Verification Task in PHIS 

Working independently, log back into the PHIS computer and document the 

inspection results, you will: 

• Document the inspection result for each of the poultry zero tolerance 

verification task. Include any inspector notes. 

• If noncompliance is found, document the noncompliance on an NR, 

• Finalize the NC and complete the NR, if possible, 

• Complete the Task, if possible, and 

• Document the result of the Directed Slaughter HACCP Verification Task 

Use the PHIS Quick Reference Guide as needed. 

Inspection Methods 22-31