Public Health Information System: 

Industry Session 

Inspection Verification 

Features 

 Inspection Results 

 Noncompliance 

 Inspector Notes/Agendas/MOIs/NR Appeals 
 

Inspection Verification Features 

 Inspection Results 

 Noncompliance Records 

 Inspector Notes 

 Meeting Agendas 

 Memorandum Of Interview (MOI) 

 Correspondence 

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Inspection Verification Menu – Inspection Results 

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Header 

Tabs 

Detail 

Footer 

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9 

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Documentation Policy – HACCP Information 

 The HACCP plans, CCPs, 

products that IPP verify are 

now documented 

 How IPP verify regulatory 

requirements (i.e., review and 

observation or recordkeeping) 

is now documented 

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Documentation Policy – Regs Verified 

 IPP will identify what regs were 

verified during the procedure 

 “Mandatory” regs must be 

verified in order to complete the 

inspection task 

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 When IPP document compliance with 

corrective actions, they are to include 

a brief description of their 

observations that support a finding of 

compliance 

Documentation Policy – Corrective Actions 

416.15 or 417.3 

 Record these affirmative findings in 

the text box (Inspection Results 

Findings tab) 

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Establishment identified the cause of the 

deviation to be a short in the cooler fan 

motor. The cooler fan motor was replaced. 

The establishment implemented a 

maintenance program for the coolers. All 

product was held. The establishment used 

the Combase Perfringens predicator 

computer modeling program to evaluate the 

cooling deviation. Results indicated no 

growth of C. botulinum and less than 1 log 

growth of C. perfringens 

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What is Noncompliance (NC)? ●
 

 Failure to meet a regulatory 

requirement 

 IPP are to: 

 Notify the establishment orally and in 

writing of any NC found in a timely manner 

 Document NC on an NR in PHIS 

 Give the NC/NR to establishment 

 Verify establishment brings itself back into 

compliance 

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Noncompliance (NC) ●
 

 Only one NR is completed per 

inspection procedure, but more than 

one noncompliance with a regulation or 

regulations can be documented on that 

one NR 

 Thus, there may be multiple pages to 

one NR. Each page documents a 

different NC or NCs
 

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Noncompliance (NC) ●
 

 PHIS tracks and counts each regulation 

verified and each regulation that is 

noncompliant 

 FSIS believes that individual instances of 

regulatory noncompliance is a better 

way to measure an establishment’s 

performance than numbers of 

procedures performed or NRs issued. 

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The Noncompliance Record (NR) ●
 

 Serves as official notice of regulatory 

noncompliance 

 The NR form: 

 Minor changes from PBIS 

 Captures more information 

 Different numbering method 

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Example Noncompliance Record (NR)
 

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X 

2/17/11 LIC4709025117N M38572 

Mike Adams Beth Smith 

416.4(a)-Food contact surface cleaning 

416.13(c) Plant monitors implementation 

of SSOP procedures 

Pre-Operational X

SSOP 

B00000057 

TASK 

Public Health Information System: 

Industry Session 
 

 

 

 

Example Noncompliance Record (NR)
 

At approximately 6:45 am while performing pre-operational sanitation inspection, I 

observed meat scraps and fat on the mixing arms of the blender in the formulation area. I 

applied a U.S. Reject tag to the blender. I notified the sanitation manager, Ms. Smith, of my 

findings. After sanitary conditions were restored, I relinquished control of the blender. 

Not under appeal 

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Inspector Notes Tool ●
 

 May be used to document conditions or 

observations that do not rise to the 

level of NC, but still need to be 

discussed with plant management, e.g.: 

 Less than perfect sanitary conditions that 

could lead to NC if conditions worsen 

 Less than perfect implementation of a 

prerequisite program 

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Inspector Notes Tool ●
 

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IPP Communication with Plant Management ●
 

 Entrance meetings 

 Awareness meetings 

 Weekly meetings 

 For cause meetings (e.g., positive 

pathogen sample result) 

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Weekly Meetings/Agenda Items ●
 

 When and Why (Directive 5000.1) 

 Possible Topics (Directive 5010.1) 

 In-plant observations 

 Agency issuances 

 FSIS sampling information 

 Information related to the establishment’s food 

safety system 

 Information from external sources 

 Any inspection-related activities occurring outside of 

approved hours of operation 

 Issues/information establishment wishes to share
 

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Meeting Agenda Tool ●
 

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Weekly Meetings – Dir 5000.1 and 5010.1 ●
 

 Documented in PHIS using the “meeting 

with establishment management” task
	

 Meeting notes are documented in an MOI
 

 IIC responsibilities in multi inspector / 

multi shift establishments
 

 Ensure regulatory concerns from all shifts are 

discussed 

 May include CSIs and FIs at the meeting 

 May delegate conducting the meeting to IPP 

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Memorandum of Interview (MOI) ●

 Purpose 

 Document no participation/no 

response 

 No standardized MOI format
 

 MOI copy is given to the plant 

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MOIs ●
 

 If an establishment disagrees with 

any part 

 Establishment should discuss first with 

IPP 

 IPP will note it at the end of MOI or as 

attachment 

 Establishment can submit own 

minutes or notes as attachment
 

 Establishment can challenge the MOI 

following the OFO chain of command 

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MOIs ●
 

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Example MOI ●
 

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Example MOI ●
 

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Plant Management Responses in PHIS ●
 

 Use Web but need eAuthentication 

account to log into PHIS 

 Need at least one PHIS Administrator 

role 

 Access to information in PHIS is 

based on a user role 

 May respond to NRs in PHIS 

 May appeal NCs/NRs in PHIS 

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Plant Management Response to NC/NR 

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Plant Management Response to NC/NR
 

Blender was re-cleaned and sanitized 

before being used in production. 

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Plant Management Response--NC/NR Appeals
 

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Plant Management Response--NC/NR Appeals
 

Section 416.15 and 416.16 requires 

us to establish and record 

preventive measures when product 

is directly contaminated. Since no 

product was present during preoperational sanitation inspection, 

no product was directly 

contaminated due to the product 

residue on the food contact surface. 

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FSIS Response to Plant NC/NR Appeals
 

The establishment restored 

sanitary conditions before 

using the blender, and 

therefore met the requirements 

of 416.15. Preventive measures 

are only required when product 

is directly contaminated or 

adulterated. 

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Appeal History is Tracked in PHIS
 

Section 416.15 and 416.16 requires us 

to establish and record preventive 

measures when product is directly 

contaminated. Since no product was 

present during pre-operational 

sanitation inspection, no product was 

directly contaminated due to the 

product residue on the food contact 

surface. 

The establishment restored sanitary conditions 

before using the blender, and therefore met the 

requirements of 416.15. Preventive measures 

are only required when product is directly 

contaminated or adulterated. 

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Questions & Answers
 

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