Inspection Verification 

11/6/2019 

PHIS INSPECTION VERIFICATION (PART 3) 

Objectives 

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

1. Correct an error in a finalized noncompliance. 

2. State the purpose of associating NRs. 

3. Identify the requirement for associating NRs. 

4. Associate NRs in PHIS. 

5. Identify inspection findings that must be discussed at the weekly meeting. 

6. Create Meeting Agendas in PHIS. 

7. State the purpose of the Memorandum of Interview (MOI). 

8. Create a MOI in PHIS. 

Associating NRs in PHIS 

Purpose of Associating NRs 

The purpose of associating NRs is to document that the immediate and further 

planned actions or the corrective actions and preventive measures the 

establishment implements are not preventing the recurrence of the 

noncompliance. In other words, there is a trend of noncompliance occurring in 

the establishment. The Agency may not be able to take further enforcement 

actions against the establishment unless the IPP has documented the 

establishment’s inability to take actions that bring it back into compliance with the

regulations. The NR associations documented by IPP are vital for the Agency to 

protect public health. 

Determining if NRs should be Associated 

After IPP document the noncompliance, they need to consider whether the 

noncompliance is an isolated incident or part of a developing trend. IPP should 

use professional judgment when making the determination whether NRs should 

be associated. IPP should gather information by asking questions, assess the 

information, and make a sound, supportable conclusion. Some factors that IPP 

should to consider are: 

Inspection Methods 19a-1 
 

 

 

 

 

 

Inspection Verification 

11/6/2019 

1. How much time has elapsed since the previous NR was written? 

2. Was this noncompliance from the same cause as the previous NR? 

3. Were the establishment’s further planned actions implemented?

4. Were the establishment’s further planned actions effective in reducing the

frequency of these noncompliances? 

5. Is the establishment continuing to implement better further planned 

actions? 

IPP are to associate NRs when they indicate an ongoing trend of same cause 

noncompliances or systemic problems with the same aspect of the 

establishment’s food safety system. 

The trend may be caused by the establishment’s failure to implement its 

proposed preventive measures. Sometimes the establishment has implemented 

its proposed preventive measures; nevertheless, these measures are not 

effective in preventing the noncompliance from recurring. Frequently, SSOP or 

HACCP recordkeeping and corrective action NRs or SSOP or HACCP monitoring 

and corrective action NRs can be associated because they represent repetitive 

failure of the same aspect of the establishment’s food safety system.

******************************************************************************************** 

Note: If IPP are uncertain whether particular noncompliances should be 

associated, they are to request assistance from their supervisor. 

*************************************************************************************************** 

NR Association Examples 

The following examples represent situations when IPP should associate NRs and 

when they should not associate NRs. 

NR Association Example 1: The IPP issued an NR when he observed water 

dripping from the ceiling onto product in the production room due to the roof 

leaking on a rainy day (SSOP noncompliance). Three days later, he observes 

condensation (water) dripping from the ceiling onto product in the production 

room (another SSOP noncompliance). In both cases, water is the source of 

product contamination but the cause of the noncompliance is not the same (poor 

ventilation or air flow versus poor facility maintenance) so the IPP decides not to 

associate the NRs. 

NR Association Example 2: The IPP issued an NR when she observed 

condensation dripping from the ceiling in the patty production room that was not 

contaminating product (SPS noncompliance). In block 12 of the NR, the 

establishment proposed adding another fan in the patty production room to 

Inspection Methods 19a-2 
 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

improve air flow. Two weeks later, she observes condensation dripping from the 

ceiling onto patties on line one in the patty production room (SSOP 

noncompliance). She also notices that no additional fans have been installed in 

the patty production room. She concludes these two noncompliances are from 

the same cause (poor air flow or ventilation) and that the establishment did not 

implement the preventive measure to prevent recurrence of the noncompliance. 

She decides to associate the current NR to the previous NR. 

******************************************************************************************** 

Note: It is important that IPP realize that Sanitation Performance Standard 

(SPS), Sanitation SOP, or HACCP noncompliances may be associated when the 

cause of the noncompliance is the same as demonstrated in example 2. 

******************************************************************************************** 

NR Association Example 3: The IPP issued an NR when he observed that the 

establishment did not meet one of the recordkeeping requirements, there were 

no monitor’s initials for one result. About five months later, he again observes 

that the establishment monitor did not initial one of the monitoring results. 

Although these two noncompliances demonstrate repetitive failures from the 

same part establishment’s food safety system, the IPP determines that the

establishment has shown a substantial period of compliance, and he decides not 

to associate this NR to the previous one. 

NR Association Example 4: The IPP issued an NR for the establishment not 

performing a monitoring procedure as specified in the HACCP plan. Two weeks 

later she observes, at a CCP in a different HACCP plan, that the establishment 

does not perform the monitoring procedures as specified in the HACCP plan. 

She decides that the NRs demonstrate repetitive failures of the same part of the 

establishment’s food safety system (not performing monitoring according to the 

HACCP plan) and that she should associate them in her documentation. She 

realizes she may associate these noncompliances even when they involve two 

different HACCP plans. 

NR Association Example 5: The IPP issued an NR when she observed fecal 

material on a young chicken carcass while performing the poultry zero tolerance 

task. The establishment documented that the evisceration machine drawing 

spoons were out of adjustment, rupturing the intestines, and the eviscerating 

machine’s rinse system was not working as the cause of the zero tolerance 

failure. The next day, she again observes fecal material on a young chicken 

carcass while performing the poultry zero tolerance task. This time the 

establishment documented the cause of the zero tolerance failure was the vent 

machine being out of adjustment. Although the establishment has documented 

two different causes for the zero tolerance noncompliances, the IPP decides to 

associate this NR to the previous NR because the underlying cause of the 

noncompliance is the same, i.e., the establishment has poor equipment 

maintenance procedures. 

Inspection Methods 19a-3 
 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

Procedures for Associating NRs 

IPP use the “Noncompliances tab” on the Noncompliance page in PHIS to 

identify the previous NR that might be associated with the current NR. IPP click 

the arrow icon under the Link column for the NR and, then the “Maintain 

Associations” link. Search criteria such as key words in the description, the

noncompliant regulation or task name can be entered to assist IPP in identifying 

NRs that may be associated. IPP may also review the printed copies of the NRs 

in the open and completed files in the government office. 

To document a trend of noncompliance, the NRs must be associated as each 

noncompliance occurs, or as each NR is issued. The most recent previous NR 

with the same cause noncompliance should be associated. The IPP must 

associate this noncompliance to the current NR to establish the chronological 

history of the same noncompliance and ineffective preventive measures. If the 

IPP has been associating NRs in this manner (like adding a link to a chain), then 

it is not necessary to identify all of the previous associated NRs in block 6a of the 

current NR. 

When IPP associate noncompliances, they: 

 reference the previous NR number and the further planned action or the 

corrective action and preventive measures that were either not 

implemented or ineffective in preventing recurrence of the previous 

noncompliance in the description current noncompliance (block 10), 

 record the reason for their decision to associate the noncompliances in the 

Inspection Notes in PHIS, and 

 add the NR association as a discussion point to the weekly meeting 

agenda in PHIS. 

Example Description for an Associated NR: At approximately 10:16 a.m., 

while performing the Beef Sanitary Dressing task, I observed repeated instances, 

within a five-minute period, where the establishment’s employee hygiene

practices (GMP 01- Employee Hygiene Practices-Knife Sanitation 3.5) 

associated with the removal of udders from the carcasses were not being 

implemented as written, resulting in carcass contamination. This section of the 

establishment’s GMP requires that the employee removing the udder sanitize the 

knife each time between carcasses. The employees removing udders did not 

sanitize their knives between each carcass. Two different employees were 

observed removing the udders from three carcasses before sanitizing their 

knives. I notified the Slaughter Supervisor of the employees’ failure to sanitize

their knives between carcasses. A similar noncompliance was documented on 

NR # LIC9372041524N, dated1/6/2016, in which employees failed to sanitize 

their knives after opening the hide. Retraining establishment employees to follow 

Inspection Methods 19a-4 
 

 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

proper hygienic practices during the slaughter process and the written GMPs was 

ineffective in preventing recurrence of the noncompliance. 

IPP are to discuss the identified associations between noncompliances and 

describe to establishment management why the associated NRs indicate a trend 

of noncompliance during the weekly meeting. Open communication with 

establishment management is an essential to part of the regulatory process. If 

IPP are not discussing repetitive noncompliance issues with the establishment, 

and thereby allowing them the opportunity to get the operation under control, IPP 

are not doing everything they can to ensure that the establishment is being 

provided “due process”. IPP are to document the discussion of noncompliance 

trends and NR associations in the Memorandum of Interview (MOI). 

IPP should continue to associate NRs that are derived from the same cause until 

they determine that an enforcement action is necessary to bring the 

establishment into compliance with the regulations. The IPP’s documentation 

must show the development of a trend of noncompliance in order for the Agency 

to be able to support any recommendation for further enforcement action. When 

IPP believe that additional enforcement action is necessary, they contact the 

District Office through supervisory channels and request a Notice of Intended 

Enforcement (NOIE) be issued to the establishment in accordance with 9 CFR 

500.4. 

Maintaining NR Associations upon Rotation 

When IPP rotate into a new assignment or are assigned to an establishment for 

the first time, they should review block 6a on the NRs in both the open and 

completed file to determine if a trend in noncompliance has been occurring in the 

establishment. They should pay particular attention to the immediate and further 

planned actions or corrective actions and preventive measures the establishment 

has been taking to address the noncompliances. This will help ensure that IPP 

continue to associate noncompliance from the same cause with previous NRs 

and the establishment continues to be notified of the failure to implement 

effective further planned actions to prevent the noncompliance from recurring. 

Inspection Methods 19a-5 
 

 

Inspection Verification 

11/6/2019 

NR Association Workshop 

Objective: Ensure you understand the significance of associating NRs 

PHIS function: NR association 

Look at the following five NRs and answer the following questions: 

1.) Should any or all of the NRs be associated? If yes, please list the NR#s. 

2.) If any of these NRs should not be included in the association, identify the 

NR(s) and state why the NR(s) should not be associated. 

3.) Is there additional language that should be included in Block 10? 

Inspection Methods 19a-6 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

U.S. Department of Agriculture TYPE OF NONCOMPLIANCE 

FOOD SAFETY AND INSPECTION SERVICE Food Safety Other Consumer Protection 

NONCOMPLIANCE RECORD 

1. DATE 2. RECORD NO. 

03/06/15 LIC1208122516N 

4. TO (Name and Title) 

QC Supervisor 

6. RELEVANT REGULATIONS 

416.13(a) 

7. TITLES OF HACCP OR SSOP PLAN or OTHER SUPPORTING 

DOCUMENTATION 

3. ESTABLISHMENT NO. 

M38574+P38574 

5. PERSONNEL NOTIFIED 

Foreman 

6a. ASSOCIATED NR(s) 

7a. NAME OF CCP(S) or PREREQUISITE PROGRAM 

8. INSPECTION TASK 

Preoperational SSOP 

9. VERIFICATION ACTVITY 

Review & Observation Recordkeeping Both 

9a. AFFECTED PRODUCT INFORMATION 

9b. RETAIN/REJECT TAGS 

10. DESCRIPTION OF NONCOMPLIANCE 

At approximately 0400 hours after establishment pre-operational inspection and prior to start of production while 

performing preoperational SSOP review & observation task I observed rust and meat particles on three band saw 

blades stored on the boning table; rust, meat particles and a white residue on the food contact surfaces of the 

cuber. I applied US Reject tags # B1468923 and B1468924 to the blades and cuber parts respectively. I notified 

the foreman of the noncompliances and she initiated action to restore sanitary conditions. The regulatory control 

actions were relinquished when sanitary conditions were restored. 

11. SIGNATURE OF INSPECTION PROGRAM EMPLOYEE 

You are hereby advised of your right to appeal this decision as delineated by 306.5 and/or 381.35 of 9 CFR 

12. PLANT MANAGEMENT RESPONSE: 

The three band saw blades were disposed of. The sanitation crew soaked the cuber parts in acid solution to 

remove rust, meat specs and white residue. 

The SSOP will be modified to include a procedure for cleaning the saw blades in a manner that will prevent rust 

formation. A procedure will also be included for soaking the cuber in an acid solution. 

This document serves as written notification that your failure to comply with regulatory requirement(s) could result in 

additional regulatory or administrative action. 

13. SIGNATURE OF PLANT MANAGEMENT 14. DATE 

03/06/15 

15. VERIFICATION SIGNATURE OF INSPECTION PROGRAM EMPLOYEE 16. DATE 

03/09/15 

FSIS FORM 5400-4 DISTRIBUTION: Original & 1 Copy to Establishment, 1 Copy to Inspector 

Inspection Methods 19a-7 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

U.S. Department of Agriculture TYPE OF NONCOMPLIANCE 

FOOD SAFETY AND INSPECTION SERVICE  Food Safety  Other Consumer Protection 

NONCOMPLIANCE RECORD 

1. DATE 2. RECORD NO. 3. ESTABLISHMENT NO. 

03/14/15 LIC3408124916N M38574+P38574 

4. TO (Name and Title) 

QC Supervisor 

5. PERSONNEL NOTIFIED 

Foreman 

6. RELEVANT REGULATIONS 

416.13(a), 416.4(b) 

6a. ASSOCIATED NR(s) 

7. TITLES OF HACCP OR SSOP PLAN or OTHER SUPPORTING 7a. NAME OF CCP(S) or PREREQUISITE 

DOCUMENTATION 

8. INSPECTION TASK 

Preoperational SSOP 

9. VERIFICATION ACTVITY 

 Review & Observation Recordkeeping  Both 

9a. AFFECTED PRODUCT INFORMATION 

9b. RETAIN/REJECT TAGS 

10. DESCRIPTION OF NONCOMPLIANCE At approximately 0410 hours after establishment pre-operational 

inspection and prior to start of production I performed preoperational SSOP review & observation task. The 

following noncompliances were observed: Rust on the auger and auger throat of the #2 grinder, rust on the auger 

and blender arms of the small Hobart grinder; rust on the crossbar on top of the hopper to the stuffer, and dried 

residue on the blade guides and the bottom of the pulley on both band saws which is noncompliance with 

416.4(b). I applied US Reject tags # B 1469277, B 1469278, B1469279, B 1469280, and B 1469281 to the #2 grinder, 

the small Hobart grinder, the stuffer, and both band saws respectively. I notified the foreman of the 

noncompliances and she initiated action to restore sanitary conditions. After sanitary conditions had been 

restored, I relinquished the regulatory control actions. 

11. SIGNATURE OF INSPECTION PROGRAM EMPLOYEE 

You are hereby advised of your right to appeal this decision as delineated by 306.5 and/or 381.35 of 9 CFR 

12. PLANT MANAGEMENT RESPONSE: 

All items were cleaned and sanitized. The deficiency occurred because of the sanitation supervisor was not 

working last evening. 

The pre-op crew will be instructed to start pre-op monitoring 30 minutes earlier each day to provide them more 

time for inspection. The sanitation supervisor has been instructed to work more closely with the sanitation crew 

to ensure procedures are being appropriately implemented. 

This document serves as written notification that your failure to comply with regulatory requirement(s) could result in 

additional regulatory or administrative action. 

13. SIGNATURE OF PLANT MANAGEMENT 14. DATE 

03/15/15 

15. VERIFICATION SIGNATURE OF INSPECTION PROGRAM EMPLOYEE 16. DATE 

03/17/15 

FSIS FORM 5400-4 DISTRIBUTION: Original & 1 Copy to Establishment, 1 Copy to Inspector 

Inspection Methods 19a-8 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

U.S. Department of Agriculture TYPE OF NONCOMPLIANCE 

FOOD SAFETY AND INSPECTION SERVICE  Food Safety  Other Consumer Protection 

NONCOMPLIANCE RECORD 

1. DATE 2. RECORD NO. 3. ESTABLISHMENT NO. 

03/20/15 LIC4307125717N M38574+P38574 

4. TO (Name and Title) 5. PERSONNEL NOTIFIED 

QC Supervisor Foreman 

6. RELEVANT REGULATIONS 6a. ASSOCIATED NR(s) 

416.4(b) 

7. TITLES OF HACCP OR SSOP PLAN or OTHER SUPPORTING 7a. NAME OF CCP(S) OR PREREQUISITE PROGRAM 

DOCUMENTATION 

8. INSPECTION TASK 9. VERIFICATION ACTVITY 

Preoperational SSOP  Review & Observation  Recordkeeping  Both 

9a. AFFECTED PRODUCT INFORMATION 

9b. RETAIN/REJECT TAGS 

10. DESCRIPTION OF NONCOMPLIANCE At approximately 0415 hours while performing the Pre-Operational 

Sanitation SOP Review & Observation task, the following was observed: Rust on the outer surfaces of the 

product brine tank; dried meat particles on the outer surface of the band saw cabinet; dried fat and meat particles 

on one of the legs of the boning table. The foreman was notified of the sanitation noncompliance. The foreman 

instructed the sanitation crew to initiate immediate corrective actions. 

11. SIGNATURE OF INSPECTION PROGRAM EMPLOYEE 

You are hereby advised of your right to appeal this decision as delineated by 306.5 and/or 381.35 of 9 CFR 

12. PLANT MANAGEMENT RESPONSE: 

No product was involved. The boning table, brine tank, and band saw were re-cleaned and sanitized 

immediately. All deficiencies were documented on the pre-op sanitation report. 

We will instruct the sanitation crew to check all pieces of equipment for rust and meat particles after cleaning. 

The sanitation foreman will assess the cleaning process for the equipment more closely. 

This document serves as written notification that your failure to comply with regulatory requirement(s) could result in 

additional regulatory or administrative action. 

13. SIGNATURE OF PLANT MANAGEMENT 14. DATE 

03/20/15 

15. VERIFICATION SIGNATURE OF INSPECTION PROGRAM EMPLOYEE 16. DATE 

03/26/15 

FSIS FORM 5400-4 DISTRIBUTION: Original & 1 Copy to Establishment, 1 Copy to Inspector 

Inspection Methods 19a-9 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

U.S. Department of Agriculture TYPE OF NONCOMPLIANCE 

FOOD SAFETY AND INSPECTION SERVICE  Food Safety  Other Consumer Protection 

NONCOMPLIANCE RECORD 

1. DATE 2. RECORD NO. 3. ESTABLISHMENT NO. 

03/22/15 LIC5606123921N M38574+P38574 

4. TO (Name and Title) 5.PERSONNEL NOTIFIED 

QC Supervisor Foreman 

6. RELEVANT REGULATIONS 6a. ASSOCIATED NR(s) 

416.13(a); 416.4(b); 416.1 

7. TITLES OF HACCP OR SSOP PLAN or OTHER SUPPORTING 7a. NAME OF CCP(S) or PREREQUISITE PROGRAM 

DOCUMENTATION 

8. INSPECTION TASK 9. VERIFICATION ACTVITY 

Preoperational SSOP  Review & Observation  Recordkeeping  Both 

9a. AFFECTED PRODUCT INFORMATION 

9b. RETAIN/REJECT TAGS 

10. DESCRIPTION OF NONCOMPLIANCE At approximately 0412 hours after the establishment’s preoperational inspection and prior to start of production while performing the preoperational SSOP review & 

observation task, the following noncompliances were observed: Frayed plastic edges on four bone dust 

scrapers; rust on the blender arm and in the bottom of the hopper of the small Hobart grinder; rusty tenderizer 

needles; and rust on the hand contact surface of the edible product shovel. No sanitation records were 

available when the inspection task was performed. I placed US Rejected tags B 1472001, B 1472002, B 

1472003, and B 1472004 respectively. I notified the foreman of the noncompliances and she initiated action to 

restore sanitary conditions. After sanitary conditions had been restored, I relinquished the regulatory control 

actions. 

11. SIGNATURE OF INSPECTION PROGRAM EMPLOYEE 

You are hereby advised of your right to appeal this decision as delineated by 306.5 and/or 381.35 of 9 CFR 

12. PLANT MANAGEMENT RESPONSE: 

The affected areas were re-cleaned and sanitized. The deficiency occurred due to lack of following procedures 

by the night manager. No product was adulterated due to the deficiency. 

The operations manager will re-address the importance of following the already in place procedures and 

completing the sanitation checklist. The production manager will check the room before the pre-op sheet is 

signed. 

This document serves as written notification that your failure to comply with regulatory requirement(s) could result in 

additional regulatory or administrative action. 

13. SIGNATURE OF PLANT MANAGEMENT 14. DATE 

03/22/15 

15. VERIFICATION SIGNATURE OF INSPECTION PROGRAM EMPLOYEE 16. DATE 

03/23/15 

FSIS FORM 5400-4 DISTRIBUTION: Original & 1 Copy to Establishment, 1 Copy to Inspector 

Inspection Methods 19a-10 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

U.S. Department of Agriculture TYPE OF NONCOMPLIANCE 

FOOD SAFETY AND INSPECTION SERVICE  Food Safety  Other Consumer Protection 

NONCOMPLIANCE RECORD 

1. DATE 2. RECORD NO. 

03/28/15 LIC5706123321N 

4. TO (Name and Title) 

QC Supervisor 

6. RELEVANT REGULATIONS 

416.13(a); 416.1 

7. TITLES OF HACCP OR SSOP PLAN or OTHER SUPPORTING 

DOCUMENTATION 

3. ESTABLISHMENT NO. 

M38574+P38574 

5. PERSONNEL NOTIFIED 

Foreman 

6a. ASSOCIATED NR(s) 

7a. NAME OF CCP(S) or PREREQUISITE PROGRAM 

8. INSPECTION TASK 

Preoperational SSOP 

9. VERIFICATION ACTVITY 

 Review & Observation  Recordkeeping  Both 

9a. AFFECTED PRODUCT INFORMATION 

9b. RETAIN/REJECT TAGS 

10. DESCRIPTION OF NONCOMPLIANCE At approximately 0400 hours, I performed the preoperational review & 

observation task in the processing area. The inspection was done after the establishment’s pre-operational 

sanitation inspection was completed. The following observations were made while performing this task: raw 

material (meat) particles were scattered on the metal wire guard of the packing machine; and an accumulation of 

raw material (meat) from the previous day’s operation in the seams of the paddles and paddle cogs of the Hobart 

mixer. I took a regulatory control action on the packing machine and the Hobart mixer with US Reject B 1472103 

and B 14721204 respectively. I notified the Foreman and after sanitary conditions were restored, I relinquished 

the regulatory control actions. The sanitation record was not available when this task was performed. 

11. SIGNATURE OF INSPECTION PROGRAM EMPLOYEE 

You are hereby advised of your right to appeal this decision as delineated by 306.5 and/or 381.35 of 9 CFR 

12. PLANT MANAGEMENT RESPONSE: 

The areas found to be deficient were re-cleaned and sanitized before processing began for the day. The cause of 

the deficiency was a lack of training the sanitation crew and pre-op crew. No product was adulterated due to the 

deficiency. 

The sanitation crew has been trained on how to properly clean the areas in question and the night manager has 

been instructed to inspect these and other areas more thoroughly each night. To prevent recurrence we have 

done the above training and also require that our pre-op personnel check these areas specifically for the next 2 

weeks. 

This document serves as written notification that your failure to comply with regulatory requirement(s) could result in 

additional regulatory or administrative action. 

13. SIGNATURE OF PLANT MANAGEMENT 14. DATE 

03/28/15 

15. VERIFICATION SIGNATURE OF INSPECTION PROGRAM EMPLOYEE 16. DATE 

03/30/15 

FSIS FORM 5400-4 DISTRIBUTION: Original & 1 Copy to Establishment, 1 Copy to Inspector 

Inspection Methods 19a-11 
 

 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

Hands-on Activity 

For the first part of this hands-on activity, you (as Robert Barclay) will document 

the results for a Heat Treated, Not Fully Cooked, Not Shelf Stable (HT-NFCNSS) HACCP task because of a “stumble-on” noncompliance. 

Note: “Stumble-on” means the IPP was not verifying the specific regulatory 

requirement as part of an inspection task but happened to observe 

noncompliance. The IPP must record the noncompliance under the appropriate 

inspection task. 

Schedule the Heat Treated, Not Fully Cooked, Not Shelf Stable Directed 

Task to Document Noncompliance 

IPP may need to schedule and perform a routine instance of an inspection task 

“as directed” based on conditions observed in the establishment. For example, 

the IPP may find noncompliance with a regulatory requirement verified under 

particular inspection task while performing a different task or other inspection 

duties. 

1. Log into PHIS as Robert Barclay (#) 

2. Click the Task Calendar option on the navigation menu 

3. Filter on Holland Point Foods in the task list 

4. Type HACCP in the Task Name box 

Note: Entering a word like “Livestock”, “SSOP” or “HACCP” typed

into the filter is enough to narrow the establishment task list. 

5. Click the Filter icon 

6. Click Contains from the pick list 

7. Locate a task named Heat Treated, Not Fully Cooked, Not Shelf 

Stable Task with a start 2/1/2016 and end 2/29/2016 

8. Click the Add link in the Directed column for the Heat Treated, Not 

Fully Cooked, Not Shelf Stable task 

9. Type a “1” in the box for Today’s date in the calendar pop-up 

window 

When IPP perform a directed instance of a routine task, they must enter a reason 

for performing the task as a directed task. 

10.Click the drop down list arrow at bottom of the calendar pop-up 

window, then click To Document Noncompliance for the reason 

11.Click the Save button 

Inspection Methods 19a-12 
 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

Entering Inspection Results for the Heat treated, Not Fully Cooked, Not 

Shelf Stable Directed Task 

Before IPP enter results for an inspection task, they must select a verification 

activity or component (claim the task). PHIS implements this restriction. 

12.Scroll down and Filter on Robert Barclay and Holland Point Foods 

in the task calendar 

13.Scroll down and locate the Heat Treated, Not Fully Cooked, Not 

Shelf Stable HACCP task scheduled for Today on the calendar 

14.Right-click on the task and select Document 

 Right clicking on the task displays the Task Menu 

 The Inspection Results page is displayed when Document is 

selected from the Task menu 

The “Task” tab on the Inspection Results page also has a data field for entering 

the reason for performing the task as a directed task. 

15.Click the Activity tab 

16.Click the Square in upper right corner of the pop box to maximize the 

screen 

17.Click the radio button for the Recordkeeping verification component 

There are five data fields relevant to HACCP verification tasks. The IPP should 

enter the HACCP plan(s), CCPs and any prerequisite programs that were verified 

while performing the HACCP verification task. If noncompliance is found, the 

HACCP plan(s), CCPs and prerequisite programs are listed in blocks 7 and 7a of 

the NR. 

18.Click the drop down list arrow for the HACCP plan, then select 

Smoked Product 

 If the HACCP plan is not in the pick list, then type the name of the 

HACCP plan in the Other HACCP Plan box 

19.Type CCP 2B Stabilization in the Name of HACCP CCP box 

Note: The name of more than one CCP can be typed in the box 

20.Click the Save button 

 The task is now claimed 

 A message at the top of the screen says “inspection result saved” 

successfully 

IPP identify the specific regulations they verified during the performance of each 

inspection task. Highlighted regulations in the list must be verified or marked as 

“not applicable”. Other regulations in the list may be verified.

Inspection Methods 19a-13 
 

 

 

 

 

 

Inspection Verification 

11/6/2019 

21.Click the Regulations tab 

22.Check the mandatory regulations as verified- 417.2(c)4, c(5), c(6) 

and c(7); 417.4(a)2, 417.4(a)(2)(i, ii, and iii); 417.5(a)(1), (a)(2) and 

(a)(3); 417.5(b); and 417.5(c) 

Note: For some inspection tasks, it may take more than one day for 

an IPP to verify all of the mandatory regulations. IPP may enter 

partial results on one day and continue finishing the task by entering 

additional results on subsequent days. Entering the regulations that 

the IPP has verified on a daily basis would very helpful to relief IPP 

or another IPP assigned to the establishment who may end up 

having to complete the inspection task. Recall that an IPP may have 

to reassign the task to himself or herself and complete it when an 

unforeseen issue arises. When the IPP that started the task has 

entered (checked) the regulations that have already been verified for 

the task, it provides a starting point for the IPP that has to finish the 

task. The IPP that is finishing the task does not have to duplicate 

work that has already been done. 

IPP cannot complete the inspection task unless they have verified all 

on the mandatory regulations or marked the mandatory regulation as 

N/A (not applicable). 

23.Check 417.4(a)(3) as also verified 

 Non-mandatory regulations may be verified while performing the 

task 

When IPP find that the establishment did not comply with a regulatory 

requirement, they must document the noncompliance on an NR. To document 

the noncompliance, IPP must enable the Create/Edit NR button in the 

Inspection Results page footer. 

24.Check the Regulatory Non-Compliance box 

Note: Checking the Regulatory Noncompliance box is the only way 

to create a NR in PHIS. 

25.Click Save button 

 The Create/Edit NR button is now enabled 

26.Click the Create/Edit NR button 

 The Noncompliance Page in PHIS is presented 

The Noncompliance page in PHIS has three tabs: General, Noncompliances, and 

Response. The “General” tab is the default view for the Noncompliance Page.

Information found on the General tab includes the date, NR number, and the 

status of the inspection task. The IPP may also associate a Memorandum of 

Inspection Methods 19a-14 
 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

Interview (MOI) and Food Safety Assessment (FSA) with this noncompliance. 

We will demonstrate associating an MOI with an NR in another hands-on 

exercise. 

27.Click the Noncompliances Tab 

 A blank noncompliance grid is displayed 

28.Click Add Noncompliance 

29.Check 417.4 (a)(2)(i) as the noncompliant regulation 

The noncompliance description needs to a clear, concise, and complete. It needs 

to include the exact problem, the time it occurred and its location, and the effect 

on product, if any. The description should clearly explain how the IPP findings 

support the determination that the establishment did not meet regulatory 

requirements. 

30.Type the Description: “Direct observation verification not performed

at the Stabilization CCP at the frequency written in the 

establishment’s plan”

31.Affected Product Information: Type Sliced Bacon 

32.Select Addressed to: Mike Adams 

33.Select Personnel Notified: Diana Popadoupolis 

34.Notice the NC Finalized box but don’t check it yet, click the Save 

button 

35.Click the Cancel button 

36.Click Noncompliances Tab again 

 The noncompliance now appears in the grid 

37.Click the Printer icon 

38.Scroll down and Review the Blocks on the NR that are now 

complete 

The NR number is randomly generated by PHIS. It is alpha numeric with 14 

characters and always ends with the letter “N”. The number that is generated 

does not relate to the establishment, e.g., it does not include the establishment 

number. The number will be followed by a / 1, 2 or 3 to indicate the number of 

pages to the NR. For HACCP verification tasks, the HACCP plan, CCP, and 

prerequisite program name will be listed. This information is generated from the 

information entered on the Activity tab on the Inspection Results page. The 

noncompliant regulation(s) and the verification activity the IPP used to verify the 

regulations are listed. The description that the IPP entered on the 

Noncompliance page appears in block 10. 

39.Click the small X at the top to close the tab or pop-up window that 

has the open NR 

40.Click Edit icon (pencil) to reopen the NR 

Inspection Methods 19a-15 
 

 

 

 

 

Inspection Verification 

11/6/2019 

When the IPP is satisfied with the written NR and ready to give a copy to 

establishment, he or she clicks the “Noncompliance Finalized” box. Once the IPP 

finalizes the noncompliance, the establishment can submit an NR appeal in PHIS 

if the establishment has access to PHIS. 

41.Check the Noncompliance Finalized box on the bottom of the 

Noncompliance page 

42.Click the Save button 

When the noncompliance has been finalized, the save button is disabled which 

means IPP cannot make any additional entries unless they unlock the 

noncompliance. 

43.Click the Cancel button 

44.Click the Noncompliances Tab again 

 Noncompliance status has changed from Open to Finalized 

45.Click the Printer icon again, print the NR, sign it, place copy in the 

government file, and give a copy to establishment management 

 You cannot print the NR during the training session 

46.Click the small X at the top to close the tab or pop up window that 

has the open NR 

IPP finalize each noncompliance and present it to establishment management as 

soon as practical, even if they have not finished the inspection task. Although the 

NRs are stored electronically in PHIS, IPP maintain an “Open” and “Completed” 

NR file in the government office. NRs remain “open” until the IPP verifies that the

establishment is back in compliance with the regulations that resulted in the 

issuance of the NR and has signed and dated block 15 and 16 of the NR. 

If an IPP needs to make a change to a noncompliance that has been finalized, he 

of she must “unlock” it and provide a justification for making the modification.

47. Click Edit icon (pencil) to reopen the NR 

 The following message appears at the top of the page “This 

noncompliance has been finalized. To unlock it click here and 

provide a justification”.

48.Click the Click Here link at the top of the page 

49.Click the drop down list arrow in the justification box and select 

Correcting a Factual Error 

50.Type Entered Wrong Regulation in the Reason to Edit NR box 

51.Click the Unlock button 

52.You entered the wrong regulation, click the “Box” in front of 417.4 

(a)(2)(i) to deselect it 

53.Click the box in front of 417.4 (a)(2)(ii) to select it 

Inspection Methods 19a-16 
 

 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

54.Check the Noncompliance Finalize box on the bottom of the 

Noncompliance page 

55.Click the Save button 

A grid at the bottom of the page lists the justification for modifying the 

noncompliance, the IPP’s name that made the modification, and the date of the

modification. Any additional changes made be the same IPP or another IPP will 

appear in the grid. 

56.Click the Cancel button 

57.Click the Noncompliances tab again 

58.Click the Print icon again, print the updated NR, sign it, place a 

copy in the government file, and give a copy to establishment 

management 

Note: The must give establishment management a copy of the 

updated NR. 

59.Click the small X at the top to close the tab or the pop-up window 

that has the open NR 

60.Click the General tab. 

The IPP would associate the NR with a FSA, if the NR was created due to 

noncompliance found during an FSA. The IPP would associate a MOI with this 

NR if he or she was going to discuss the noncompliance at the weekly meeting. 

Before the IPP can designate the NR as completed, the IPP must verify that the 

establishment has brought itself back into compliance the regulations that led to 

the issuance of the NR. If the NR is not checked completed, the IPP cannot 

complete the inspection task. 

61.Check NR Completed box 

62.Click Save button 

63.Click the Cancel button 

Recall from the lecture portion of this module that the “Findings” tab on the

Inspection Results page has two text areas that IPP may use for recording 

additional findings and comments directly related to performing the task. 

64.Click the Findings tab 

65.Enter comments and findings if needed 

 Specific productionidentification (lot), requirements verified at 

each CCP as they’re verified and prerequisite programs verified, 

etc.

66.Check the Inspection Completed box 

67.Click the Save button 

Inspection Methods 19a-17 
 

 

 

 

 

 

Inspection Verification 

11/6/2019 

Note: When the save button is clicked, the “Inspection Completed” box 

is disabled (grayed out). To make changes to an inspection task that has 

been completed, the IPP will need to “unlock” it, provide a justification, 

modified it, and re-save it. 

68.Click the Close button 

 Notice the task is green indicating that it has been completed 

For the second part of this hands-on activity, you (as Robert Barclay) will 

document the results of a Fully Cooked, Not Shelf Stable HACCP verification 

task with a noncompliance observed and associate the NR with a previous NR. 

Schedule the Fully Cooked, Not Shelf Stable Task 

1. Scroll up and filter on Holland Point Foods in the task list (should be 

selected) 

2. Type HACCP in the Task Name box (may still be filtered for HACCP) 

Note: Entering a word like “Livestock”, “SSOP” or “HACCP” typed

into the filter is enough to narrow the establishment task list. 

3. Click the Filter icon 

4. Click Contains from the pick list 

5. Locate a task named Fully Cooked, Not Shelf Stable Task with a 

start 2/1/2016 and end 2/29/2016 

6. Click the Add link in the routine column for the Fully Cooked, Not 

Shelf Stable task 

7. Type a “1” in the box for Today’s date in the calendar pop-up 

window 

8. Click the Save button 

Before IPP enter results for an inspection task, they must select a verification 

activity or component (claim the task). PHIS implements this restriction. 

9. Scroll down and Filter on Robert Barclay and Holland Point Foods 

in the task calendar (may already be filtered on Barclay and Holland 

Point Foods) 

10.Scroll down and locate the Fully Cooked, Not Shelf Stable task 

scheduled for Today on the calendar 

11.Right-click on the task and select Document 

 Right clicking on the task displays the Task Menu 

 The Inspection Results page is displayed when Document is 

selected from the Task menu 

12.Click the Activity tab 

13.Click the Square in upper right corner of the pop box to maximize the 

screen 

Inspection Methods 19a-18 
 

 

 

 

 

 

Inspection Verification 

11/6/2019 

14.Click the radio button for Both verification components 

There are five data fields relevant to HACCP verification tasks. The IPP should 

enter the HACCP plan(s), CCPs and any prerequisite programs that were verified 

while performing the HACCP verification task. If noncompliance is found, the 

HACCP plan(s), CCPs and prerequisite programs are listed in blocks 7 and 7a of 

the NR. 

15.Click the drop down list arrow for the HACCP plan, then select Deli 

Meat HACCP Plan 

 If the HACCP plan is not in the pick list, then type the name of the 

HACCP plan in the Other HACCP Plan box 

16.Type CCP 1B Cooking, CCP 2B Chilling, and CCP 3B Packaging 

in the Name of HACCP CCP box 

Note: The name of more than one CCP can be typed in the box 

17.Click the “Save” button 

 The task is now claimed 

 A message at the top of the screen says “inspection result saved” 

successfully 

IPP identify the specific regulations they verified during the performance of each 

inspection task. Highlighted regulations in the list must be verified or marked as 

“not applicable”. Other regulations in the list may be verified.

18.Click the Regulations tab 

19.Select the mandatory regulations that were verified today, including 

417.2(c)4, (c)(5), (c)(6) and (c)(7); 417.4 (a)(2)(i), (ii) and (iii); 

417.5(a)(1), (a)(2) and a(3), 417.5(b); and 417.5(c) 

There are several mandatory regulations for the HACCP verification tasks. Since 

IPP have to verify these requirements at all CCPs, the task will most likely take 

more than a day to complete. IPP may enter partial results for the task. When 

they find noncompliance before verifying all the mandatory regulations, they 

document it in PHIS and give the NR to establishment management as soon as 

practical. Refer to the example on page 38. When IPP find noncompliance, they 

are to document it on an electronically generated NR in PHIS. 

20.Check the Regulatory Noncompliance box 

 This enables the Create/Edit NR button 

21.Click Findings tab 

22.Enter the following information in the Comments box 

 Oven Roasted Chicken Breast lot #A02042016 

 Verified the HACCP requirements at both CCPs 

Inspection Methods 19a-19 
 

 

 

 

 

 

Inspection Verification 

11/6/2019 

 Verified implementation of the Allergen program 

 Need to verify that the establishment is back in compliance 

 Pre-shipment review needs to be verified 

23.Click the Save button 

24.Click the Create/Edit NR button 

25.Click on the Noncompliances tab 

26.Click on Add Noncompliance 

27.Check 417.5(a)(3) and 417.5(b) as the noncompliant regulations 

28.For the Noncompliance Description, Type: 

 At approximately 10:00 am, on 2/8/2016, while performing a fully 

cooked, not shelf stable HACCP task, I reviewed the establishment’s 

cooking record and noticed that the establishment monitor did not 

enter a time for one of the monitoring activities. I notified Chick 

Moreno, QC Tech., of the failure to record the time. 

29.Type Oven Roasted Chicken Breast in the “Affected Product

Information” box 

30.Select Mike Adams for “Addressed To” name

31.Select Personnel Notified: Chick Moreno 

32.Click the Save button to create the Noncompliance (within the NR 

record) 

33.Click the Cancel button to return to the General Tab of the NR page 

34.Click on the Noncompliances tab 

 The record keeping noncompliance appears in the grid 

35.Click the Edit icon (pencil) to reopen the recordkeeping 

noncompliance record 

36.Scroll down and check the Noncompliance Finalized box 

37.Click Save button 

38.Click Cancel button 

39.Click the on the Noncompliances tab again 

40.Click on Add Noncompliance 

41.Check 417.2(c)(4) as the noncompliant regulation 

42.For the Noncompliance Description, Type: 

 At approximately 1:00 pm, on 2/8/2016, while performing the fully 

cooked not shelf stable HACCP task, I reviewed yesterday’s chilling

record and noticed that the establishment only monitored the chilling 

CCP once in the morning and once in the afternoon. The HACCP 

plan states the monitoring activity is to be conducted every 2 hours. I 

notified Mary White, QC Tech., of the failure to monitor the CCP at 

the frequency stated in the HACCP plan. 

43.Type Oven Roasted Chicken Breast in the “Affected Product

Information” box

Inspection Methods 19a-20 
 

 

 

 

 

 

Inspection Verification 

11/6/2019 

44.Select Mike Adams for “Addressed To” name

The QC technician’s name (Mary White) in not on the personnel notified pick-list. 

45.Type Mary in the first name box and White, QC Tech in the last 

name box 

46.Click the Add button 

The IPP should add Mary White as contact in the establishment profile otherwise 

he or she will have to manually type her name in the boxes each time she is 

notified of a noncompliance. After adding her as a contact, her name will appear 

in the pick-list. 

47.Click the Save button to create the Noncompliance (within the NR 

record) 

48.Click the Cancel button to return to the General Tab of the NR page 

49.Click on the Noncompliances tab again 

 The monitoring noncompliance appears in the grid 

 Notice the NR number is the same but it has a “/ 2”

Associating NRs 

IPP are to associate NRs when they indicate an on-going trend of same cause 

noncompliances or systemic problems with the establishment’s food safety

system. 

50.Click the Link icon (red arrow) for the monitoring (open) 

noncompliance 

51.Click Maintain Associations 

 No associated NRs appear in the grid 

There are several filters that can be used on the Noncompliance Association 

page. The IPP may filter by “Any or All”, specify the NR date range, look for NRs 

that cite the exact same regulations, or NRs created for the same inspection 

task. IPP should be careful with their search criteria and the “Any or All” filter. If 

the IPP gets zero hits on the search, he or she can loosen his or her criteria and 

re-filter. 

To ensure the IPP has the right NR to associate, the IPP may need to review the 

NRs issued to the establishment by clicking the Printer icon for each NR. After 

reviewing the recent NRs, the IPP can select the correct NR from the list to 

complete the association. 

52.Check the Box next to the NR dated 2/2/2016 

53.Click the Save button to create the association 

 The associated NR now appears in the maintain associations grid 

Inspection Methods 19a-21 
 

 

 

Inspection Verification 

11/6/2019 

54.Click the Back button to return to the General Tab on the 

Noncompliance Page 

55.Click on the Noncompliances tab 

56.Click the Edit icon (pencil) to reopen the noncompliance record 

Recall that the purpose of associating NRs is to document the establishment’s 

unwillingness or inability to implement further planned actions or preventive 

measures to prevent the same cause noncompliance. In other words, the further 

planned actions or preventive measures the establishment takes is not bringing it 

back into compliance with the regulations. This documentation assists the 

Agency in taking additional enforcement actions against the establishment. The 

establishment must be given its “due process” rights.

57.Type the language for a developing trend in noncompliance in the 

description: 

 A similar noncompliance was documented on NR 0003023015296N, 

dated 2/2/2016. Counseling the monitor about conducting the 

monitoring activity at the frequency stated in the HACCP plan and 

having the HACCP coordinator review the monitoring record twice a 

day for 3 days did not prevent recurrence of the noncompliance. 

58.Click the Save button to update the Noncompliance within the NR 

record 

59.Click the Cancel button to return to the General Tab of the 

Noncompliance Record page 

60.Click on the Noncompliances tab again 

61.Click on the Printer icon for the noncompliance to view the NR 

(FSIS Form 5400-4) available for printing or saving as an electronic 

document 

62.Review the NR, note the associated NR number in Block 6a and the 

updated trend language in block 10 

63.Click the small X at the top to close the tab or the pop-up window 

that has the open NR 

64.Click the Edit icon (pencil) to reopen the noncompliance record 

When the IPP is satisfied with the written NR and ready to give a copy to 

establishment, he or she clicks the “Noncompliance Finalized” box. 

65.Scroll down and check the Noncompliance Finalized box 

66.Click Save button 

67.Click Cancel button 

68.Click on the Noncompliances tab 

 NR Status changed to Finalized 

Inspection Methods 19a-22 
 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

After adding the language for a trend in noncompliance to the NR text, 

associating this NR to the previous NR, and finalizing the noncompliance, the 

IPP needs to print the NR and give a copy to establishment management. 

69.In the establishment, you would now print the NR, sign it, place a 

copy in the government file and provide a copy to the establishment 

70.Click Cancel button 

71.Click the Close button 

72.Sign out of PHIS by clicking the Red X in the top right corner of the 

screen 

We are done, for now, with the NR documentation for this task and will now 

discuss the weekly meeting requirements, creating meeting agendas, and 

creating Memorandum of Interviews (MOIs). We will return to this NR and 

Inspection Results after we create some HACCP inspection notes, a meeting 

agenda, and a MOI. After that we will then pretend we held a weekly meeting 

with the establishment. After documenting that meeting and establishment 

management responses to our inspection issues and this NR, we will come back 

and document and complete the NR and Inspection Result for the Fully Cooked, 

Not Shelf Stable task. 

PHIS Features IPP Use to Document Meetings between IPP and 

Establishment Management 

PHIS has several time-saving features that IPP use to document the mandatory 

meetings that they have with establishment management. These features enable 

IPP to work efficiently. First of all, there is a meeting agenda tool for recording 

the topics to be discussed at the meeting. Secondly, there is an inspection notes 

tool to record IPP concerns that do not rise to the level of noncompliance but still 

need to be discussed with establishment management. The inspection notes can 

be easily transferred to the meeting agenda. Lastly, the Memorandum of 

Interview (MOI) tool creates the official record of the discussion between IPP and 

establishment management at each meeting. 

Entrance Meetings 

Upon rotation into an assignment, or when IPP are newly assigned to an 

establishment, they are to review the establishment’s history, which is reflected in

the establishment’s homepage in PHIS. They are to consult with their 

immediate supervisor if they have questions or concerns about the 

establishment’s history. IPP need to review the following elements of the 

establishment’s history. 

Inspection Methods 19a-23 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

1. PHIS records of recent noncompliances including any immediate and further 

planned action that the establishment may have provided to address the 

noncompliances; 

2. Recent inspection notes and MOIs; 

3. The results of any recent or ongoing FSIS verification sampling activities from 

the establishment’s homepage; 

4. The results from the most recent Food Safety Assessment(s) conducted at 

the establishment; and 

5. If any enforcement action has been deferred, or if a suspension has been 

held in abeyance at the establishment. In addition, they need to familiarize 

themselves with the Agency’s expectations, as described in the verification

plan, and the results of the Agency’s findings from verifying the effectiveness 

of the corrective and preventive measures that were proffered by the 

establishment. Finally, IPP are also to become familiar with the conditions 

that led the Agency to bring the enforcement action that has been deferred or 

resulted in the suspension that is in abeyance. 

In addition to becoming familiar with the establishment’s history, when IPP rotate 

into an assignment or conduct an inspection at an establishment for the first time, 

they are to review the: 

1. establishment’s Sanitation SOPs, HACCP plan, and prerequisite programs; 

and 

2. establishment profile in PHIS to become familiar with the information in the 

profile. As IPP become familiar with the establishment operations, they are to 

update the PHIS establishment profile as needed. 

After IPP familiarize themselves with establishment’s history, HACCP plans, and

programs, they are to conduct an entrance meeting (e.g., the first weekly 

meeting) with the establishment management. At this meeting, IPP should 

inquire about the specific operations of the establishment and seek to answer 

any questions that came up during their review of the establishment’s history or 

programs. IPP are to ask establishment management about the location of the 

applicable records and the protocol for FSIS personnel to access and review the 

records. Establishments are required to provide access to records needed by IPP 

to perform their duties. However, IPP must review the necessary records in the 

location specified by establishment management. IPP are not to maintain any 

copies of the establishment’s written programs or data from such programs in the

inspection office. Likewise, IPP are to ask about any previously agreed upon 

notification (e.g., when IPP need to inform the establishment they will be 

collecting a sample) when Agency sampling is performed at the establishment. 

Inspection Methods 19a-24 
 

 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

IPP need to know this information so that an establishment can properly control 

sampled product pending FSIS test results. 

IPP take notes at the entrance meeting and document the notes in a MOI in 

PHIS and provide a copy of the MOI to the establishment. 

Awareness Meetings 

When new regulations, policies, performance standards, compliance guidelines, 

or product sampling protocols are published in a Federal Register Notice, FSIS 

provides information, guidance and instructions to IPP for verifying the new policy 

or implementing the new performance standards or implementing the new 

sampling protocol through either a FSIS Directive or FSIS Notice. The directive 

or notice often directs IPP to conduct an awareness meeting with establishment 

management upon receipt of notice or directive. The notice or directive identifies 

specific information that IPP are to share with establishment management at the 

meeting. 

IPP take notes at the awareness meeting and document the notes in a MOI 

in PHIS and provide a copy of the MOI to the establishment. 

Weekly Meetings and Agenda Items 

As set out in FSIS Directive 5000.1, IPP are to have weekly meetings with 

establishment management. IPP are to use the tools in PHIS to record 

inspection notes, create meeting agendas, document MOIs, and record the 

performance of weekly meeting tasks. The performance of the weekly meeting 

AND other meetings is documented in PHIS under the “Meeting with

Establishment Management” task. 

The purpose of the weekly meeting is to provide an opportunity for IPP to 

address matters that affect the establishment’s on-going compliance with FSIS 

requirements. The discussion of issues during the weekly meeting is not intended 

to replace documentation of noncompliance on an NR. Moreover, the fact that 

an issue is not discussed at the weekly meeting does not mean that the issue 

could not become the subject of an NR. 

Meetings should benefit both IPP and the establishment. For instance, it is 

important that IPP discuss topics pertinent to the establishment’s food safety

system that could affect public health. IPP are not precluded from asking 

establishments about any subject of regulatory concern, e.g. recalls, allergen 

control, etc. Establishment management may wish to share information regarding 

their operations, such as facility improvements and changes to their food safety 

systems, or express concerns at the meetings. 

Inspection Methods 19a-25 
 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

A wide variety of topics can be discussed at the meetings, including individual 

noncompliances, developing trends of noncompliance, and findings by IPP that 

do not represent regulatory noncompliance but that need to be brought to the 

attention of the establishment. For example, discussion of information from 

external sources, such as customer or consumer complaints, can provide 

information to alert establishment management about a safety risk or about other 

information that is relevant to the establishment’s food safety system. 

******************************************************************************************** 

Note: FSIS Directive 5000.1 requires IPP to discuss developing trends in 

noncompliance at the weekly meetings and document the discussion of 

noncompliance trends and the associated NRs in an MOI. IPP are to discuss any 

identified associations between current and past noncompliances, and describe 

to establishment management why the associated NRs indicate a trend of 

noncompliance. It is recommended that IPP explain that continued 

noncompliance may result in further enforcement actions, to help the 

establishment understand the consequences of continued noncompliance. 

******************************************************************************************** 

FSIS Directive 5010.1 provides a general list of food safety related topics that 

IPP may consider discussing with the establishment during weekly meetings. 

Given the range of the issues confronting FSIS-regulated establishments, it may 

be difficult to discuss all of the topics that either FSIS or the establishment 

wishes to address during any one weekly meeting. Similarly, IPP should not use 

the list of topics in FSIS Directive 5010.1 like check list nor should they attempt to 

discuss all topics listed during a given period of time. The topics in the directive 

should be discussed as they arise. The list below is not all-inclusive. Possible 

topics for discussion listed in FSIS Directive 5010.1 include: 

1. in-plant observations, e.g., individual NRs, less than perfect conditions that 

may, if not addressed, become noncompliances, and humane 

handling/poultry good commercial practices issues; 

2. issues and information that the establishment wishes to share; 

3. agency issuances, e.g., FSIS notices and directives and askFSIS questions; 

4. information regarding FSIS sampling; 

5. information related to the establishment’s food safety system, e.g., changes 

to prerequisite programs used to support food safety decisions; 

6. information from external sources, e.g., consumer complaints and recalls; and 

7. any inspection related activities occurring outside of approved hours of 

operation. 

Inspection Methods 19a-26 
 

 

 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

On a periodic basis, about once a month as scheduled using the PHIS “Update 

Establishment Profile” task, IPP are to ask establishment management at the 

weekly meeting whether it has made any changes in the production process or 

other changes that could affect the safety of the product. If IPP learn that 

establishment management has made a change in its process, based on the 

nature of the change, IPP are to perform the appropriate verification activities 

outlined in FSIS Directives 5000.1 and 5000.6. If IPP are unsure how to proceed, 

they are to contact their supervisor for guidance. 

Before the weekly meeting with the establishment, IPP may use the meeting 

agenda tool in PHIS to create an outline of the topics to be discussed. The 

topics discussed at the weekly meeting are dependent upon the events or 

conditions that occur in the establishment each week. The meeting agenda may 

be printed and distributed to IPP who will attend the meeting. IPP are to share a 

copy of the meeting agenda with establishment management when requested. 

PHIS will enable IPP to link the meeting agenda to an MOI to create an 

establishment meeting MOI. 

When an establishment has multiple inspection shifts and/or multiple assigned 

IPP, it is the Inspector-in-Charge’s (IIC) duty and responsibility to conduct and 

document weekly meetings. The IIC: 

 ensures that regulatory concerns that arise on all shifts are discussed at 

the weekly meetings, 

 may delegate conducting the meeting to IPP, 

 may include IPP (CSIs or FIs) in the meeting with establishment 

management; 

 signs all documentation, and 

 ensures that all IPP on all establishment shifts are made aware of 

regulatory concerns that are discussed at weekly meetings. 

When the IIC designates an FSIS employee to conduct the weekly meeting, it 

does not mean that IIC never conducts the weekly meeting or attends the 

weekly meeting. Depending upon the events occurring (e.g., a product recall, 

positive pathogen result, humane handing issues or an inadequate HACCP 

system) or conditions observed (e.g., trends in noncompliance) in the 

establishment, it may be appropriate for the IIC, or even the FLS, to conduct the 

weekly meeting or at least be in attendance to assist and support IPP. 

As set out in FSIS Directive 5000.1, IPP are to take notes at the weekly 

meetings and are to document the notes in a MOI in PHIS. IPP are to 

provide establishment management with a copy of the MOI. 

******************************************************************************************** 

Inspection Methods 19a-27 
 

 

 

Inspection Verification 

11/6/2019 

Note: If IPP do not conduct a weekly meeting, they are to document this fact and 

the reason why in an MOI. For example, if establishment management chooses 

not to attend the weekly meeting, IPP are to document this in an MOI. If IPP 

cannot conduct the meeting due to the performance of higher priority tasks, such 

as sampling, IPP are to document this in an MOI. 

For Cause Meetings 

As needed, IPP can schedule a meeting with establishment management to 

discuss urgent issues such as a positive pathogen result, recall, outbreak, or 

inhumane handling incident. 

IPP take notes at the meeting, document in a MOI in PHIS, and provide a 

copy of the MOI to the establishment. 

******************************************************************************************** 

Memorandum of Interview (MOIs) 

FSIS Directives 5000.1 and 5010.1 and several notices instruct IPP to meet with 

establishment management and document the outcome of the meeting in an 

MOI. An MOI is used to record and convey discussions with establishment 

or facility management. The MOI is the written summary of an interview. It 

should not be a verbatim recitation of the interview, nor does it necessarily have 

to be written in the same order as the interview was conducted. Instead, it 

includes the date of the meeting, who was at the meeting, and captures and 

summarizes critical, relevant information including the specific topics discussed 

and answers to any questions asked during the meeting. 

******************************************************************************************** 

Note: IPP are not to use the MOI as a means to document daily conversations 

with establishment employees. 

******************************************************************************************** 

IPP can create and document the following MOIs in PHIS: 

 Establishment Meeting 

 Standard, 

 Domestic Food Defense, and 

 Import Food Defense 

Inspection Methods 19a-28 
 

 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

An MOI is a very important inspection tool for IPP because it documents the fact 

that IPP maintain open lines of communication with official establishments. For 

instance, after the weekly meeting, IPP are to prepare either an establishment 

meeting MOI or a standard MOI in PHIS to document the agenda items covered 

in the meeting and document any establishment responses. IPP are to 

document any discussion of noncompliance trends and NR associations at the 

weekly meeting in the MOI. Open NRs and NRs under appeal may be linked to 

an establishment meeting MOI or a standard MOI in PHIS. 

An MOI can also document a variety of other issues including, but not limited to 

the: 

 Discussion of a new inspection policy transmitted through a FSIS notice 

(e.g., a directed awareness meeting), 

 Performance of records review in accordance with FSIS Directive 5000.2, 

and 

 Performance of specific verification activities (e.g., supplier tracking 

information and humane handling) as deemed necessary by FSIS. 

If establishment management provides no response to issues/concerns, this fact 

should be recorded in the MOI. 

IPP are to maintain a copy of the MOI in the official government file and must 

provide a copy of the MOI to the establishment. When the MOI is provided to the 

establishment or facility, it is designated as “finalized” in PHIS.

MOIs can be used to track the establishment’s history of responding to

issues/conditions in the establishment that are not noncompliance but can lead to 

noncompliance if conditions worsen or if the establishment doesn’t act upon the

information the IPP has given the establishment, e.g., less than perfect execution 

of prerequisite program. If the situation has been documented in a MOI on 

numerous occasions, it would be hard for the establishment to say it didn’t know

the issue/condition could lead to noncompliance when it finally results in 

noncompliance documented on an NR. The following example will demonstrate 

this concept. 

MOI Example: An establishment has concluded in its hazard analysis that the 

growth of pathogens is not likely to occur in its raw ground process because it 

implements a temperature control program. During the week the CSI found that 

the establishment missed a product temperature measurement as outlined in its 

temperature control program. The CSI realizes that one missed product 

temperature check is usually not enough evidence to conclude that the 

establishment does not have the documentation/records to support that the 

hazard is not reasonably likely to occur in the process. However, the CSI has 

found the same problem with temperature control program 6 times this month 

prior to the current finding, has discussed the failure to measure the product 

Inspection Methods 19a-29 
 

 

 

 

 

Inspection Verification 

11/6/2019 

temperature at the weekly meeting, and documented the establishment’s 

response in a MOI. Hence, the CSI concludes that the establishment is not 

executing the program as written and does not have documentation/records to 

support that the hazard is not reasonably likely to occur in the process, i.e., the 

establishment cannot support the decision in its hazard analysis, and there is 

noncompliance with 417.5(a)(1). By including the less than perfect execution of 

the prerequisite program in the weekly meeting and documenting it in an MOI, 

the CSI has given the establishment its due process. “Less than perfect 

conditions” documented in the MOIs can be referenced later in the NRs to 

support findings of noncompliance. 

Note: The determination that an establishment no longer has support for the 

decision made in the hazard analysis is not dependent upon a specific number of 

occurrences of failing to implement the prerequisite program. In this example, 

seven occurrences were used to represent the establishment’s failure to execute

its prerequisite program and maintain records that continue to support the 

decision it made in the hazard analysis. 

If IPP need assistance in determining whether or not the implementation of 

a prerequisite program and the records continue to support the decision 

that hazard is not reasonably likely to occur in its process, they should 

seek assistance through their supervisor. 

If an establishment objects to any part of the MOI, IPP are to document the 

objection at the end of, or as an attachment to, the MOI. If the establishment's 

objection is in writing, IPP are to attach the written objection to the MOI. When 

the establishment’s written objection is transmitted electronically, e.g., e-mail or 

other file format, IPP can upload the file in PHIS and save the document as an 

attachment to the MOI record. IPP provide a copy of the amended MOI to the 

establishment. MOIs can be reviewed by the Frontline Supervisor. 

Tips for Writing MOIs 

 Write the MOI as soon as possible after conducting the meeting. “Cold notes” 

are difficult to understand. 

 Document who attended the meeting, the topics that were discussed, and 

what was said at the meeting. Document only the facts and not any opinions. 

 Use quotations only when directly quoting a person. 

Example: Mr. Adams said, “I told Ms. Popadoupolis, the Food Safety 

Manager, that the SSOP and HACCP records need to be available to the 

second shift inspector. “ Ms. Popadoupolis said she would take care of it.” 

Inspection Methods 19a-30 
 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

 Paraphrasing is generally a safer way of relating what someonesaid since it is 

difficult to capture the verbatim account when a person is speaking quickly. 

 When paraphrasing, use words like “said” and “stated” to maintain a neutral 

tone. 

Example: Mr. Adams stated that Mr. Wallace, the Maintenance Manager, is 

waiting for a quote to repair a large section of epoxy flooring outside the 

smokehouses and rack wash area. 

 Do not use “claimed” as a synonym for “said” because this verb has an

undertone of blame and mistrust. 

Example: Mr. Wilson claimed he was not present during pre-operational 

sanitation inspection. (This sounds as though we do not believe him.) 

 When discussing several people of the same gender, restate the name to 

prevent confusion. 

Example: Mr. Irvine said that he told his Quality Assurance Manager that not 

making the SSOP and HACCP records available to the second shift inspector 

was a violation of the USDA regulations and that he will develop a method of 

making them available. (Who will develop a method of making the records 

available? Mr. Irvine or the Quality Assurance Manager?) 

 Use the first person for your observations. 

Example: I asked Mr. Irvine to tell me which office he contacted within the 

FSIS. 

 Use the third person to relate information about the interviewee. 

Example: Ms. Jones said she was the acting HACCP Coordinator of the 

establishment during the Food Safety Assessment. 

Hands-on Activity 

The following hands-on section is intended to provide familiarity and experience 

with the Inspection Notes, Meeting Agenda and MOI pages that are accessed 

from the Inspection Verification left navigation menu. The inspection notes, 

meeting agenda, and MOI process we will demonstrate support the weekly 

meeting. 

For this hands-on activity, you (Robert Barclay) will: 

 Create a few more inspection notes, 

Inspection Methods 19a-31 
 

 

 

 

 

 

Inspection Verification 

11/6/2019 

 Create a meeting agenda, 

 Create a MOI, and 

 Complete the Fully Cooked, Not Shelf Stable task you started 

Creating Inspection Notes 

The PHIS inspection notes feature is designed to be helpful to IPP in several 

ways: First of all, inspection notes help foster communication between IPP 

assigned to the establishment across days and shifts. Secondly, they provide a 

way to capture inspection findings that do not rise to the level of noncompliance 

but still need to be discussed with establishment management. Lastly, PHIS 

provides a mechanism for easily transferring these notes into a meeting agenda 

for the weekly meeting and MOIs. 

1. Log into PHIS as Robert Barclay ( your #) 

2. Click the Down Arrow next to Inspection Verification in the left 

navigation menu 

3. Click Select Establishment from the sub menu 

4. Click the radio button to select Holland Point Foods 

5. Click on Inspection Notes in the left navigation menu 

 The Inspector Notes List page and grid is displayed 

6. Click the Create Note button 

7. Check the Enable Auto Save box and select the “autosave content”

for every 20 minutes 

8. Populate data: 

 Today’s date (change if needed) 

 First shift radio button selected 

 Select Processing as the category 

9. In the text box Type: “A cooler temperature check was not performed 

as written in the cooler temperature prerequisite program”

Note: A single missed activity (critical parameter measurement) for a 

prerequisite program usually does not result in a noncompliance 

determination. However, it is an issue that needs to be discussed 

with establishment management at a weekly meeting and 

documented in an MOI. The establishment’s continued failure to 

implement the program may eventually lead to a noncompliance 

determination. Verifying prerequisite programs with be discussed in 

the HACCP training modules. 

10.Click the Save button and the Cancel button 

Inspection Methods 19a-32 
 

 

 

 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

11.Create and save an additional note with Today’s date; select 

Processing as the category 

 I noticed the HACCP plan has been recently signed and dated, but I 

didn’t observe any modifications

12.Create and save an additional note with Today’s date; select 

Processing as the category 

 Noncompliance on two NRs was associated because it is from the 

same cause: failure to monitor at the frequency stated in the HACCP 

plan 

Note: IPP are required to document the identified trend in 

noncompliance in the inspection notes feature of PHIS for 

discussion at the next meeting with establishment management. 

Creating a Meeting Agenda 

FSIS Directive 5000.1 requires IPP to conduct entrance meeting and weekly 

meetings with establishment management. Some FSIS Notices require IPP to 

conduct an awareness meeting with establishment. Conditions in the 

establishment and some inspection findings may require IPP to have non-routine 

meeting with establishment management, e.g., a positive pathogen or positive 

residue sample result, humane handling issues, or a recall. These are often 

referred to as for cause meetings. A wide variety of topics can be discussed at 

the meetings, including individual noncompliances, developing trends of 

noncompliance, and findings by IPP that do not represent regulatory 

noncompliance but need to be brought to the attention of the establishment. IPP 

can use the meeting agenda tool in PHIS to create an agenda for the meeting. 

13.Click on Meeting Agendas in the left navigation menu 

 The Agenda List page and grid are displayed 

14.Click the Create Agenda button 

15. Check the Enable Auto Save box and select the “autosave content”

for every 20 minutes 

The Agenda page is displayed which has 4 tabs. The default view for this page is 

the “Meeting” tab. The meeting date, meeting subject and attendees are 

mandatory information (red asterisk) that the IPP must enter on this tab. The IPP 

should also enter the meeting start time but this is not mandatory. The attendee 

names on the pick-list come from the contact names in the establishment profile. 

To select a meeting attendee name, IPP click (highlight) the person’s name on

the pick-list. To select multiple meeting attendee names from the pick-list, IPP 

hold down the “control” key on the computer key board and click the person’s 

Inspection Methods 19a-33 
 

 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

name. Meeting attendee names not on the pick-list can be added by typing in the 

person’s name and clicking the “Add” button. 

The default meeting subject is “Establishment Awareness Meeting” but the IPP 

can manually change the subject title to: 

 Reflect specific concerns like an E. coli O157: H7 Positive Sample 

Result/Positive Residue Result/Recall. 

 Establishment Weekly Meeting or Entrance Meeting (when the IPP is 

newly assigned to the establishment) 

Awareness meetings are conducted to inform industry of new FSIS regulations, 

policy, compliance guidelines and sampling protocols. 

16.Populate data: 

 Meeting Date: Today’s

 Start Time: 1:00 p.m. 

 Change Subject: Type: Establishment Weekly Meeting Agenda 

 Attendees: Select Mike Adams hold down the control key and select 

Diana Popadoupolis 

 Type Dr. James in the first name box and Davis, FLS in the last 

name box 

 Click the Add button to add the FLS 

The PHIS agenda feature lets IPP select inspector notes and import those notes 

into a meeting agenda. This allows IPP to include appropriate entries from the 

PHIS inspector notes feature into a draft agenda in preparation for the weekly 

meeting. Some inspector notes may be memory joggers for the IPP or just to 

convey information to IPP assigned to the same establishment that may not need 

to be a discussion item at the weekly meeting with the establishment. When 

there are no inspection notes that need to be discussed at the weekly meeting, 

IPP will use the Agenda tab to add discussion topics to the meeting agenda. 

17.Click on Comment List tab 

18.Enter from February 1 to February 29 for the Date Range and click 

the Filter button 

19.You can check the box for one or more notes, but for the exercise 

click the Check All button 

20.Click the Send Comments to Agenda Tab button 

Inspection notes are placed in the agenda “as is” and may need some editing 

and additions such as introduction and conclusion text before completing the 

meeting agenda. 

Inspection Methods 19a-34 
 

 

 

 

 

 

Inspection Verification 

11/6/2019 

21.Edit Inspector Notes into agenda items, as desired, e.g., change NR 

association note to: 

 Discuss developing trend in monitoring noncompliance and the two 

NRs issued in the past week 

22.Add a sentence to HACCP plan modification note: 

 Ask establishment what modifications were made to the HACCP plan 

IPP may add additional topics to the agenda that they did not enter in as 

inspector notes that they feel need to be discussed at the weekly meeting. 

23.Add additional topics, e.g., 

 Discuss the training requirement for the person that modified the 

HACCP plan 

 Ask if the person that modified the plan successfully completed a 

course or training in the seven principles of HACCP that included 

a segment on the development of a HACCP plan and records 

review 

If the IPP feels that a particular noncompliance on an open NR needs to be 

discussed with establishment management at the weekly meeting, IPP should 

associate the open NR with the meeting agenda. 

24.Click the NR tab 

25.Select the Open NR that identified the trend in monitoring 

noncompliance 

26.To be sure you have selected the correct open NR, click the View 

NR button 

27.Review the Noncompliance Description 

28.Click the small X at the top to close the tab or the pop-up window 

that has the open NR 

29.Click the Save button to create the meeting agenda 

30.Click the Cancel button 

31.Click the Printer icon for the weekly meeting agenda you created 

32.Right click anywhere on the meeting agenda and select print in the

pop up menu or click the printer icon at the bottom of the computer 

screen. Use the tools icon (sprocket) in the upper right corner to save 

it to your computer desktop (file, save as, file name, and save). 

 The IPP should take the agenda to the meeting. He or she may 

distribute a copy to other IPP participants. IPP must share a copy 

of the meeting agenda with establishment management when 

Inspection Methods 19a-35 
 

 

 

 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

requested prior to the meeting. This will let the participants know 

what topics are going to be discussed at the meeting. 

33.Click the small X at the top to close the tab or the pop-up window 

that has the open Agenda 

Conduct the Meeting 

Now that the IPP has created the establishment meeting Agenda, he or she 

would log off of PHIS and conduct the meeting. IPP use the Agenda to assist in 

the organization and focus of the meeting. IPP are required to take notes and 

document the outcome of the meetings they have with establishment 

management. An MOI is used to record and convey IPP discussions with 

establishment or facility management. 

Creating an Establishment Meeting MOI from the Agenda 

After the meeting, IPP document the outcome of the meeting on the MOI. IPP 

should include the establishment’s response to regulatory and non-regulatory 

concerns discussed at the meeting. 

34.Click on Meeting Agendas from the left navigation menu (but we 

should already be at the Agenda list page) 

35.From the Agenda List, locate the meeting agenda you just created 

and click on the MOI icon (red arrow) 

36.Click the Enable Auto Save box and select the “autosave content”

for every 20 minutes 

The Establishment Meeting MOI page is displayed which has 4 tabs: Meeting, 

Agenda, NR and Response. The default view for this page is the “Meeting” tab. 

The mandatory information (red asterisk), i.e., the meeting date, meeting start 

time, meeting subject, and attendees, is pre-populated in the fields with same 

information the IPP entered on the Agenda page. 

The Response tab on the MOI Meeting page may be used by establishment 

management to record comments/responses to the topics discussed at the 

meeting in PHIS when the establishment has a Plant Manager role 

(eauthentication) in PHIS. PHIS will automatically add their comments, any 

rebuttals, or additional information to the finalized MOI. IPP are not to add 

establishment responses using the Response Tab. This tab is reserved for an 

establishment that has a Plant Manager role in PHIS and wants to respond to a 

finalized MOI. If the establishment does not have a Plant Manager role but 

chooses to respond electronically, e.g., e-mail or other file format, to meeting 

issues there is “Add Attachment” link at the bottom of the Agenda tab of the 

Establishment Meeting MOI page to upload the file. 

Inspection Methods 19a-36 
 

 

 

 

 

 

Inspection Verification 

11/6/2019 

Note: If the IPP creates an MOI using the left navigation menu rather than 

through the Agenda List page, there is not an “Add Attachment” link for 

uploading electronic documents. 

If the establishment does not provide a response to a discussion topic that 

requires a response, IPP are to document the establishment’s failure to respond

in the MOI. If the establishment objects to any part of the MOI with a 

handwritten response (or other hardcopy), IPP are to attach the handwritten 

objection to the MOI hardcopy in the government file. IPP are not to transcribe 

the establishment’s written response into PHIS. When the establishment’s written

objection is transmitted electronically, e.g., e-mail or other file format, IPP can 

upload the file in PHIS and save the document as an attachment to the MOI 

record using the “Add Attachment” link at the bottom of the Agenda tab of the

Establishment Meeting MOI page. 

37.From the Meeting tab, update any information that changed from the 

agenda, e.g., attendee names, date, or time 

38.Click on the Agenda tab 

39.Edit the text to create a record of the meeting from the agenda topics, 

e.g., add the following to the developing trend in monitoring 

noncompliance: 

 Mr. Adams said both incidents will be immediately investigated to 

determine why monitoring is not being performed at the required 

frequency. A QC tech will review monitoring records twice a day for a 

week. 

40.Add the following to the developing trend in monitoring 

noncompliance: 

 I informed Mr. Adams that continued failure to meet these regulatory 

requirements may result in additional regulatory or administrative 

action. 

Note: When there is a trend in noncompliance occurring in the 

establishment, IPP are required to include this statement in the MOI. 

This statement is another means of providing the establishment due 

process. 

41. Click the Save button to create the Establishment Meeting Minutes 

MOI 

42. Click the Cancel button 

43. To view a formatted copy of the Establishment Meeting MOI, locate 

the establishment meeting minutes MOI you created 

 By Date ( Today’s)

Inspection Methods 19a-37 
 

 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

 By Type (“Establishment Meeting MOI”)

The IPP should look at the printed or PDF version of the MOI to make sure it is 

complete and has no errors. It’s also a good idea for the IPP to give the copy of

the MOI to the establishment before he or she designates it as final. Any 

establishment disagreement with the contents can be addressed before the MOI 

is final. The MOI may be edited after it is finalized in PHIS by unlocking it and 

providing a justification like the NR. The history of edits made to unlocked 

finalized MOIs is documented and displayed to IPP and establishment managers 

that have eAuthentication. 

44.Click on the Printer icon to view the MOI record available for printing 

or saving as an electronic document 

45.Click the small X at the top to close the tab or pop-up window that 

has the open MOI 

46.Click the Edit icon (pencil) to edit the MOI you created 

47.Scroll down and check the Finalize box 

48.Click the Save button 

 The MOI status is now “Finalized” in the MOI List page grid. 

The IPP must give a copy of the finalized MOI to the establishment. Several 

example MOIs are in Attachment 1 of this handout. 

Completing the Fully Cooked, Not Shelf Stable Task 

For this hands-on activity, you did not find additional noncompliance and you 

verified that the establishment is back in compliance with the monitoring 

requirement. PHIS will not allow the inspection task to be designated as 

“complete” until the IPP documents the NR as “complete”. 

In reality it would probably take the IPP a few days to verify that the 

establishment is conducting the monitoring activity as written in the HACCP plan. 

Thus, the IPP would likely update the inspection results on a subsequent day. 

But in the training session we want to demonstrate how to complete an 

inspection task. 

49.Click the Inspection Results from left navigation menu 

50.Click on Edit icon (pencil) for the open Fully Cooked, Not Shelf 

Stable HACCP verification task 

51.Click the Create/Edit NR button to access the NR 

 The Noncompliance Record page is displayed 

52.Check the NR Completed box 

53.Click the Save button to set the NR status to “Completed”

54.Press the Cancel button to return to the Inspection Result page 

Inspection Methods 19a-38 
 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

PHIS will not allow inspection tasks to be designated a completed unless all the 

mandatory regulations are either verified or marked as N/A (Not Applicable). N/A 

is provided for mandatory regulations that, for some unavoidable reason or 

unforeseen circumstances, could not be verified during the execution of the 

inspection task or the regulation does not apply to establishment operations. 

55.Click on the Regulations tab 

56.Update the task End Date with Today’s Date if necessary 

57.You also verified 430.4(a), 430.4(c)(2), 430.4(c)(3), and 430.4(c)(7) 

and the pre-shipment review. The establishment is in compliance 

with these regulations. 

 Lm requirements are discussed later in the course 

You have ensured the establishment is back in compliance with the regulations 

sited in the NR. 

58.Click the Findings tab 

 Update the information, e.g., indicate all mandatory regulations 

verified 

59.Check the Inspection Completed box 

60.Click the Save button to set the status of the Inspection Task to 

“Completed”

 The following message appears at the top of the page 

“Inspection Result saved successfully “

61. Click the Cancel button 

 Notice the status of the inspection task changes to “completed” 

in the grid 

62. Sign out by clicking the Red X in the upper right corner of the screen 

This ends the hands-on learning for Inspection Verification. You will get more 

practice using the Inspection Verification elements in several workshops during 

the rest of the course. 

Inspection Methods 19a-39 
 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

Summary Example 

Documenting Inspection Results and Noncompliance Example: Upon arrival 

at the establishment, the CSI logs in to PHIS and reviews the establishment task 

list and task calendar. The CSI notices that a Not Heat Treated- Shelf Stable 

HACCP verification task is scheduled to be performed today. The CSI opens 

(claims) the task by selecting the component used to verify the regulatory 

requirements. He clicks on the “regulations tab” and reviews the regulations that 

are mandatory for him to verify while performing this task. He selects a specific 

production of beef pepperoni. He enters the establishment to perform the task. 

While verifying the monitoring, verification, and recordkeeping regulatory 

requirements at the fermentation step-CCP 1, he determines that the 

establishment is not following the monitoring procedure as written in the HACCP 

plan. He informs establishment management of the noncompliance. Upon 

returning to the inspection office, he logs in to PHIS, creates an NR, selects 

417.2(c)(4) to indicate noncompliance with that regulation, and adds the 

description of the noncompliance to the NR by typing the monitoring 

noncompliance in the NR text box. He “finalizes” the noncompliance, prints it,

and delivers it to establishment management. Three days after documenting the 

monitoring noncompliance, he observes the monitor performing the monitoring 

procedure at the fermentation step for another lot of beef pepperoni. This time 

the monitor followed the procedure as written in the HACCP plan. He notes that 

the establishment has brought itself back into compliance with the monitoring 

requirement. 

Fourteen days after starting the task while verifying the monitoring, verification, 

and recordkeeping regulatory requirements at the drying step-CCP 2, he notices 

that an entry on the monitoring record was not initialed. He notifies the 

establishment of this noncompliance. He logs in to PHIS, selects the same 

inspection task, and documents a second noncompliance on the NR. He selects 

417.5(b) to indicate noncompliance with that regulation, ADDS this 

recordkeeping noncompliance to the existing (open) NR by typing the 

finding in the NR text box, “finalizes” the second noncompliance, and 

prints another copy of the NR to give to the establishment. 

Two days after documenting the recordkeeping noncompliance, he reviews the 

establishment’s monitoring records for product lots produced after the beef 

pepperoni and finds that all the entries have been initialed. He notes that the 

establishment has brought itself back into compliance with the recordkeeping 

requirement. 

After verifying the establishment’s prerequisite programs and all relevant 

regulations including the pre-shipment review for the specific production, he logs 

in to PHIS, indicates that 9 CFR 417.5(c) was verified, changes the status of the 

NR to “completed”, and then documents the inspection task as “completed”.

Inspection Methods 19a-40 
 

 

 

□ □ □ □ □ 

□ 

□ 

Inspection Verification 

11/6/2019 

PHIS Steps for this Example 

Activity Day 1 Day 4 Day 14 Day 16 Day 17 

HACCP Task Claim Open Complete 

NR Create Compliance Verified  Complete 

1st 

Noncompliance 

Add/Finalize Finalized 

2nd 

Noncompliance 

Add/Finalize Finalized 

1 

2 5 

7 

6 

4 

3 

1. Initiate / claim the HACCP Task 

2. Create the NR 

3. Add the 1st Noncompliance (cite one or more Regulations) 

Finalize the 1st Noncompliance 

4. Add 2nd Noncompliance (cite one or more Regulations) 

Finalize 2nd Noncompliance (print, sign, and provide) 

5. Verify return to compliance 

6. Complete the NR (after all verification performed) 

7. Complete the HACCP Task (after all results entered) 

Inspection Methods 19a-41 
 

 

 

 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

Attachment 1: Example MOIs 

Memorandum of Interview Conducted at EST. M44925/P44925 

Weekly Meeting 

Date: February 4, 2016 

Time: 1300 

Attending: Mr. Mike Adams, President 

Ms. Diana Popadoupolis, Food Safety Manager 

Mr. Chick Moreno, HACCP Coordinator 

Mr. David Wallace, Maintenance Manager 

Inspector Conducting the Meeting: Mr. Robert Barclay, Consumer Safety 

Inspector/IIC 

Items Discussed: 

1. Noncompliance Records 

I reviewed the condensation noncompliance documented on NR 

#LIC4709025117N issued this week with establishment management. I 

informed the establishment that I associated this condensation 

noncompliance with the condensation noncompliances documented on 

NR # LIC2946085063N and NR # LIC9372041524N and that installing a 

fan in the hot dog packaging room did not prevent the noncompliance from 

recurring. I also informed establishment management that continued 

failure to meet the regulatory requirements may result in additional 

regulatory or administrative action. Mr. Adams stated that Ms. 

Popadoupolis would modify the Sanitation SOP to include a procedure for 

a production employee to observe all overheads in production areas and 

remove condensation as necessary during operation. 

2. Implementation of the Temperature Control Program 

I informed establishment management that when I reviewed the records 

associated with their temperature control program this week I found that 

the program was not being implemented as written. I noted that one 

product temperature measurement was not recorded. Mr. Moreno stated 

that he would counsel the responsible employee on the importance of 

taking the temperature measurements at the frequency stated in the 

program. Ms. Popadoupolis stated she would review the internal 

temperature logs daily for one week starting Monday. 

Inspection Methods 19a-42 
 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

3. Lockout/Tagout 

I inquired about the status of the establishment’s updated list of

lockout/tagout trained employees. Mr. Wallace stated that the list is in the 

process of being updated and as soon as it is completed, the list will be 

forwarded to me. 

4. Safety 

I informed establishment management of the near miss that occurred 

earlier this week involving an establishment employee riding an electric 

pallet jack and myself. 

Mr. Moreno responded by stating that he would look into the incident and 

Mr. Wallace stated that all electric pallet jacks have had the rabbit function 

(make the jack go faster) disconnected. 

5. Record Access 

I informed establishment management that they must make their SSOP, 

HACCP, and all supporting documentation accessible to the 2nd shift 

inspector. I informed establishment management that the failure to make 

these records accessible would result in the inspector issuing a 

noncompliance record. Mr. Adams responded by stating that plant 

management will discuss this matter and one of the possible solutions 

would be to provide a key to the night shift supervisors. 

6. HACCP 

Ms. Popadoupolis informed me that she reassessed the establishment’s 

RTE product HACCP plans to clearly define the establishment’s critical 

limits as per the askFSIS questions listed below that were discussed at 

the previous meeting. 

Question: When the establishment decides to use Appendix A Guidelines 

For Meeting Lethality Performance Standards For Certain Meat And 

Poultry Products as its supporting document (9 CFR 417.5(a)(2)) for its 

cooking/lethality step, must it identify one specific time/temperature 

parameter that it will use as its critical limit in its HACCP plan or can the 

establishment use the entire table? 

Question: If the establishment is producing several different products 

under a single HACCP plan, can the establishment provide a list in its 

HACCP plan of the time/temperature parameters that it may use from 

Appendix A Guidelines For Meeting Lethality Performance Standards For 

Certain Meat And Poultry Products as a critical limit? 

Inspection Methods 19a-43 
 

 

 

 

 

Inspection Verification 

11/6/2019 

Ms. Popadoupolis also stated that the establishment was going to begin 

producing sliced cooked beef and were in the final stages of preparing the 

HACCP plan. 

7. Planned Improvement Program 

Mr. Wallace reviewed the establishment’s PIP. Mr. Wallace stated that 

plant management is awaiting a possible solution from the rack 

manufacturer regarding the flaking paint on the metal racks used to store 

rework plastic tubs. 

Mr. Wallace stated that plant management is waiting for a quote to repair 

a large section of epoxy flooring outside the ovens and rack wash area. 

Mr. Wallace stated that permanent repairs to this section of the floor may 

not be completed until November. However, in the mean time, the 

maintenance personnel will be performing minor repairs as necessary. 

I informed Mr. Wallace that several lights were out in the formulation room 

and some were out in the sliced product packaging room. Mr. Wallace 

stated that the lights would be replaced this weekend. 

8. Holiday Operations 

I inquired if the establishment would be conducting operations on Monday, 

February 21st (Federal Holiday). Mr. Adams responded and stated that 

the establishment would conduct normal operations on that Monday. Mr. 

Adams asked if he needed to provide a letter to that effect and I 

responded by stating that establishment management needed to provide a 

letter to the USDA indicating that the establishment will be operating and 

include the hours of operation. 

9. Review of Establishment Records 

I discussed with Mr. Adams the list of establishment records that I had 

reviewed earlier in the week, including sanitation food contact surface and 

environmental swab results from 2-1 through 2-3. 

Plant Management was provided a copy of the meeting notes. 

Inspection Methods 19a-44 
 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

Example Memorandum of Interview (MOI) Awareness Meeting 

Date: October 17, 2019 

Time: 1445 

Location: Novosibar Poultry, INC. EST. P44926 

1000 Country Lane 

Livingston, CA 00000 

Attending: Ms. Irene Jones, HACCP Coordinator 

Inspector Conducting the Meeting: Cindy Soundly, CSI 

Subject: FSIS Notice 08-10 dated 10/17/19 titled “Sampling of Young Chicken 

Carcasses for Nitrofurans Prior to Chilling”

The following program points were discussed during the awareness meeting: 

1. FSIS developed the nitrofuran residue sampling project to identify 

metabolites of nitrofuran, including semicarbazide (SEM) in poultry 

carcasses. 

2. The sample for the study is a young chicken whole carcass. The carcass 

will be collected at a point in the production line immediately after 

evisceration and prior to chilling and the application of antimicrobial 

agents. 

3. The sample will be collected under the project code NRP_WC (NRP –

Whole chicken) and will begin on or after November 1, 2019. 

4. The sample will be collected and shipped on the same day to the FSIS 

Western Laboratory for analysis using the nitrofuran method. 

5. The establishment is not required to hold the production lot pending 

laboratory results for the sample collected for this sampling project. 

6. FSIS will report the test results through PHIS. 

7. Poultry slaughter establishments eligible for NRP_WC testing will continue 

to receive other directed residue sampling tasks under the U.S. National 

Residue Program (NRP). 

Ms. Jones was provided a copy of the awareness meeting notes. 

Inspection Methods 19a-45 
 

 

 

 

 

 

 

 

 

Inspection Verification 

11/6/2019 

Example Memorandum of Interview (MOI) Presumptive E. coli O157:H7 

Positive 

Date: February 14, 2015 

Time: 0730 

Location: Groveton Meats, Inc. 

1200 Presley Drive 

Los Angeles, CA 94852 

Attending: Ms. Haley Craig, HACCP Coordinator 

Mr. Lauren Kennedy, Plant Manager 

Inspector Conducting the Meeting: Mr. Robert Barclay, Consumer Safety 

Inspector/IIC 

Subject: Presumptive positive E. coli O157:H7 ground beef sample 

Items Discussed: 

1. E. coli O157:H7 Presumptive Positive Result 

I notified Ms. Craig and Mr. Kennedy that the routine MT43 ground beef 

patty sample that I submitted to the FSIS lab on 1/31/11 tested 

presumptive positive for E. coli O157:H7. 

2. Affected Product 

The review of establishment records revealed that the amount of product 

represented by the sample was 900 lbs of ground beef patties. Ms. Craig 

stated that the 900 lbs was still on QC hold in the main freezer, this I later 

confirmed myself. The source material was 2513 lbs of beef trimmings 

which is now implicated in the presumptive positive pathogen result (bill of 

lading #25799 lot #012711AJ). I asked Ms. Craig to identify the additional 

product lots that were produced using the same lot of beef trimmings. Ms. 

Craig stated that he believed that a lot of beef patties and hamburger 

patties were also produced, and he would provide me with the amount of 

product and the lot numbers. Ms. Craig also stated that Groveton does 

not commingle lots of beef trimmings received from Open Beef, Inc., and 

Inspection Methods 19a-46 
 

 

 

Inspection Verification 

11/6/2019 

that a total clean-up is performed before a new lot of beef trimmings is 

used. 

3. Possible Additional Enforcement Action 

I informed Mr. Kennedy and Ms. Craig that if the sample is confirmed 

positive for E. coli O157:H7, the product would be considered adulterated 

and the establishment would be expected to take corrective actions 

including proper disposition of the held product. FSIS may take 

withholding action or suspend operations in accordance with the Rules of 

Practice, Part 500 of the MPI regulations if adulterated product moves in 

commerce 

Supplier Information Previously Gathered: 

1. Establishment Name and Number: Open Beef, Inc., Est. M44927 

2. Establishment phone number: 707-777-1000 

3. Establishment point of contact: Jeff Irvine, Food Safety Manager 

4. Supplier lot number: 012711AJ 

5. Raw beef component: beef manufacturing trimmings 

6. Amount of raw beef component: 2513 lb 

The establishment was unable to provide the point of contact’s E-mail address 

and fax number and the production date for the beef trimmings. 

Establishment management was provided a copy of the meeting notes. 

Inspection Methods 19a-47