USDA Food Safety and lnspKt:lon Service 

===--sa us. DEPARlM:NTOfAOOnl.T\M 

• 

Objectives 

FSIS Responsibility 

-~ llftlr<'('ll1t'nt 

l\\l('c.;l]ga1lrn1 

n.11ysl~ 

lllc-1·r 

EIAO Training May 2017

1

1

Upon completion of this module, you will be able to:

• Describe what a verification plan is, the purpose, and

when a plan is developed.

• Describe the role of the EIAO in developing the

verification plan.

22

2

• Verifying an establishment’s corrective measures

following an NOIE or suspension is one of FSIS’ 

most important public health responsibilities. 

33

3

1
 

 

 

 

 

 

 

 

 

 

Verification Plan 

Verification Plan 

Verification Plan 

EIAO Training May 2017

•Provides a systematic means for FSIS to ensure

that an establishment is effectively carrying out its

corrective actions regarding a NOIE or suspension.

44

4

5

• Failure to carry out plan activities may:

• Jeopardize public health because the establishment

may be producing unsafe product

• Negatively impact our ability to take further

enforcement.

• Impact the establishment’s “due process” in that FSIS

may be keeping the enforcement action open for a

prolonged period without justification.

55

•Designed to verify that an establishment has fully

implemented revisions and is effective in assuring

regulatory compliance

•Assists the establishment to understand the

importance of FSIS’ verification activities.

66

6

2
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Contents 

Contents 

Example Verification Plan 

EIAO Training May 2017

• Describes verification activities that will be performed by

inspection personnel based on specific corrective actions

provided by the establishment

• Provides the PHIS task associated with each verification

activity that will be carried out by the inspection team

• Provides the regulatory citation associated with each

verification activity

77

7

8

• The EIAO also determines corrective actions proffered

by the establishment that cannot be verified through

regular PHIS procedures and lists them in the

verification plan.

• Example: plant improvement plans

88

Plant Action

Verify implementation of SSOP

Reg. Citation

416.13(b)

Task

Preop/Op Sanitation

Verify calibration of process

monitoring equipment

417.4(a)(2)(i) RTE NSS HACCP

Verify actual temperatures

recorded in chilling records

417.5(a)(3) Poultry Slaughter

PIP Item

Verify that the overheads have been refinished at the end of 3 months.

99

9

3
 

 

 

 

 

 

 

 

 

 

 

 

 

When to Develop 

Verification Plan 

Preparing the Plan 

EIAO Training May 2017

• Verification plan should be developed whenever a

decision is made to:

• Defer enforcement after an NOIE has been issued

• Hold a suspension in abeyance after the assignment of

inspectors has been suspended

• Consent agreement/verify provisions

110

10

• The verification plan must be:

• referenced in the deferral or abeyance letter

• provided to the establishment as an enclosure to the

deferral or abeyance letter

111

11

• EIAO has primary responsibility

• Include input from the FLS and the IPP team

• Team approach ensures key issues are covered and

proper work methods will be used to conduct

verification activities

• Additional time may be needed to prepare the plan

112

12

4
 

 

 

 

 

 

 

 

 

 

 

Verification Activities 

Flexibility 

EIAO Follow-up 

EIAO Training May 2017

• Procedures identified in the verification plan are

performed as regularly scheduled PHIS procedures

•In-plant inspection team will verify the corrective

actions as a part of the inspection procedure

113

13

•In-plant inspection team has the flexibility to increase

the frequency of verification based on their findings

• Inspector generated procedures can also be

performed if the establishment increases food safety

monitoring and verification activities.

114

14

• The EIAO will:

• Conduct follow-up at establishments at 30-, 60-, and

90-day intervals

• Determine establishment compliance

• For example, at the end of the deferral or abeyance

period to determine if the action should be closed out

115

15

5
 

 

 

 

 

 

 

Establishments in Deferral or 

.A:oeyance 

• 

Workshop 

EIAO Training May 2017

• Verification activities could reveal:

• sufficient basis exists to close a deferral decision or

suspension being held in abeyance

• corrective measures are inadequate, and FSIS should

suspend inspection, reinstate a suspension, or initiate

proceedings to withdraw inspection

• EIAOs document this in a decision document to the

DM or in letter to establishment

116

16

117

17

6