EIAO Training 4-4-14

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• Small Business Regulatory Enforcement 

Fairness Act (SBREFA) • Signed into law March 29, 1996 • Gives small/very small establishments a 

greater voice in development and enforcement 

of regulations

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• Small Plant • Very Small Plant • Ombudsman 

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• Advocacy • Outreach and compliance assistance • Enforcement Fairness • To ensure non-retaliation for regulated 

establishments

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• Goal – Provide technical guidance and 

assistance to small and very small meat, 

poultry establishments, and egg plants • Constitute vast majority of meat and poultry 

plants in U.S. • Usually need technical guidance and 

assistance in HACCP and food safety 

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• Small and Very Small Plants may: • Lack resources • Lack knowledge • Have possible language barriers • Lack strong Associations • Believe that old methods result in safe 

products

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• Lack of scientific support for hazard 

analysis and reassessment • Validation – Reliance on literature without 

validation in the plant’s environment • “We’ve done it this way for years - no one 

has died from eating our product.” • “Government makes new requirements to 

put small plants out of business” • Cannot leave plant for training

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• EIAO’s play a vital role in advocacy • Key position to provide outreach to small and 

very small plants • Included in EIAO job description and 

performance elements • Majority of issues deal with food safety systems 

design

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• Food Safety System Design, “HACCP” • Supporting Documentation • Initial Validation • More Complex

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• Bad Actors • Must meet Regulatory Compliance • Do not have to implement outreach we 

provide • Document, document, document...

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• Outreach visits • For outreach assistance - not FSA • Promotes open communication • May perform while in the area performing 

FSA at another plant

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• Promote understanding of regulatory 

requirements • Explain what to expect during FSA • Provide FSIS materials/resources • Share guidance material/contact lists • Carry FSIS supplied material with you • Refer plants to Contacts/Coordinators • They can do what FSIS cannot

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• Do not write the HACCP Plan or SSOP • Do not dictate CCP’s • Do not create additional burdens • Do not hesitate to involve Contacts or 

Coordinators • They can provide direct assistance

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• Participate in HACCP courses or 

roundtables held at universities • Collaborate with others to hold workshops 

for small plants • Food Safety Summits • Conferences for IPP

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• Outreach and Partnerships Division of 

OOEET • Prepares compliance materials • Serves • FSIS employees • Small plant owners/operators • State and local governments • American Indian/Eskimo • Underserved populations

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• Extensive library of free outreach materials • In English and Spanish, some in Chinese, 

Korean, and Vietnamese • Guidebook for Preparation of HACCP Plans • Generic HACCP Models available • Booklets, videos and CDs on HACCP and Food 

Safety

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• Hard copies – Listed on brochure • Call Outreach and Partnership Division of 

OOEET at 202-690-6522 • FSIS web page • http://www.fsis.usda.gov/wps/portal/fsis/topic

s/regulatory-compliance/haccp/small-andvery-small-plant-outreach

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• In addition to the role of the EIAO: • State Outreach and Technical Assistance 

Division (SOTAD) of OOEET works with 

Contacts and Coordinators, associations, and 

others • List of HACCP Coordinators in each state can be 

accessed from the small plant webpage

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• In addition to the role of the EIAO: • In November 2009 FSIS began to offer • Toll-free Small Plant Help Desk • One stop shop for questions about how to make sure 

products are safe, wholesome, properly labeled • Provide a portal to other services such as AskFSIS • 1-877-FSISHelp or email Infosource@fsis.usda.gov

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• OFO has developed a start up package to 

guide new small and very small plants thru 

the process • Beginning with applying for the Grant of 

Inspection • Available at any district office

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• National Ombudsman and Regulatory 

Fairness Boards • Forum for small businesses to report 

compliance or enforcement experiences with 

Federal regulatory agencies

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• Avenues of appeal for small entities • Do not replace FSIS appeal processes • Cannot overturn or adjudicate Agency 

decisions • Focus on “unfairness” in regulatory 

decisions or enforcement actions

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• Agency role • Ensure non-retaliation • Attend Fair Regulatory Enforcement Hearings if 

issue raised • Provide official responses to complaints or 

comments

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• Provide compliance assistance to small 

and very small plants • Provide information on outreach and 

available resources • Attend meetings, roundtables, and 

workshops as directed • Communication is the key!

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• FSIS Headquarters SBREFA Contacts: • Lisa Volk, OFO (202) 720-4863 • Rachel Edelstein, OPPD (202) 205-0495 • Victoria Levine, OPPD (202) 720-5627 • Scott Safian, OPEER (202) 418-8872 • Jeff Tarrant, OOEET (202) 690-6522

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