Inspection Verification 

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PHIS INSPECTION VERIFICATION (PART 2) 

Objectives 

After completing this section of the training, participants will be able to: 

1. Define the term “noncompliance”.

2. Document noncompliance on a Noncompliance Record (NR) in PHIS 

3. Identify the information that must be recorded on the NR when IPP are 

documenting a trend in noncompliance. 

4. Identify the activity IPP must perform before an NR can be completed. 

Documenting Noncompliance in PHIS 

Noncompliance is defined as an establishment’s failure to meet a regulatory 

requirement. When IPP find regulatory noncompliance, they are to: 

1. Notify a representative of establishment management as soon as possible 

either verbally or in writing, 

2. Document the noncompliance on a Noncompliance Record (NR, FSIS Form 

5400-4) in PHIS and present the noncompliance to establishment 

management, 

3. Verify that the establishment takes necessary actions to bring itself into 

compliance with the applicable regulation, and 

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Note: PHIS will not allow the inspection task to be designated as “completed” 

until IPP have verified and documented that the establishment has brought 

itself into compliance with the regulatory requirements that were not met and 

resulted in the issuance of the NR. 

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IPP should not allow the establishment to address noncompliance without 

documenting it (there are few exceptions identified the HACCP regulatory 

process module). To complete the NR, IPP follow the instructions in Chapter V of 

FSIS PHIS Directive 5000.1 and the PHIS user guide on the insideFSIS intranet 

PHIS page. 

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The NR serves as FSIS’s official notification and documentation of the

establishment’s failure to meet one or more regulatory requirements. NRs are 

legal documents. They are the basis for supporting further enforcement actions 

that the Agency may take against an establishment. NRs are also the building 

blocks for a legal case that may be developed against an establishment. If an 

FSIS administrative enforcement action has been taken and appealed by an 

establishment, an administrative law judge, who will make a decision concerning 

the case, will review all the evidence supporting the enforcement action. In many 

of these cases, the NR generated by IPP may be the only evidence provided to 

the judge that supports FSIS’s actions. The NRs provided to the judge in those 

cases must speak for themselves. Therefore, it is extremely important that IPP 

use good documentation practices and follow Agency policy when completing 

NRs. For instance, IPP must ensure that the written description of 

noncompliance documented on an NR adequately supports the determination of 

regulatory noncompliance and the NR is accurately completed. IPP must provide 

establishment management with a copy of the NR. By notifying the establishment 

of noncompliance with the regulatory requirements both orally and in writing via 

the NR, IPP are providing the establishment with due process. 

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Note: Supervisory personnel are to support IPP in documenting noncompliances 

when they occur. 

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Only one NR is completed per inspection task when noncompliance is found. 

However, more than one noncompliance can be documented on the NR. 

In some establishments, inspection tasks may take all day, more than a day, or a 

week or several weeks for the IPP to complete. For these inspection tasks, PHIS 

enables IPP to document noncompliance on the NR when it is found and provide 

a copy of the NR to establishment management before the inspection task is 

completed. For example, a particular inspection task takes three days to 

complete in the establishment. On the first day of performing the task, the IPP 

finds noncompliance with a regulatory requirement. IPP must finalize each 

individual noncompliance and present it to establishment management as soon 

as practical. Therefore, she notifies the establishment orally and presents the 

noncompliance to the establishment by giving management a copy of the NR at 

the end of the workday. On the third day of performing the task, she finds 

noncompliance with a different regulatory requirement, notifies the establishment 

orally, and presents this noncompliance to establishment on another copy of the 

NR with the same number. In this example, there is one NR with multiple pages. 

Each page of the NR documents a different noncompliance and cites a different 

regulation but the number is the same on each page. 

Noncompliances and NRs have a status displayed in PHIS. The noncompliance 

and NR statuses are defined in the following table. 

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Status in PHIS Definition 

Noncompliance (NC) Open  A noncompliance has been 

documented in PHIS 

Finalized  The noncompliance is ready 

to deliver to establishment 

management 

Noncompliance 

Record (NR) 

Open  An NR has been created in 

PHIS 

Completed  All of the mandatory 

regulations have been 

verified 

 The establishment has 

brought itself into compliance 

with the regulations for each 

noncompliance in the NR. 

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Note: IPP can issue a printed copy of the NR to establishment management at 

any time after it is created, e.g., when the first noncompliance is documented and 

finalized, when another noncompliance is documented and finalized on the 

existing (open) NR, or after the NR is completed. 

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Completing the Noncompliance Record (NR, FSIS Form 5400-4) in PHIS 

When IPP determine that the establishment has not met one or more regulatory 

requirements, they check the “Regulatory Noncompliance” box at the bottom of 

the “Regulations tab” of the Inspection Results page, and then click “Save” in 

PHIS. Checking the “Regulatory Noncompliance” box enables the Create/Edit 

NR button on the bottom of the Inspection Results page. Much of the information 

that appears in the sections/blocks on the printed NR is automatically added by 

PHIS. Some blocks on the printed NR are completed with information entered by 

the IPP. For instance, the IPP must provide a complete, clear, and concise 

description of each noncompliance. 

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Note: If PHIS is not operational, IPP may complete and issue a paper copy of the 

NR (FSIS Form 5400-5). However, once PHIS becomes operational again, IPP 

are to record the applicable procedure and results and document the NR in 

PHIS. 

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Sections/Blocks of the NR 

At the top of the NR, PHIS automatically checks a box to indicate the 

noncompliance relates to “Food Safety” or “Other Consumer Protection” based 

on the inspection task name. 

1. Date—Automatically generated by PHIS from the Inspection Results page. 

2. NR number.—Automatically generated by PHIS. The number of the NR is a 

random, system generated number. It contains 14 alpha numeric characters, 

but does not have any information like establishment number or date 

associated with it. The number ends with a letter N and it is usually followed 

with a /1. If additional noncompliance(s) is later recorded for the same task, 

there may be additional NR pages identifying those noncompliances. Those 

pages will have the same NR number but it will be followed with a /2, 3, and 

so on. Having PHIS randomly generate the number for the NR prevents the 

duplication NR numbers. 

3. Est. No.—Automatically generated by PHIS from the Inspection Results 

page. The establishment number is associated with the task on the task 

calendar. 

4. To (Name and Title)—PHIS will provide a pick-list of names from the PHIS 

Establishment profile “Contacts” page to select from or the IPP can manually 

enter (type) the name and title of the responsible person. For a HACCP 

system noncompliance, the name of the person who signed the HACCP plan 

should be selected. For a Sanitation SOP regulation noncompliance, the 

name of the person who signed the Sanitation SOP should be selected. For 

SPS noncompliance, IPP should enter the name of the establishment official 

responsible for responding to the NRs. PHIS adds the name of the individual 

the IPP selected to this block of the NR. 

5. Personnel Notified—IPP enter the names of the establishment management 

personnel who were notified about the noncompliance. PHIS will provide a 

pick-list of names from the PHIS Establishment profile “Contacts” page. IPP 

select one or more names from the list offered in PHIS. If IPP notified 

someone other than one of the listed contacts, they manually enter (type) the 

name and title of the establishment management personnel in the other 

personnel notified fields on the Noncompliance page. PHIS will add the 

name(s) of the individual(s) the IPP selected to this block of the NR. 

6. Relevant Regulations—IPP check one or more the regulatory citations 

appearing in the pick-list on the Noncompliance page in PHIS. PHIS will 

provide a regulatory citation pick-list based on the regulations that were 

checked as verified by the IPP on the Inspection Results page. IPP verify that 

the regulatory citation pick-list includes all the specific regulations not met. If 

a particular regulation is not available in the PHIS list of regulations on the 

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Inspection Results page, they should type it in the noncompliance description 

text block of the NR. PHIS will add the regulations that the IPP checked as 

non-compliant to this block of the NR. 

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Note: PHIS tracks and counts each regulation verified and each regulation 

that is noncompliant. An establishment’s performance is based on the 

individual instances of regulatory noncompliance entered into PHIS and not 

on the number of NRs issued. 

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6a. Associated NR(s)—IPP associate NRs when a developing trend in 

noncompliance is occurring within the establishment . IPP should only 

associate NRs together when the noncompliances are from the same cause. 

PHIS will allow IPP to review recent NRs with similar documented 

noncompliances and select one or more NRs to be associated to the new NR. 

PHIS will add the associated NR numbers to block 6a. 

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Note: Associating NRs will be discussed in detail later in this module and 

demonstrated in the hands-on learning portion of this module. 

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7. Titles of HACCP or SSOP Plan or other supporting Documentation—For 

HACCP verification tasks, IPP select the HACCP plan under the Activity Tab 

of the Inspection Results page that was verified during the performance of the 

HACCP task. PHIS will provide a pick-list of the names of the HACCP plans 

from the Establishment profile “HACCP” page. The IPP may also manually 

enter (type) the name of another HACCP plan if it is also verified. The 

HACCP plan name is added to this block by PHIS. 

7a. Name of CCP(s) or Prerequisite Program—For HACCP verification tasks, 

IPP manually enter (type) the name of CCP(s) that was verified during the 

performance of the HACCP task in the box under the Activity Tab of the 

Inspection Results page. They also select prerequisite program (if applicable) 

that was verified during the performance of the HACCP task under the Activity 

Tab of the Inspection Results page. PHIS will provide a pick-list of the names 

of the prerequisite programs from the Establishment profile “HACCP” page. 

The IPP may also manually enter (type) the name of another prerequisite 

program if it is also verified. PHIS will add the CCP(s) and/or prerequisite 

programs recorded in the Inspection Results page to the NR. 

Note: Performing the HACCP verification tasks is discussed in detail later in 

this course. 

8. Inspection Task—Automatically generated by PHIS from the Inspection 

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Results page. The task may be a routine or directed task. 

9. Verification Activity—Automatically generated by PHIS from the Inspection 

Results page. When IPP claim (start) the task, they are required to select the 

verification component (review & observation or recordkeeping or both) used 

to verify compliance with the regulations. 

9a. Affected Product Information—IPP check the product adulteration box on 

the Noncompliance page to indicate that the documented noncompliance 

resulted in adulterated or misbranded product being produced. Finding fecal 

material while performing the Livestock Zero Tolerance task would be an 

example of when the product adulteration box should be checked. If the 

adulteration box is checked, IPP enter (type) the product name, lot number, 

approximate weight and any other information available in the data fields on 

the Noncompliance page to identify the specific amount of product affected by 

the noncompliance. PHIS will automatically add the product information on 

the Noncompliance page to this block of the NR. When direct contamination 

or adulteration is not observed during the task, IPP leave the data fields on 

the Noncompliance page blank. 

9b. Retain/Reject Tags—When IPP take a regulatory control action based on 

the noncompliance finding, e.g., retain contaminated or adulterated product or 

reject equipment or facilities, they manually enter (type) the number of the 

tag(s) in the appropriate field on the Noncompliance page. PHIS will 

automatically add the tag number(s) for the Noncompliance page to this 

block. 

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Note: If a regulatory control action was taken, IPP are to immediately notify 

establishment management orally or in writing and provide the basis for 

taking the regulatory control action. 

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10.Description of Noncompliance—IPP include the following elements in their 

description of the noncompliance in the text box of the Noncompliance page: 

 A clear, concise, and complete description of each noncompliance 

including 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. 

 An explanation of how the IPP notified establishment management of the 

noncompliance. 

 Reflect the use of a regulatory control action (include the tag number) or a 

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withholding action. 

 If there is a developing trend of noncompliance, IPP add additional 

information to the description of the noncompliance. IPP also associate 

the current NR to the previous NR that documents the noncompliance 

from the same cause. IPP include: 

 A description of how the IPP determined that this noncompliance is 

from the same cause as the previous noncompliance, and 

 The previous NR number and establishment’s immediate and further 

planned actions or corrective actions and preventive measures taken 

for the previous noncompliance that were unsuccessful in achieving 

compliance. 

If another noncompliance is found during the remainder of the inspection task, 

IPP can document it separately in PHIS. PHIS will add the description of the 

noncompliance from the Noncompliance page to this block. 

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Note: In most cases, it is not necessary to include references to the Acts or a 

complete quote of the applicable regulation. 

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The following examples demonstrate documenting noncompliance in the text 

box on the Noncompliance page in PHIS. Refer to Attachment 1 of this 

handout. 

Noncompliance Description Example 1: At approximately 0410 hours, on 

1/27/2016, after the establishment’s pre-operational inspection and before the 

start of production, I performed the Pre-Op SSOP review and observation 

task. I observed the following noncompliances: 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. I applied U.S. “Rejected” tags (#B67587521 through 6) to the #2 

grinder, the small Hobart grinder, the stuffer, and both band saws. I verbally 

informed the sanitation foreman of the noncompliance with 416.13(a). He 

immediately had the equipment appropriately cleaned to restore sanitary 

conditions. 

Noncompliance Description Example 2: At approximately 1425 hours, on 

1/28/2016, while performing the SPS task, I observed condensation dripping 

from pipes attached to the ceiling onto chicken parts on belt #1 in the boning 

room. Belt #1 was U.S. “Rejected” with tag B2746867. Approximately 150 lb 

of product with lot #1282012Z was U.S. “Retained” with tag B2746868. Ms. 

Mary White was verbally notified of the direct contamination of product and 

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the insanitary condition of belt #1. She was informed that the regulatory 

control actions would remain in effect until the establishment meets the 

requirements of 9 CFR 416.15. 

11.Signature of Inspection Program Employee—When IPP are satisfied with 

the description of the noncompliance in the text box on the Noncompliance 

page, they check the “Finalized” box at the bottom of the page, print and sign 

the copy of the NR given to the establishment. 

12. Plant Management Response—The establishment is not required to 

provide a response for the noncompliance documented on the NR. Providing 

a response to the NR is voluntary on the part of the establishment. However, 

the establishment is responsible for bringing itself back into compliance with 

the regulatory requirements. When the establishment elects to respond to the 

noncompliance, it may provide “immediate action” and “further planned 

action”. “Immediate action” represents the action the establishment takes to 

correct the noncompliance, including appropriate product disposition. The 

“further planned action” is the action to prevent recurrence of the 

noncompliance. The establishment may respond to the noncompliance in a 

number of ways. 

 When the establishment has e-authentication, it may respond to the NR 

electronically in PHIS. To observe the establishment’s response, IPP click 

the “Response” tab on the Noncompliance Record page.

 If the establishment response to the NR is provided in writing through 

electronic means (PDF file or word file) to the IPP, he or she can upload 

the file to the Response tab on the Noncompliance page. 

 The establishment may provide immediate and further planned actions on 

the printed copy of the NR and return it to the IPP. 

 The establishment may provide a verbal response to the NR (e.g., verbally 

provide immediate and further planned action or corrective action and 

preventive measures). IPP may record that response on the printed 

copy of the NR. However, there is no requirement for IPP to record 

management’s verbal response on the NR. If IPP elect to document the 

establishment’s response on the printed copy of the NR, they can add 

brief synopses of the verbal response in block 12. They should not 

transcribe all the information verbatim. Entering the establishment’s 

response to correct the noncompliance may assist FSIS in the future 

especially if the action does not prevent recurrence of the noncompliance. 

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Note: The preferred method of documenting the establishment’s verbal

responses to noncompliance documented on NRs is in weekly meeting 

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notes and subsequent MOI. IPP do not enter the establishment’s 

verbal response to the NR or the written response on the printed NR 

in the Response tab of the Noncompliance Record page of PHIS. 

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IPP should not tell the establishment what immediate and further planned 

actions to take to correct and prevent a noncompliance or require the 

establishment to take any particular immediate and further planned actions to 

correct and prevent a noncompliance. Determining the proper action to take is 

the establishment management’s responsibility! 

13 and 14. Signature of Plant Management and Date—If establishment 

management responds in writing in block 12 of the copy of the NR given to 

them, an establishment official should sign and date the printed copy of the 

NR. 

15 and 16. Verification Signature of Inspection Program Employee and 

Date— Once an establishment is back in compliance with all the regulatory 

requirements documented on the NR as noncompliant, IPP check the “NR

Completed” box on the bottom of the Noncompliance Record page in PHIS. 

The IPP also signs and dates the printed copy NR in the government file after 

verifying the establishment has brought itself into compliance with all the 

regulatory requirements that resulted in the issuance of the NR as described 

in the next section. 

Maintaining Copies of NRs in the Government Office 

IPP maintain an NR file that is divided into two sections in the government office 

at official establishments. One section of the NR file is identified as “open”. The 

other section is identified as “completed”.

The Open NR File 

In addition to giving the establishment a copy of the printed NR, the IPP places a 

copy of the NR in the “open” file when the IPP has not verified that the 

establishment is back in compliance or the establishment has not brought itself 

into compliance with the regulatory requirement that resulted in the issuance of 

the NR. Depending on the noncompliance, the establishment may be allowed a 

period of time to bring itself into compliance with the regulations provided 

operations would not result in the preparation of adulterated product. 

Remember that the establishment is not required to provide immediate and 

further planned actions in writing on the NR. However, if the establishment 

returns a copy of the NR to the IPP with proposed immediate and further planned 

actions in block 12, the IPP removes the NR without the establishment’s 

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response from “open file” and replaces it with the NR that has the 

establishment’s response. The NR without the establishment’s response served 

as a place holder to indicate that an NR had been issued until the establishment 

returned a copy of the NR with its response. If the establishment proposed 

immediate and further planned actions orally, the IPP may document a summary 

of the establishment’s oral response on the NR and place it in the “open” file. The 

NR remains in the open file in the government office and the electronic version of 

the NR in PHIS remains “open” until the establishment has brought itself into 

compliance with the regulatory requirements. 

The Completed NR File 

When the IPP verifies that the establishment has brought itself into compliance 

with the regulatory requirement(s) that resulted in the issuance of the NR, the 

IPP removes the NR from the “open file” completes block 15 and 16 of the NR 

(signs and dates) and places the NR in the “completed” file. If the establishment 

provided a response in writing on the NR or the IPP documented the 

establishment’s oral response on the NR, the IPP signs and dates the copy of the 

NR with establishment’s documented written or oral response. The IPP also 

checks the “NR Completed” box on the Noncompliance Record page in PHIS. 

IPP do not sign the copy the NR in the open file in the government office until 

they have verified that the establishment has brought itself into compliance with 

the regulations. 

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Note: In some noncompliance situations, the establishment may have taken 

immediate action and the IPP verified that the establishment had brought itself 

into compliance with the regulatory requirement(s) before the IPP gave the NR to 

the establishment, e.g., pre-op sanitation noncompliance. In this case, the IPP 

completes blocks 15 and 16 of the NR (signs and dates) and places the NR in 

the “completed” file.

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Completing “Open” NRs

IPP review the “open” NR file in the government office or the “open” NRs in PHIS 

by clicking the arrow next to Inspection Verification in the left navigation menu 

and then clicking the Noncompliance Records link daily. During the performance 

of inspection tasks, they are to verify that the establishment has brought itself 

into compliance with regulatory requirements that were not met and resulted in 

the issuance of an NR. 

Verifying that the Establishment is Back in Compliance Example 1: Upon 

arriving at the establishment on Monday, a relief IPP reviews the open NR file in 

the government office and sees that the assigned IPP had issued an NR last 

Tuesday for a 1 foot by 8 inch hole in the processing room floor, under the 

product belt conveyor of line one, that had an accumulation of product residue 

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from previous days’ production. The establishment stated in block 12 of the NR 

that the floor would be repaired over the weekend. While performing the Pre-Op 

SSOP Review and Observation task in the processing room, the relief IPP 

examines the floor under the product belt conveyor of line one and sees that the 

floor has been repaired and there is no longer an insanitary condition. 

Upon returning to the inspection office, the relief IPP removes the NR from the 

“open” file, signs and dates blocks 15 and 16 because the establishment has 

brought itself into compliance, and then transfers it to the “completed” NR file. 

When he logs into PHIS, he accesses the NR in PHIS and checks the “NR 

Completed” box on the Noncompliance Record page. 

The relief IPP wants to make sure that the regularly assigned IPP is aware of this 

action. He creates an Inspection Note, provides information about his 

observations, and points out the completed NR. 

If the noncompliance necessitates the establishment to take corrective action 

required by 9 CFR 416.15 or 417.3, the NR can only be completed after the IPP 

has verified that the establishment has met the requirements of 9 CFR 416.15 or 

417.3. Establishments are not required to indicate corrective and preventive 

measures on the NR. Hence, IPP may need to verify corrective actions by 

reviewing establishment records. 

Verifying that the Establishment is Back in Compliance Example 2: On 

Monday, the assigned IPP found a deviation from a critical limit while performing 

the HACCP verification task and notified the establishment. The establishment is 

required to take the corrective actions in 9 CFR 417.3(a) when there is deviation, 

and the IPP is required to verify that the establishment’s corrective actions meet 

the regulatory requirements in 9 CFR 417.3(a). 

The IPP observes the establishment segregate and hold the affected product, 

identify and eliminate the cause of the deviation, and record these actions on the 

corrective action log. The establishment also makes entries on the log that states 

“we will monitor the critical limit hourly instead of twice per shift as written in the 

HACCP plan for the next two days to ensure that the CCP is under control and 

meet with the maintenance supervisor to establish a preventive measure”. She 

documents the noncompliance in the PHIS and gives the establishment a copy of 

the NR. The establishment returns the NR to the IPP with the following notation 

in block 12 “see corrective action log”. She places the NR in the “open” file.

On Thursday, she reviews the establishment’s corrective action log and

monitoring records for the specific production involved in the deviation to finish 

the HACCP verification task. She finds that the establishment has established a 

standard operating procedure (SOP) as a preventive measure and the additional 

monitoring checks were performed and no additional deviations were found. The 

corrective action log indicates that the affected product is still on hold pending a 

review of the deviation by a processing authority. On Friday, the establishment 

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tells the IPP that the affected product will be destroyed. The IPP oversees the 

destruction of the affected product and reviews the corrective action log, which 

has the product disposition entry. 

Upon returning to the inspection office, she removes the NR from the “open” file, 

signs and dates blocks 15 and 16 because the establishment has brought itself 

into compliance, and then transfers it to the “completed” NR file. She already 

verified all of the other mandatory regulations for the task so when she logs into 

PHIS, she also accesses the NR in PHIS and checks the “NR Completed” box on 

the Noncompliance Record page. Then, she checks the “Inspection Completed” 

box on the Inspection Results page. 

Hands-on Activity 

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

with the PHIS Inspection Results and Noncompliance pages that are used to 

document the results of inspection tasks performed by IPP. For this hands-on 

activity, you (as Robert Barclay) will document the results, including 

noncompliance, for a Pre-Op SSOP Review and Observation task. 

Follow these steps along with the instructor. 

 Open the laptop 

 Log-onto laptop: 

 User Name: FSIS_user 

 Password: FSIS 

 Double click the Start Internet Explorer icon 

 PHIS Log-in 

 Select User: Robert Barclay (your #) 

Schedule a Pre-Op SSOP Review and Observation Task 

1. Click Task Calendar option in the left navigation menu 

2. From the Establishment Task List, click the drop-down arrow and 

select Holland Point Foods as the establishment 

3. Type SSOP in the task name filter 

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

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

4. Click the Filter icon 

5. Click Contains in the pick list 

6. Find the Pre-Op SSOP Review and Observation task on the task 

list 

7. Click the Add link in the routine column for the Pre-Op SSOP 

Review and Observation task 

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8. Type the number “1” in the box for Today’s Date in the task 

calendar pop-up window 

9. Click the Save button 

10.Scroll down to the Task Calendar and see if the Pre-Op SSOP 

Review and Observation task is on the calendar for Today 

Enter the Inspection Result for the Pre-Op SSOP Review and Observation 

Task 

Before the results from performing an inspection task can be entered on the 

Inspection Result page, the IPP must claim the task. The IPP that claims the task 

is responsible for performing it and documenting the results. Recall from the task 

calendar presentation, that another IPP can complete it, but he or she will have 

to unlock the task and provide a reason for unlocking it. 

1. Right click on the Pre-Op SSOP Review and Observation 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 

2. Click the Activity tab 

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

screen 

4. Click the radio button in front of Both for the verification component 

5. Click the Save button 

 The task is now claimed 

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

saved successfully”

Note: If a verification component is not selected before the IPP saves, 

he or she will get an error message at the top of the page. 

IPP can add additional information directly related to performing the task in the 

comments or affirmative findings texts boxes under the Findings tab. 

6. Click the Findings Tab 

7. In the Comments box type: “The RTE product room and blending 

area were inspected because establishment SSOP records indicated 

product residue on food contact surfaces was found twice last week”

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

inspection task. PHIS does not allow a task to be designated as “completed” in 

the system unless all of the mandatory regulations for the task have been verified 

or the N/A (not applicable) box has been checked and a justification for not 

verifying the regulation has been provided. 

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8. Click the Regulations tab 

9. Check the mandatory regulations as verified- 416.13(a), 416.13(c), 

416.14, and 416.16(a) 

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. 

10.Check the Regulatory Non-compliance box 

Note: Checking the Regulatory Noncompliance box is the only way 

to create a NR in PHIS. 

11.Click the Save button 

 The Create/Edit NR button is now enabled 

12.Click the Create/Edit NR button 

 The Noncompliance Page in PHIS is presented 

13.Review the Noncompliance Record page 

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

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

14.Review the information on the General tab 

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 

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

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

exercise. 

15.Click on the Noncompliances tab 

 A blank noncompliance grid is displayed 

16.Click Add Noncompliance 

17.Slowly scroll down and Review the information on the 

Noncompliance page 

At the top of the “Noncompliance” page are the regulations that the IPP verified 

during the performance of the task. These were selected (checked) from the 

“Regulations” tab on the Inspection Task Results page. In the middle of the page 

is the text box for entering the description of the noncompliance. Under the 

noncompliance description text box there are additional product information text 

boxes including entering Regulatory Control Action tag numbers. At the bottom of 

the page, IPP select the name of establishment individual that the 

noncompliance and associated NR is addressed to which is usually a predetermine contact individual. They also identify the name of the individual(s) that 

Inspection Methods 14-14 
 

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7/11/2018 

were notified of the noncompliance. These names should have been entered on 

the establishment profile. IPP may add additional names that are not on the picklist by typing in their first and last names and clicking the “Add” button. The NR 

addressee name is mandatory. If this individual is not selected, the IPP will get 

an error message. 

18.Scroll to the top of the page, document the noncompliance and 

complete a draft of the NR (FSIS Form 5400-4) 

19.Check 416.13(a) 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. 

20.Type the Description: While performing Pre-Op Sanitation 

inspection on 2-2-2016 at 6:44 am after the facilities were released 

for inspection, I observed meat and fat scraps from the previous 

day's production on meat slicer #5 and the mixing blades of the 

vacuum blender. I applied U.S. Rejected tag B00001 to the slicer 

and U.S. Rejected tag B000002 to the blender. I verbally informed 

Diana Popadoupolis of the noncompliance with 416.13(a). She 

immediately had the equipment cleaned to restore sanitary 

conditions. The sanitation record was not available when this task 

was performed. 

21.Type Tag #s B000001 and B000002 in the box 

22.Click the Addressed to down arrow and select: Mike Adams 

23.Select Personnel Notified: Diana Popadoupolis 

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

button, then Cancel button 

25.Click Noncompliances Tab again 

 The noncompliance now appears in the grid 

26.Click the Printer icon 

27.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. The noncompliant regulation(s) and the verification activity the 

IPP used to verify the regulations are listed. If a regulatory control action was 

taken the tag number appears in block 9. The description that the IPP entered on 

the Noncompliance page appears in block 10. 

Inspection Methods 14-15 
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7/11/2018 

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 Edit icon (pencil) to reopen the NR 

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. 

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

Noncompliance page 

31.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 

32.Click the Cancel button 

33.Click the Noncompliances Tab again 

 Notice that the status of the Noncompliance has changed from 

Open to Finalized in the grid 

34.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 

35.Click the small X at the top to close the tab or the 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. 

The establishment restored sanitary conditions, thus the establishment is back in 

compliance with the regulations. 

36.Check the NR Completed 

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

38.Click the Cancel button to return to the Inspection Result page 

39.Click the Regulations Tab 

40.Check 416.15(a) and 416.15(b) as verified 

 You verified that the establishment implemented the required 

corrective actions 

41.Check the Inspection Completed box 

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Inspection Verification 

7/11/2018 

42.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 “

43.Click the Close button 

44.Scroll down to the bottom of the task calendar 

 Notice that the Pre-op SSOP Review and Observation task is 

now green indicating that it is completed 

45.Sign out of PHIS by clicking the Red X in the top corner of the screen 

Summary Example 

The following example summarizes documenting inspection results and 

noncompliance in PHIS. The documentation methods outlined in the example 

were demonstrated in the hands-on learning portion of this module. 

Documenting Inspection Results and Noncompliance Example: Upon arrival 

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

list and task calendar. The IPP notices that a Pre-Op SSOP review and 

observation task is on the task calendar to be performed today. The IPP 

“initiates/claims” (opens) the task by selecting “both” for the verification

component. She clicks on the “regulations tab” and reviews the regulations that 

are mandatory for her to verify while performing this task. She determines the 

processing areas and equipment she will observe to verify compliance with the 

regulations. She enters the establishment to perform the task. 

While performing the task, she finds meat, fat, and bone dust adhering to the 

surface of the band saw blade and on the inside of the band saw cabinet. She 

applies a U.S. Rejected Tag to the band saw and verbally notifies establishment 

management. She also finds dried, encrusted fat and meat scraps on the 

underside of two boning tables and notifies establishment management. She 

reviews the establishment’s sanitation record. The establishment did not identify 

product residue on the band saw. 

She returns to the inspection office to document the results of her verification. 

She logs on to PHIS, creates an NR, selects 416.13(a) and 416.4(b) to indicate 

noncompliance with those regulations, adds the description of the 

noncompliances to the NR by typing it in the NR text box, “finalizes” the 

noncompliance, and prints a copy of the NR to be given to the establishment. 

While she is documenting the noncompliances, the establishment cleans the 

band saw and the underside of the boning tables. 

When she gives the NR to establishment management, the establishment 

requests that she remove the U.S. Rejected Tag from the band saw. She verifies 

that the band saw has been cleaned and removes the tag and verifies that the 

Inspection Methods 14-17 
 

 

□ □ 

□ □ 

□ □ 

Inspection Verification 

7/11/2018 

residue from previous days’ production has been removed from the underside of 

the boning tables. She also verifies that the establishment documented that it 

restored sanitary conditions in its records. Upon returning to the inspection office, 

she logs back into PHIS, documents the NR as “completed” and then documents 

the inspection task as “completed”.

PHIS Steps for this Example 

Activity Monday 

SSOP Task Initiate Complete 

NR Create Complete 

Noncompliance Add Finalize 

1 

2 

3 

5 

4 

6 

1. Initiate/claim the SSOP Task 

2. Create the NR 

3. Add Noncompliance (cite one or more Regulations) 

4. Finalize Noncompliance (print, sign, and provide) 

5. Complete the NR (after all verification performed/verifying return to 

compliance) 

6. Complete the SSOP Task (after all results entered) 

Inspection Methods 14-18 
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Attachment 1 

When documenting noncompliance on a Noncompliance Record (NR), a good 

method to follow is to determine the 6Ws (While, When, What, Where, Who, and 

Why) and then document the details for each one of the Ws. 

This is an example outline created using the 6W method. It is an organized way 

to gather facts and help prepare an NR. 

While 

While performing what inspection task? 

 Identify the scheduled inspection task 

 Provide brief summary of regulation(s) verified 

Example: 

“While verifying the construction requirement during the SPS 

verification task.....”, or “While verifying the monitoring requirement 

during the HACCP Raw Intact task......”

When 

When was the noncompliance discovered? 

 Date 

 Time 

 Operation status of the establishment 

When did the noncompliance begin? 

When has this noncompliance happened before? 

Example: 

While performing SSOP Pre-Op Review and Observation task on 8-

20-13 at 7:44 a.m., after the facility was released for inspection, I 

discovered... 

What 

What is the noncompliance? 

What were the exact conditions? 

 Adulterant/contaminant- number, size, shape, color, and 

consistency. 

 Environment- leaks, condensation, wall or floor quality. 

What documents or records were reviewed? 

What regulatory control actions were taken, if any? 

What action did the establishment take or propose? 

A detailed description helps paint a picture for the reader, and makes 

pertinent and relative facts of the findings clear. 

Example: 

In the northeast corner of the meat processing room, I observed three 

dried meat particles (1⁄4 inch by 1⁄4 inch) laying on the surface of the 

Inspection Methods 14-19 
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7/11/2018 

meat grinder’s knife assembly.

I reviewed the establishment’s pre-op sanitation records prior to my 

inspection; no sanitation failures were documented. 

Note: Words like filthy, dirty or scummy are not acceptable in 

describing noncompliant findings. The contamination must be 

accurately described with respect to size, shape and consistency, such 

as “2 inch by 5 inch smear of a black oily substance”, or 15 to 20 1/4 

inch to 1 inch pieces of fat. 

Where 

Specific location within the establishment? 

 A room 

 Area within a room 

 Outside 

Other locations affected by the noncompliance? 

Example: 

In the northeast corner of the meat processing room, I observed...

Who When a noncompliance is discovered, IPP have an obligation to 

immediately report it orally and then in writing to the establishment. 

Especially, when production is stopped and/or when meat, poultry or 

egg products are retained. 

Example: 

I immediately placed a U.S. Rejected Tag #B1234567 on the meat 

grinder and notified Ms. Rosenberg of the noncompliance and the 

reason for taking a regulatory control action. 

Why 

Why is there noncompliance? 

What regulations were not met? 

 Regulation A 

 Regulation B 

What procedure, plan or program was the establishment not following 

(e.g., Sanitation SOP, HACCP plan, or prerequisite program)? 

Example: 

I explained to Ms. Rosenberg, QC Manager, Quality Beef Co., that 

Quality Beef Co. is not following its Sanitation SOP dated on 

(4/20/2015), and signed by Sam Smith as written. 

Furthermore, it states on page 3, Section I-Pre-op Sanitation: “We will 

clean and sanitize all equipment before the start of meat processing 

operations.” 

Lastly, I explained to Ms. Rosenberg the establishment is not meeting 

FSIS Regulation 416.13(a). 

Inspection Methods 14-20