UnitedStates 

Department of 

Agriculture 

Modernization of Poultry Slaughter Inspection 

Analysis of Specified Offline Tasks 

for Establishments Converting to the 

New Poultry Inspection System 

Food Safety and Inspection Service 

Office of Planning, Analysis and Risk Management 

September 30, 2019 
 

 

Modernization of Poultry Slaughter Inspection - Analysis of Specified Offline Tasks for 

Establishments Converting to the New Poultry Inspection System 

TABLE OF CONTENTS 

Executive Summary...................................................................................................................3 

I. Purpose ..................................................................................................................................4 

II. Introduction/Background ......................................................................................................4 

III. Methodology........................................................................................................................6 

Data Used............................................................................................................................ 6 

IV. Results and Discussion ........................................................................................................6 

Task Analysis...................................................................................................................... 6 

Noncompliance Analysis .................................................................................................... 8 

V. Conclusion ............................................................................................................................9 

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Modernization of Poultry Slaughter Inspection - Analysis of Specified Offline Tasks for 

Establishments Converting to the New Poultry Inspection System 

LIST OF TABLES 

Table 1 - List of Tasks Reviewed ................................................................................................... 5 

Table 2 – Selected Total Offline Tasks Performed Before and After Conversion to NPIS for 72 

Formerly Non-HIMP Establishments ............................................................................................. 6 

Table 3 – Selected Total Offline Tasks Performed by Aggregate Percentage Increase after NPIS 

Conversion for 72 Formerly Non-HIMP Establishments ............................................................... 7 

Table 4 - Total NRs and Noncompliance Percent for Selected Offline Tasks Three Months 

Before and After NPIS Conversion ................................................................................................ 8 

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Modernization of Poultry Slaughter Inspection - Analysis of Specified Offline Tasks for 

Establishments Converting to the New Poultry Inspection System 

Executive Summary 

The final rule to modernize poultry slaughter inspection was published on August 21, 2014 

and went into effect on October 20, 2014. This rule established an additional inspection 

system called the New Poultry Inspection System (NPIS) for young chicken and all turkey 

slaughter establishments. NPIS allows Food Safety and Inspection Service (FSIS) inspectors 

to perform more offline inspection activities that are focused on ensuring food safety, while 

providing for more efficient and effective online carcass-by-carcass inspection. This is 

achieved by permitting establishment personnel to sort carcasses and remove unacceptable 

carcasses and parts before the birds are presented to FSIS for carcass inspection and 

assigning one inspector to perform the online carcass inspection (CI) duties and one to 

perform offline verification inspection (VI) activities for each evisceration line. 

This analysis includes 72 formerly non-HIMP (HACCP-Based Inspection Models Project) 

establishments that converted to NPIS, using Public Health Information System (PHIS) 

inspection task data from May 2015 to April 2019. Specifically, it examines eleven food 

safety-related offline tasks 30 to 120 days1 before and 30 to 120 days after each 

establishment’s NPIS conversion date to determine if the number of completed tasks 

increased as expected. This report shows that inspectors consistently completed a higher 

number of selected food safety-related offline inspection tasks, including the new NPIS 

inspection tasks after NPIS implementation, as expected. Two new tasks, NPIS Zero 

Tolerance Food Safety Verification and NPIS Poultry Ready-to-Cook were developed for 

offline Consumer Safety Inspectors (CSIs) to verify requirements. The NPIS Zero Tolerance 

Food Safety Verification task replaces the Poultry Zero Tolerance verification task, which 

was in effect prior to NPIS for these establishments. 

Overall, this analysis shows, as expected, that the new 15J NPIS Zero Tolerance Food Safety 

Verification task is being performed at or near four times more often after NPIS conversion 

as compared to the pre-NPIS 03J04 Poultry Zero Tolerance Verification task. 

The Noncompliance Records (NRs) for these zero tolerance verification tasks more than 

tripled in conjunction with the increase in tasks performed, indicating the new policy was 

effective in consistently detecting and correcting food safety issues under NPIS. The overall 

rate of Noncompliance (NC) for these tasks was slightly lower after NPIS conversion in the 

aggregate, with variations in the NC rate among establishments. 

Performance of all other analyzed offline tasks increased from 4% to 40%2 for the specific 

inspection tasks reviewed. This is one of the main purposes of NPIS, namely to make more 

1 For each NPIS establishment reviewed, a 30-day window was first determined before and after the NPIS 

conversion date and data from this window were excluded from the analysis to allow for an adjustment period 

for NPIS implementation. Inspection results were then reviewed for the 90-day period before and after the 30 

day before and after window. 2 The increase for 03J02 Slaughter HACCP tasks was 83%, but there were two establishments that had an 

inflated number of tasks due to a recording error. When these outliers were removed, there was a 40% increase 

for 03J02 Slaughter HACCP tasks. 

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Modernization of Poultry Slaughter Inspection - Analysis of Specified Offline Tasks for 

Establishments Converting to the New Poultry Inspection System 

time available for performing other offline tasks within the establishment. There were 

increases in NRs for the additional offline tasks as well. 

I. Purpose 

The purpose of the analysis described in this report is to review and assess establishments 

that have converted to NPIS and to determine whether specific offline Public Health 

Information System (PHIS) inspection tasks, including the new NPIS zero tolerance task, 

were performed more frequently after conversion to NPIS, as expected. Noncompliance 

totals and rates were also compared before and after NPIS conversion. 

II. Introduction/Background 

The final rule to modernize poultry slaughter inspection was published on August 21, 2014 

and went into effect on October 20, 2014. This rule established NPIS for young chicken and 

all turkey slaughter establishments. NPIS requires that establishment personnel sort carcasses 

and remove unacceptable carcasses and parts before the birds are presented to the FSIS 

carcass inspector. This allows shifting of agency resources to conduct more offline inspection 

activities that are more effective in ensuring food safety. Specifically, under NPIS, one 

inspector is assigned to perform online carcass inspection (CI) duties, and one inspector is 

assigned to perform offline verification inspection (VI) duties for each evisceration line. 

Additionally, the Finished Product Standards (FPS) used in establishments continuing to 

operate under the Streamlined Inspection System (SIS), New Line Speed Inspection System 

(NELS), and New Turkey Inspection System (NTIS), are replaced with a requirement that 

establishments maintain records to document that the products resulting from their slaughter 

operations meet the definition of ready-to-cook (RTC) poultry. 

By assigning an offline inspector to each evisceration line, inspectors are able to complete a 

higher number of offline inspection tasks. Previously, one offline inspector covered multiple 

evisceration lines. Two new offline tasks, NPIS Zero Tolerance Food Safety Verification and 

NPIS Poultry Ready-to-Cook were developed for offline CSIs to verify requirements. The 

NPIS Zero Tolerance Food Safety Verification task replaces the Poultry Zero Tolerance 

verification, which was pre-NPIS for these establishments. This new zero tolerance task is 

expected to be performed once per hour in an eight-hour shift per evisceration line, compared 

to just twice in an eight-hour shift per evisceration line with the other inspection systems. 

The NPIS Poultry Ready-to-Cook task replaces the FPS verification for establishments 

operating under NPIS and is scheduled once per month as a routine task. This routine task is 

primarily a records check of the establishment to ensure that poultry RTC procedures are 

being performed as required. There is an option to perform additional tasks as needed if 

assigned by the Public Health Veterinarian (PHV), Inspector in Charge (IIC) or designee. 

Under NPIS, each offline inspector is to pull 10 birds off the line prior to the online carcass 

inspector each hour to verify that the establishment meets the zero tolerance standard for 

visible fecal material, and for Septicemia and Toxemia (Sep/Tox) using the NPIS Zero 

Tolerance Food Safety Verification task. Thus, during an 8-hour shift, 80 birds are to be 

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Modernization of Poultry Slaughter Inspection - Analysis of Specified Offline Tasks for 

Establishments Converting to the New Poultry Inspection System 

checked, compared to only 20 birds under prior non-HIMP systems in an 8-hour shift for 

each evisceration line. This is one of the key offline tasks which is reviewed with respect to 

frequency before and after NPIS conversion. 

This analysis provides a review of inspection results for establishments that have converted 

to NPIS for specific food safety-related tasks 30 to 120 days before and 30 to 120 days after 

the NPIS conversion date to determine if the expected frequency is occurring for the NPIS 

Zero Tolerance Food Safety Verification task and to see if there is a general increase in other 

selected food safety-related offline tasks as expected for NPIS establishments. The final rule 

establishing NPIS 3 states that it is designed to facilitate pathogen reduction in poultry 

products by shifting Agency resources to allow FSIS inspectors to perform more offline 

inspection activities that are more effective in ensuring food safety, while providing for a 

more efficient and effective online carcass-by-carcass inspection. 

The tasks that were reviewed as part of this analysis are listed in Table 1. The sanitation 

tasks (SSOP) and HACCP tasks included in this list were identified as key offline tasks that 

are more effective in ensuring food safety as outlined in the final rule, and these are expected 

to increase with NPIS. The other tasks assessed include pre-NPIS and post-NPIS Zero 

Tolerance, Poultry Finished Products Standards, NPIS Poultry Ready-to-Cook, and Poultry 

Good Commercial Practices. 

Table 1 - List of Tasks Reviewed4 

Inspection 

Task Code Inspection Task Name Description 

01B02 Pre-Op SSOP Review and Observation 

Review the establishment's SSOP and become familiar with the 

procedures 

01C01 Operational SSOP Record Review Verify operational SSOP records 

01C02 Operational SSOP Review and Observation Verification of the establishment's operational SSOP 

01D03 Poultry Sanitary Dressing Verification of sanitary dressing in poultry slaughter 

03A04 Review of Establishment Data Weekly review of establishment data per Directive 5000.2 

03J02 Slaughter HACCP 

Verification of all 5 HACCP regulatory requirements through the 

review/observation and recordkeeping components 

03J04 Poultry Zero Tolerance Verification 

Verifcation of zero tolerance for feces on poultry carcasses entering 

chilling system 

04A06 Poultry Finished Product Standards 

Verify poultry products are produced in a safe, wholesome manner 

and not misbranded 

04C05 Poultry Good Commercial Practices Poultry Good Commercial Practices 

15A06 NPIS Poultry Ready-to-Cook Ready to Cook Task for NPIS establishments 

15J NPIS Zero Tolerance Food Safety Verification 

Verification of zero tolerance for feces in NPIS system 

establishments 

3 Department of Agriculture, Food Safety and Inspection Service, 9CFR Parts 381 and 500, Modernization of Poultry Slaughter Inspection; 

Final Rule, Federal Register Vol. 79 No. 162, August 21, 2014. 

4 This includes the Poultry Sanitary Dressing task, which has subsequently been discontinued as of 11/28/2016 as described in Directive 

6420.5, Verifying Poultry Slaughter Establishments Maintain Adequate Procedures for Preventing Contamination with Feces and Enteric 

Pathogens (Oct 17, 2016). 

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Modernization of Poultry Slaughter Inspection - Analysis of Specified Offline Tasks for 

Establishments Converting to the New Poultry Inspection System 

III. Methodology 

Change in the number of tasks completed is calculated to determine the level of increase or 

decrease after conversion to NPIS. A four-fold increase in the new NPIS Zero Tolerance 

Food Safety Verification tasks is generally expected for establishments converting from a 

traditional system to NPIS and “no change” for zero tolerance tasks is generally expected 

for HIMP plants converting to NPIS. The other offline inspection tasks reviewed are 

expected to increase following establishment conversion to NPIS, but not by a specified 

factor. As such, the analysis of zero tolerance and other selected offline inspection tasks is 

limited to establishments that converted from non-HIMP to NPIS. 

Data Used 

For this review, FSIS extracted inspection data from PHIS for the specific tasks outlined in 

Table 1. The data elements used for this project were extracted for the period May 2015 

through April 2019 for 72 NPIS establishments that were formerly non-HIMP and converted 

to NPIS. In addition, PHIS task information for 30 days prior and 30 days after the NPIS 

conversion date for each establishment was excluded in various calculations to mitigate 

effects of data variation during the NPIS transition period. 

IV. Results and Discussion 

Task Analysis 

The inspection results summary for the NPIS establishments that were formerly non-HIMP 

as of January 2019 are presented in Table 2. The table illustrates the overall totals for each 

Table 2 – Selected Total Offline Tasks Performed Before and After Conversion to 

NPIS for 72 Formerly Non-HIMP Establishments 

Inspectio 

n Task 

Code Task Name 

Total Tasks 

3 Months 

Pre NPIS 

Total 

Tasks 3 

Months 

Post NPIS 

Ratio 

Post 

NPIS 

Pre NPIS 

03J04 Poultry Zero Tolerance Verification 36,948 247 n/a 

15J NPIS Zero Tolerance Food Safety 

Verification 0 141,429 3.83* 

04A06 Poultry Finished Product Standards 44,030 70 n/a 

15A06 NPIS Poultry Ready-to-Cook 0 492 0.01** 

01B02 Pre-Op SSOP Review and Observation 2,053 2,327 1.13 

01C01 Operational SSOP Record Review 4,761 5,577 1.17 

01C02 Operational SSOP Review and 

Observation 6,743 8,018 1.19 

01D03 Poultry Sanitary Dressing 358 443 1.24 

03A04 Review of Establishment Data 1,648 1,757 1.07 

03J02 Slaughter HACCP 3,993 7,291 ***1.83 

04C05 Poultry Good Commercial Practices 9,368 9,703 1.04 

*Ratio Zero Tolerance = NPIS Zero Tolerance Food Safety Verification (15J)/Poultry Zero Tolerance Verification (03J04) 

**Ratio NPIS Poultry Ready-to-Cook = NPIS Poultry Ready-to-Cook (15A06)/Poultry Finished Product Standards (04A06) 

***Two establishments were outliers with very high task totals - without these two establishments the ratio is 1.40 

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Modernization of Poultry Slaughter Inspection - Analysis of Specified Offline Tasks for 

Establishments Converting to the New Poultry Inspection System 

task type, as well as a ratio of the Post-NPIS/Pre-NPIS tasks, which provides a measure of 

the increase in task frequency, as applicable. 

The area highlighted in green in Table 2 depicts the tasks that include the 10-bird checks, 

specifically Poultry Zero Tolerance Verification (03J04 prior to NPIS), and NPIS Zero 

Tolerance Food Safety Verification (15J after NPIS conversion). This task was expected to 

increase four-fold after NPIS conversion assuming the same levels of production before and 

after. As Table 2 illustrates, the NPIS Zero Tolerance Food Safety Verification Task overall 

for these establishments was performed about 4 (3.83) times more after NPIS conversion, as 

expected, in the aggregate (36,948 pre NPIS / 141,429 post NPIS). 

The Poultry Finished Product Standards task, highlighted in blue in Table 2 and included 

with tasks performed prior to NPIS conversion, is not applicable under NPIS as the 

establishment assumes the responsibility to ensure poultry is ready-to-cook; this explains the 

major decrease in this task performed post NPIS. The NPIS Poultry Ready-to-Cook task is a 

new task that replaces the Poultry Finished Product Standards task. This task is scheduled 

once per month as a routine task. The routine task is primarily a records check to ensure that 

poultry ready-to-cook procedures are being performed by the establishment as required. 

There is an option to perform additional NPIS Poultry Ready-to-Cook tasks as needed if 

assigned by the PHV, IIC or designee. 

As Table 2 illustrates, the Slaughter HACCP task almost doubled pre and post NPIS 

conversion, however, this total was heavily influenced by two establishments. Follow up by 

District Office management responsible for those two establishments, which were both in the 

same circuit, revealed that Inspection Program Personnel (IPP) were recording inspection of 

parts as individual tasks which led to the completion of unnecessary tasks. When these two 

establishments are removed from the ratio calculation, post-NPIS totals for 03J02 (Slaughter 

HACCP) are 1.40 when compared to pre-NPIS (3,844 pre-NPIS/5,368 post-NPIS). 

A summary of the percentage change in the number of offline tasks performed in the 30-120 

day period after NPIS conversion by task is shown in Table 3. All Sanitation Standard 

Operating Procedures (SSOP) tasks increased, with tasks 01B02 Pre-Op SSOP Review and 

Observation (+13%), 01C01 Operational SSOP Record Review (+17%), and 01C02 

Operational SSOP Review and Observation (+19%) having considerable increases. The 

Table 3 – Selected Total Offline Tasks Performed by Aggregate Percentage Increase after 

NPIS Conversion for 72 Formerly Non-HIMP Establishments 

PHIS Task 

Code Task Name Percent Increase 

01B02 

01C01 

01C02 

01D03* 

03J02** 

04C05 

Pre-Op SSOP Review and Observation 

Operational SSOP Record Review 

Operational SSOP Review and Observation 

Poultry Sanitary Dressing 

Slaughter HACCP 

Poultry Good Commercial Practices 

+13% 

+17% 

+19% 

+24% 

+83% 

+4% 

* Task discontinued 11/2016 

**Two establishments were outliers with very high totals - without these two there is a 40% increase 

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Modernization of Poultry Slaughter Inspection - Analysis of Specified Offline Tasks for 

Establishments Converting to the New Poultry Inspection System 

03J02 Slaughter HACCP tasks increased by the highest amount (+83%) but had two heavily 

influencing establishments as mentioned earlier. Removing these two establishments from 

the equation, the increase was smaller but remained the highest (+40%). 

Noncompliance Analysis 

A Noncompliance Record (NR) is a written record that documents noncompliance with 

FSIS regulations. The Noncompliance (NC) rate is the number of completed tasks with at 

least one noncompliance divided by the number of completed tasks. The total NRs and NC 

rate for all establishments for the offline tasks reviewed are given in Table 4. 

Table 4 - Total NRs and Noncompliance Percent for Selected Offline Tasks Three 

Months Before and After NPIS Conversion 

Inspection 

Task Code Task Name 

Total NRs 

3 Months 

Pre-NPIS 

Total NRs 

3 Months 

Post-NPIS 

Total 

NC% 3 

Months 

Pre-NPIS 

Total 

NC% 3 

Months 

PostNPIS 

01B02 Pre-Op SSOP Review and Observation 627 677 23.48 22.58 

01C01 Operational SSOP Record Review 45 97 0.94 1.71 

01C02 Operational SSOP Review and Observation 958 1,464 12.48 15.49 

01D03 * Poultry Sanitary Dressing 8 8 2.20 1.78 

03A04 Review of Establishment Data 0 4 n/a 0.23 

03J02 Slaughter HACCP 257 231 6.09 3.08 

03J04 Poultry Zero Tolerance Verification 381 1 1.02 0.40 

04A06 Poultry Finished Product Standards 226 2 0.51 2.78 

04C05 Poultry Good Commercial Practices 9 3 0.10 0.03 

15A06 NPIS Poultry Ready-to-Cook 0 71 12.72 

15J NPIS Zero Tolerance Food Safety 

Verification 0 1,238 0.87 

*Task 01D03 Poultry Sanitary Dressing was discontinued 11/2016 

Areas highlighted in green and yellow represent NPIS poultry zero tolerance task NR counts and NC rate 

As shown in Table 4, for 01B02 Pre-Op SSOP Review and Observation tasks post-NPIS 

conversion, there was an increase in NR counts from 627 to 677, but a slight decrease in the 

NC rate from 23.48% to 22.58%. The count for 01C01 Operational SSOP Record Review 

NRs more than doubled from 45 to 97, and the NC rate was close to double from 0.94% to 

1.71%. This indicates increased activity and identification of noncompliant situations, which 

likely stems from the increased time available for IPP to perform these tasks. 

The number of NRs for 01C02 Operational SSOP Review and Observation increased in 

count from 958 to 1,464, and the NC rate increased from 12.48% to 15.49%. This is also a 

clear indication that more of these tasks were performed by IPP and more NRs were written 

based upon the period of time reviewed. The 03J02 Slaughter HACCP task NRs decreased 

from 257 to 231, and the NC rate for 03J02 Slaughter HACCP shows a reduction from 

6.09% to 3.08%. As noted earlier there were larger numbers of the 03J02 Slaughter HACCP 

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Modernization of Poultry Slaughter Inspection - Analysis of Specified Offline Tasks for 

Establishments Converting to the New Poultry Inspection System 

tasks recorded as performed in error by two establishments which inflated the post-NPIS 

totals. When removing these two establishments from the post-NPIS totals for the 03J02 

Slaughter HACCP task, there were 5,368 tasks with 218 NRs for a post-NPIS NC rate of 

4.06%. 

The pre-NPIS conversion 04A06 Poultry Finished Product Standards (FPS) task was 

performed 44,030 times (typically twice daily in non-HIMP establishments) during the time 

period included in this analysis, and generated 226 NRs with a noncompliance rate of 

0.51%. The 04A06 FPS task is designed for inspectors to verify that the slaughter and 

evisceration process is under control and is accomplished by IPP examining ten-bird sample 

sets to determine compliance with the FPS. The post NPIS conversion 15A06 NPIS Poultry 

Ready-to-Cook task is scheduled once per month as a routine task, was performed 492 times 

during the time period included in this analysis, and generated 71 NRs with a 

noncompliance rate of 12.72%. Under the 15A06 task, FSIS inspectors verify that an 

establishment is producing RTC poultry by reviewing establishment records documenting 

that the products resulting from their slaughter operation meet the definition of RTC poultry 

and by observing carcasses as part of their inspection activities. 

The largest increase in NR totals pre and post NPIS conversion were in the zero tolerance 

task NRs, which increased from 381 (03J04 Poultry Zero Tolerance Verification) to 1,238 

(15J NPIS Zero Tolerance Food Safety Verification), just over three times more NRs. This 

is a clear indication that the increased zero tolerance tasks are resulting in consistent 

documentation of NRs. The NC rate decreased slightly from 1.02% pre-NPIS conversion to 

0.87% post-NPIS conversion for the zero tolerance tasks. 

V. Conclusion 

With the implementation of NPIS, offline tasks completed are expected to increase as an 

offline inspector is assigned to each evisceration line, and these inspectors are required to 

complete a higher number of offline inspection tasks. Previously, one inspector covered 

multiple evisceration lines, which limited the amount of time available to the inspector to 

complete offline tasks. 

The review of selected offline tasks 30-120 days before and 30-120 days after a previously 

non-HIMP establishment’s conversion to NPIS shows that the expected increase in frequency 

of tasks is occurring in the key task, 15J NPIS Zero Tolerance Food Safety Verification. This 

indicates the new policy is being implemented effectively in terms of the number of tasks 

(10-bird checks) performed. In addition, the NRs for this task increased nearly 

proportionately in the aggregate in conjunction with the added tasks, indicating the new 

policy was effective in consistently detecting and correcting food safety issues under NPIS. 

The NC rate for these zero tolerance tasks decreased slightly. 

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Modernization of Poultry Slaughter Inspection - Analysis of Specified Offline Tasks for 

Establishments Converting to the New Poultry Inspection System 

The other offline tasks increased overall as well, from 4% to 40%5 for the specific inspection 

tasks reviewed. There were two establishments that performed a higher number of 03J02 

Slaughter HACCP tasks, and follow up with the District Office responsible for these two 

establishments showed this was due to a recording error. Further review showed that 

adequate corrections were subsequently made by IPP at these two establishments in the 

performance of the tasks. The NC rate and number of NRs for the 03J02 Slaughter HACCP 

tasks decreased while the number of tasks increased. 

The number of NRs increased for all of the SSOP tasks. The NC rate increased for 

Operational Record Review as well for Operational SSOP review and Observation and 

decreased slightly for Pre-Operational SSOP review and Observation. 

5 The increase for 03J02 Slaughter HACCP tasks was 83%, but there were two establishments that had an 

inflated number of tasks due to a recording error. When these outliers were removed, there was a 40% increase 

for 03J02 Slaughter HACCP tasks. 

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