Evaluation of HACCP Inspection

Models Project (HIMP) for Market Hogs

United States Department of Agriculture

Food Safety and Inspection Service

Final Report

November 2014

1
Table of Contents

SUMMARY.................................................................................................................................... 5

1.0 INTRODUCTION .................................................................................................................... 8

2.0 DESCRIPTION OF HIMP AND NON-HIMP MARKET HOG ESTABLISHMENTS ....... 11

2.1 Inspection in HIMP and Non-HIMP Market Hog Establishments..................................... 11

2.2 Line Speed Estimation ........................................................................................................ 12

3.0 RESULTS ............................................................................................................................... 13

3.1 Verification that the Establishment is Executing its HIMP Slaughter Process Control Plan 

(PCP) whereby Establishment Employees Sort Acceptable and Unacceptable Carcasses and 

Parts........................................................................................................................................... 13

3.1.1 Number of Off-line FSIS Verification Inspection Procedures per Establishment Under 

PBIS ...................................................................................................................................... 13

3.1.2 Number of Off-line FSIS Verification Inspection Procedures for HACCP and 

Sanitation SOP per Establishment Under PHIS.................................................................... 14

3.1.3 FSIS Condemnation Rates and HIMP Establishment Sorting Disposition Rates........ 20

3.2 Verification of the Establishment Executing its Sanitation SOPs and its HACCP System 21

3.2.1 Off-line Inspection Procedures Performed .................................................................. 21

3.2.2 Public Health Noncompliance Rates ........................................................................... 22

3.2.3 Postmortem Food Safety Disease Conditions (FS-1) .................................................. 26

3.2.4 Fecal Material, Ingesta, and Milk Contamination (FS-2)............................................ 27

3.2.5 Ante-Mortem Inspection (FS-3) .................................................................................. 28

3.3 Verification of the Outcomes of the Establishment Slaughter HACCP and Process Control 

Plans, Both Organoliptic and Microbiologic ............................................................................ 28

3.3.1 Food Safety Performance Standards............................................................................ 28

3.3.2 Other Consumer Protection Performance Standards ................................................... 29

3.3.3 Salmonella Positive Rates............................................................................................ 30

3.3.4 Chemical Residue Sampling........................................................................................ 32

4.0 CONCLUSION....................................................................................................................... 34

5.0 REFERENCES ....................................................................................................................... 36

6.0 APPENDIX............................................................................................................................. 37

Appendix A-Differences Between PBIS and PHIS Information Systems................................ 37

Appendix B- Description of PBIS Inspection Task Codes....................................................... 39

Appendix C: Regulations Descriptions for Market Hog Establishments ................................. 41

Appendix D: HIMP Market Hog Performance Standards........................................................ 44

Appendix E: Inspection Procedures Performed per Establishment in HIMP and Non-HIMP 

Market Hog Establishments Under PBIS CY2006 through CY2009....................................... 45

2
List of Figures and Tables

Figure 2-1 Flowchart of the HIMP Market Hog Inspection Systems........................................... 11

Table 3- 1 Number of Inspection Procedures Performed per Establishment in HIMP and NonHIMP Market Hog Establishments Under PBIS in CY2010........................................................ 14

Table 3- 2 Number of Mandatory Regulation Verifications per Establishment in HIMP and NonHIMP Market Hog Establishments for CY2012........................................................................... 15

Table 3- 3 Number of Mandatory Regulation Verifications per Establishment in HIMP and NonHIMP Market Hog Establishments for CY2013........................................................................... 16

Table 3- 4 Number of Public Health-Related Regulations Verified per Establishment in HIMP 

and Non-HIMP Market Hog Establishments for CY2012............................................................ 18

Table 3- 5 Public Health-Related Regulations Verified per Establishment in HIMP and NonHIMP Market Hog Establishments for CY2013........................................................................... 19

Table 3- 6 Sorting and Condemnation Rates for HIMP and Non-HIMP Market Hog 

Establishments for CY2006 to CY2010 ....................................................................................... 21

Table 3- 7 Sorting and Condemnation Rates for HIMP and Non-HIMP Market Hog 

Establishments for CY2012 and CY2013..................................................................................... 21

Table 3- 8 Average CY2006-CY2010 W3NR Noncompliance Rates for HIMP and Non-HIMP 

Market Hog Establishments.......................................................................................................... 23

Table 3- 9 SSOP and HACCP Public Health (PHR) Noncompliance Rates for HIMP and NonHIMP Market Hog Establishments for CY2012........................................................................... 24

Table 3- 10 SSOP and HACCP PHR Noncompliance Rates for HIMP and Non-HIMP Market 

Hog Establishments for CY2013 .................................................................................................. 25

Table 3- 11 Noncompliance Rates for Food Safety Disease Conditions (FS-1) at HIMP Market 

Hog Establishments for CY2006 to CY2010................................................................................ 26

Table 3- 12 Noncompliance Rates for Fecal Material, Ingesta, and Milk Conditions at HIMP and 

Non-HIMP Comparison Establishments ...................................................................................... 27

Table 3- 13 Noncompliance Rates for Fecal Material, Ingesta, and Milk Conditions at HIMP and 

Non-HIMP Market Hog Establishments for CY2012 and CY2013 ............................................. 27

Table 3- 14 Ante-Mortem 9 CFR Part 309 Noncompliance Rates at HIMP Market Hog 

Establishments.............................................................................................................................. 28

Table 3- 15 Achievement of Food Safety Performance Standards at HIMP Market Hog 

Establishments.............................................................................................................................. 29

Table 3- 16 Achievement of OCP Performance Standards at HIMP Market Hog Establishments 

for CY2009 - CY2010 and CY2012 – CY2013............................................................................ 30

Table 3- 17 Salmonella Percent Positive Rates for HIMP and Non-HIMP Market Hog 

Establishments.............................................................................................................................. 31

Table 3- 18 Salmonella Positive Rate from Market Hog Baseline Study (August 2010-August 

2011) ............................................................................................................................................. 32

Table 3- 19 Directed Residue Samples at HIMP and Non-HIMP Market Hog Establishments .. 32

Table 3- 20 Inspector Generated Sampling at HIMP and Non-HIMP Market Hog Establishments 

CY2009 - CY2013 ........................................................................................................................ 33

Table B- 1 PBIS Procedure Codes And Procedure Code Descriptions........................................ 39

Table B- 2 PHIS Inspection Task Code Description .................................................................... 40

3
Table C- 1 Mandatory Regulations for Market Hog Establishments ........................................... 41

Table C- 2 Public Health Regulations (PHRs) for Market Hog Establishments.......................... 42

Table D- 1 Market Hog Performance Standards for HIMP Market Hog Establishments............ 44

Table E- 1 Inspection Procedures Performed per Establishment in HIMP and Non-HIMP Market 

Hog Establishments Under PBIS in CY2006 ............................................................................... 45

Table E- 2 Inspection Procedures Performed per Establishment in HIMP and Non-HIMP Market 

Hog Establishments Under PBIS in CY2007 ............................................................................... 46

Table E- 3 Inspection Procedures Performed per Establishment in HIMP and Non-HIMP Market 

Hog Establishments Under PBIS in CY2008 ............................................................................... 47

Table E- 4 Inspection Procedures Performed per Establishment in HIMP and Non-HIMP Market 

Hog Establishments Under PBIS in CY2009 ............................................................................... 48

4
SUMMARY

The objective of this report is to evaluate Food Safety and Inspection Service (FSIS) inspection 

findings in market hog slaughter establishments participating in the Hazard Analysis and Critical 

Control Point (HACCP) Inspection Models Project (HIMP) and determine whether the HIMP 

inspection system is performing as well as the existing inspection system in terms of safety and 

wholesomeness of hog slaughter and overall consumer protection. The evaluation is based on 

two time periods: the years CY2006 - CY2010 and the years CY2012 - CY2013. (The year 

CY2011 was a transition year for FSIS information systems and will not be considered). The 

evaluation compares the 5 HIMP market hog establishments with a set of 21 non-HIMP market 

hog slaughter establishments selected to be comparable with HIMP market hog establishments 

with respect to production volume, line speed, and days of slaughter operation. The FSIS 

inspection findings are assessed across three interrelated inspection activities:

1. Verification, by off-line inspectors, of the establishment’s execution of its HIMP 

slaughter Process Control Plan (PCP), under which establishment employees sort out 

unacceptable carcasses and parts.

2. Verification by off-line inspectors of the establishment executing its Sanitation Standard 

Operating Procedures (Sanitation SOP) and its HACCP plans under 9 CFR Parts 416 and 

417.

3. Verification of the outcomes of the establishment HACCP and process control plans, 

both organoleptic and microbiologic

A summary of results follows:

1. Verification, by off-line inspectors, of the establishment’s execution of its HIMP 

slaughter Process Control Plan (PCP), under which establishment employees sort 

out unacceptable carcasses and parts.

Under HIMP, employees of slaughter establishments sort animals at ante- and postmortem prior to FSIS inspection. The rate of ante- and post-mortem sorting by HIMP 

establishment employees and condemnation by FSIS inspectors at non-HIMP market hog 

establishments are comparable (3.0 per 1,000 hogs versus 2.7 per 1,000 hogs, 

respectively). FSIS inspectors perform off-line inspection procedures in HIMP market 

hog establishments to verify that the establishments are executing their HIMP slaughter 

PCP. FSIS inspectors performed an average of 2,061 off-line verification inspections per 

HIMP market hog establishment in CY2010 versus an average of 1,482 off-line

verification inspections per non-HIMP establishment. Overall, FSIS inspectors perform 

1.4 times more off-line verification inspection procedures in HIMP market hog 

establishments than in non-HIMP market hog establishments and 1.5 times more 

Sanitation SOP and HACCP verification inspection procedures. This increased level of 

inspection provides increased assurance that HIMP market hog establishments are 

satisfying HACCP regulations and producing a wholesome and safe product.

5
2. Verification by off-line inspectors of the establishment executing its Sanitation 

Standard Operating Procedures (Sanitation SOP) and its HACCP plans under 9 

CFR Parts 416 and 417

FSIS inspectors conduct off-line inspection procedures in HIMP market hog

establishments to verify that they are complying with Sanitation SOP and HACCP 

regulations and designated performance standards for Food Safety (FS), Other Consumer 

Protection (OCP) defects, and pathogen levels. FSIS inspectors ensure that each 

establishment is complying with federal regulations and is operated and maintained in a 

manner sufficient to prevent the creation of insanitary conditions and to ensure that 

product is not adulterated. This report finds that under HIMP, market hog establishments

are receiving an increased level of Sanitation SOP and HACCP inspections. The 

assumption is made that the number of inspection tasks performed per establishment is

correlated with production of a safe product. The FSIS risk assessments on poultry 

slaughter (FSIS 2008, 2012, 2014) found that more off-line procedures were associated 

with lower Salmonella and Campylobacter prevalence and an increase in public illnesses 

avoided.

SSOP and HACCP Off-line Inspections

o In CY2010, FSIS inspectors performed 1.5 times more off-line Sanitation SOP

and HACCP inspection verifications of public health-related regulations 

(W3NRs) in HIMP than non-HIMP market hog establishments. 

o In CY2012 and CY2013, FSIS inspectors performed 1.1 times more off-line

Sanitation SOP and HACCP inspection verifications of public health-related 

regulations (PHRs) in HIMP than non-HIMP market hog establishments. 

o Although there are more 9 CFR 416 verifications and fewer 9 CFR 417 verifications in 

HIMP, both verifications are considered to address food safety issues and carry the same 

regulatory weight when enforcement actions are initiated.

SSOP and HACCP Regulatory Noncompliances

o In CY2006-CY2010, public health-related (W3NR) noncompliance rates of 

Sanitation SOP and HACCP regulations were 1.2 times higher in HIMP than nonHIMP market hog establishments. This difference is statistically significant.

o In CY2010 and CY2013, public health-related (PHR) noncompliance rates of 

Sanitation SOP and HACCP regulations were 1.1 times higher in non-HIMP than 

HIMP market hog establishments. Both differences are statistically significant.

3. Verification of the outcomes of the establishment HACCP and process control plans, 

both organoleptic and microbiologic

Before beginning HIMP, FSIS developed Food Safety (FS) and Other Consumer 

Protection (OCP) performance standards that market hog establishments must meet (FSIS 

6
2000, Cates et al 20011

). To ensure that HIMP market hog establishments are complying 

with FS and OCP performance standards, FSIS has increased the number of daily off-line

verifications of market hog carcasses from 11 per line in non-HIMP market hog 

establishments to 24 per line in HIMP market hog establishments. For this report, FSIS 

requested that the District Offices provide the paper records stored at individual facilities 

that inspectors keep on FS and OCP for in-plant inspections for the two periods CY2009-

CY2010 and CY2012-CY2013. The request was limited to these two time periods so as 

to limit the impact on field personnel and because it is believed that two years of data 

from before PHIS are sufficient to develop conclusions on FS and OCP.

HIMP Food Safety Performance

o Food safety conditions for systemic diseases in carcasses such as toxemia or

septicemia (FS-1 defects) in HIMP market hog establishments, which were below 

1 per 10 thousand carcasses in CY2009-CY2010, are below 3 in 100 thousand in 

CY2012-CY2013.

o Carcass contamination with fecal material, ingesta, and milk (FS-2 defects) in 

HIMP market hog establishments, was below 6 per 10 thousand carcasses in

CY2009-CY2010. For CY2012-CY2013, fecal material, ingesta, and milk defects 

are below 5 per 10 thousand carcasses.

o Food safety conditions from systemic disease in live animals such as neurologic 

conditions (FS-3), found at ante-mortem were zero in CY2009-CY2010 and are 

less than 1 in 10 thousand for CY2012-CY2013.

HIMP Other Consumer Protection Performance

o Other Consumer Protection Conditions due to localized disease in carcasses such 

as arthritis (OCP-1 defects), cystic kidneys (OCP-2 defects), and bruise (OCP-3

defects) found at postmortem in HIMP market hog establishments are all less than 

one-half their OCP performance standards on average.

Salmonella Testing Results

In July 2011, FSIS discontinued collecting Salmonella verification samples of carcasses

in calves/bulls, steers/heifers and market hog slaughter classes. For the years CY2006 –

CY2009, the Salmonella positive rates in HIMP market hog establishments were lower 

than those in non-HIMP comparison establishments but were higher in CY2010. The 

differences are not statistically significant for any of the years.

FSIS conducted a Salmonella baseline study on hog slaughter establishments during the 

thirteen month period August 2010 to August 2011. The program was designed to 

estimate the national prevalence of Salmonella in market hogs. The final sampling frame 

included 253 establishments that contribute approximately 99.9% of hogs slaughtered in 

the U.S. From this sampling frame, 152 random establishments were sampled. The 

Salmonella post-chill rates were:

1 RTI began collecting baseline organoleptic and microbiological data in August 1998, before HIMP program began. 

7

 
o 5 HIMP market hog establishments –0.69%

o 21 non-HIMP market hog comparison establishments -1.35%

o All 147 non-HIMP hog slaughter establishments in baseline study – 3.05%

The difference in Salmonella testing results between the 5 HIMP and the 21 non-HIMP 

comparison establishments is not statistically significant (Two Sided Exact Fisher p =

0.55). This is probably the result of the small sample size relative to the low Salmonella

positive rate. The difference between HIMP market hog establishments and all 147 nonHIMP market hog establishments in the baseline study (includes the 21 non-HIMP 

comparison establishments) (0.69% versus 3.05%) is highly statistically significant (Two 

Sided Exact Fisher p < 0.00001).

Chemical Residues

FSIS conducts tests for residues of chemical use—including antibiotics, sulfonamides, 

and various other drugs, pesticides and environmental chemicals—in meat, poultry and 

egg products destined for human consumption. To ensure that the level of chemical 

residues remains low, FSIS conducts random residue sampling scheduled by headquarters 

and inspector-generated targeted sampling originating from the field. The number of 

annual chemical residue samples per market hog establishment is about the same in 

HIMP and non-HIMP comparison establishments (26 versus 27). The number of 

inspector generated chemical residue samples per market hog establishment is 1.7 times 

higher in HIMP market hog establishments than non-HIMP (619 versus 358).

• Over the period, CY2006-CY2010, HIMP market hog establishments had zero 

violative levels of chemical residues versus six in the non-HIMP comparison 

establishments. This difference is not statistically significant (Two-Sided Exact 

Fisher p = 0.067).

• For the period CY2012-CY2013, HIMP market hog establishments had 9

violative levels (0.15% of samples) versus 115 (0.76% of samples) in the nonHIMP market hog establishments. This is a statistically significant difference 

(Two-Sided Exact Fisher p < 0.0001).

Conclusion

FSIS's evaluation found that market hog slaughter establishments participating in HIMP are 

performing as well as comparable large non-HIMP market hog establishments and meeting FSIS 

expectations for the overall HIMP project. On this basis, FSIS sees no reason to discontinue 

HIMP in market hog establishments. 

1.0 INTRODUCTION

In October 1999, FSIS initiated the Hazard Analysis and Critical Control Pont (HACCP) 

Inspection Models Project (HIMP) project in volunteer slaughter establishments to determine 

whether new government slaughter inspection procedures, along with new plant responsibilities, 

could promote innovation and provide increased or equivalent food safety and consumer 

protection. Under HIMP, employees of slaughter establishments sort animals at both ante- and 

8
post-mortem prior to FSIS inspection, making an initial determination whether they are diseased

or unacceptable. Like the traditional inspection model, FSIS inspectors in HIMP market hog 

slaughter establishments inspect each head, viscera, and carcass after sorting by establishment 

employees. FSIS inspectors ensure that the establishment’s ante-mortem and post-mortem 

process controls meet regulatory standards through online carcass-by-carcass inspection and 

additional off-line verification activities. This approach is consistent with HACCP principles

where industry personnel rather than federal inspectors are responsible for identifying the steps 

in the slaughter process where food safety hazards are most likely to occur. They are also 

responsible for establishing controls that prevent or reduce these hazards prior to inspection.

Currently, there are 20 young chicken, 5 young turkey, and 5 market hog slaughter 

establishments participating in HIMP. This report focuses on the 5 market hog slaughter 

establishments participating in the HIMP project.

Before beginning HIMP, Research Triangle Institute (RTI), a third-party consulting organization,

conducted baseline organoleptic and microbiological data collection in 3 large traditional market 

hog slaughter establishments that volunteered to participate in the HIMP program (Cates et al. 

20012

). The baseline data document the status of pre-HIMP market hog slaughter-line inspection 

systems thus providing a benchmark for comparing the performance of establishments operating 

under the HIMP inspection system with those operating under traditional (non-HIMP) inspection 

systems. In March 2000, FSIS held a public meeting to present the HIMP baseline results and 

receive comments on proposed HIMP performance standards developed from the baseline RTI 

data. In November 2000, FSIS published the final HIMP market hog performance standards for 

three Food Safety (FS) and three Other Consumer Protection (OCP) carcass conditions of 

concern (FSIS 2000). Prior to operating under HIMP, market hog establishments were expected 

to revise their HACCP systems to meet food safety standards and to develop slaughter process 

control plans to meet or exceed OCP standards. Establishments are responsible for identifying 

and removing carcasses and parts that do not meet applicable regulatory requirements and HIMP 

performance standards. FSIS inspectors are responsible for verifying that plants are continuously 

achieving the required outcomes and inspecting the results.

The objective of the present analysis is to evaluate the performance of HIMP market hog

establishments and to determine whether the HIMP market hog inspection system meets Food 

Safety (FS) and Other Consumer Protection (OCP) standards and is performing as well as the 

existing inspection system in terms of safety and wholesomeness of hog slaughter and overall 

consumer protection. To accomplish this, HIMP market hog establishments are evaluated across 

a variety of operational parameters:

• Inspections

• Regulation verifications and noncompliances

• Public Health Related (W3NR and PHR) regulations

• Microbiological and chemical testing results

• Food Safety and OCP performance standards

2 RTI began collecting baseline organoleptic and microbiological data in August 1998, before HIMP program began. 

9

 
The evaluation is based on data for the years CY2006 through CY2010 and CY2012 through 

CY2013. The year CY2011 was a transition year for FSIS information systems and will not be 

considered.

Establishment performance results from CY2006 to CY2010 are based on data from the PBIS 

(Performance Based Inspection System) database and results from CY2012 to CY2013 are based 

on data from the PHIS (Public Health Inspection System) database. FSIS began transitioning 

establishments from the PBIS, which was in effect during the period of CY2006 to CY2010, to 

the PHIS in April 2011. The period April 2011 to December 2011 was a transitional period 

during which the inspection results for some establishments were recorded under PBIS, while 

others were recorded under PHIS. The data under the two systems are not completely compatible

as discussed in Appendix A. For this reason, the transitional period CY2011 is not included in 

this update of the HIMP market hog report, and the analysis of CY2006-CY2010 data is separate 

from the CY2012-CY2013 data.

Throughout this document, results are first presented for CY2006 to CY2010 (these results are 

based on PBIS data) and then for CY2012 and CY2013 (these results are based on PHIS data). 

The evaluation compares the 5 large HIMP market hog establishments with a comparison set of 

21 large non-HIMP market hog establishments selected to be comparable with HIMP market hog 

establishments with respect to production volume, line speed, and days of operation.

The FSIS inspection findings are assessed across three interrelated inspection activities:

1. Verification, by off-line inspectors, of the establishment’s execution of its HIMP 

slaughter PCP, under which establishment employees sort unacceptable carcasses and 

parts.

2. Verification of the establishment executing its Sanitation SOP and HACCP food safety 

systems.

3. Verification of the outcomes of the establishment HACCP and process control plans, 

both organoleptic and microbiologic

10
2.0 DESCRIPTION OF HIMP AND NON-HIMP 

MARKET HOG ESTABLISHMENTS

A description of HIMP and non-HIMP market hog inspection systems follows.

2.1 Inspection in HIMP and Non-HIMP Market Hog Establishments

The HIMP market hog inspection system has one ante-mortem inspector, two or three online 

carcass inspectors (CI), and one off-line verification inspector (VI) assigned to each line. The 

online CIs inspect every head, viscera, and carcass at the corresponding fixed locations on the 

slaughter line (See Figures 2-1) to ensure that market hog products receiving the USDA mark of 

inspection are not adulterated. The off-line VI performs system verifications and the 24 carcass 

food safety check. The major difference between HIMP and non-HIMP inspection is that the 

HIMP VI performs 24 food safety carcass checks versus 11 carcass food safety checks at nonHIMP market hog slaughter establishments. Market hog carcass inspection is conducted more 

efficiently under HIMP than under the non-HIMP inspection systems because establishment 

personnel have already sorted and removed diseased animals at ante-mortem and identified and 

removed unacceptable carcasses and parts at post-mortem just prior to FSIS inspection.

Figure 2-1 Flowchart of the HIMP Market Hog Inspection Systems

HIMP Market Hog Inspection

Separation 

of carcass 

and head

Prepare and 

clean carcass 

for separation 

of head and 

viscera

Separation of 

carcass and 

viscera

CI

Carcass 

Trimmed

PHV/IIC

Online CI = Carcass, head and viscera inspectors

*Offline VI = System Verifications 

**Offline VI = 24 Carcass Food Safety Checks

PHV/IIC = System Inspection

VI*

CI

Carcass 

verification 

location

Carcass 

chilling

CI

VI**

11
2.2 Line Speed Estimation

HIMP slaughter establishments are permitted to operate at higher evisceration line speeds than 

traditional slaughter establishments operating under current inspection systems as long as they 

maintain process control and meet or exceed Food Safety and OCP performance standards. To 

evaluate the impact of line speed on HIMP establishment performance, it is necessary to know 

line speeds in HIMP and comparison non-HIMP market hog establishments. 

To clarify line speeds, the annual average line speed at a market hog slaughter establishment was 

calculated based on the establishment’s annual slaughter volume, hours of operation, and the 

number of shifts and slaughter lines.

In CY2013, the estimated line speeds at the 5 HIMP market hog establishments varied from 885

to 1,295 head per hour (hph), with an estimated average line speed of 1,099 hph. The 21 nonHIMP comparison establishments had line estimated speeds of 571 to 1,149 hph, with an

estimated average line speed of 977 heads per hour.

3

3 Line speed estimates are calculated based on data provided by FSIS personnel on operating hours, donning and 

doffing times, and average overtime. Responses included ranges, averages, and estimates, so estimated line speeds 

likely vary from the actual line speeds. This results in estimated line speeds that may be above the actual operating 

line speeds and above the allowed maximum for non-HIMP establishments. 

12

 
3.0 RESULTS

This section presents a summary of FSIS inspection findings in HIMP market hog establishments 

and compares them to inspection findings in 21 traditional non-HIMP market hog establishments

of comparable size or with FSIS HIMP market hog performance standards derived from the RTI 

study of pre-HIMP market hog establishments as appropriate. The findings are organized around

the following three interrelated FSIS inspection activities:

1. Verification, by off-line inspectors, of the establishment’s execution of its HIMP 

slaughter process control plans, under which establishment employees sort acceptable 

and unacceptable carcasses and parts.

2. Verification of the establishment’s execution of its Sanitation Standard Operating 

Procedures (Sanitation SOP) and its Hazard Analysis and Critical Control Point 

(HACCP) system under 9 CFR Parts 416 and 417.

3. Verification of the outcomes of the establishment’s HACCP and process control plans, 

both organoleptic and microbiologic

3.1 Verification that the Establishment is Executing its HIMP Slaughter 

Process Control Plan (PCP) whereby Establishment Employees Sort 

Acceptable and Unacceptable Carcasses and Parts

Under HIMP, employees of slaughter establishments sort live animals at ante-mortem and 

carcasses at post-mortem, in both cases just prior to inspection by FSIS inspectors. The sorted 

carcasses are expected to meet or exceed Food Safety (FS) and Other Consumer Protection 

(OCP) performance standards. FSIS online inspectors inspect each head, viscera, and carcass as 

required by the Federal Meat Inspection Act (FMIA) and conduct off-line carcass verification 

sampling to verify that the establishment’s finished product meets or exceeds the required 

outcome. The off-line inspectors also conduct other verification sampling of the establishment’s 

processes and products to ensure compliance with Sanitation SOP, HACCP, and other FSIS 

regulatory requirements. This section describes the FSIS off-line verification activities of 

establishments executing their HIMP PCP and complying with food safety regulatory 

requirements.

3.1.1 Number of Off-line FSIS Verification Inspection Procedures per Establishment Under 

PBIS

FSIS inspectors conduct off-line verification inspection procedures in HIMP market hog

establishments to verify that the establishment complies with established standards for food 

safety and OCP defects, pathogen levels, other applicable sanitation and HACCP federal 

regulations, and established HIMP performance standards.

Table 3-1 presents the ratio of the number of off-line inspection procedures per establishment in 

HIMP and non-HIMP market hog establishments for CY2010 (data for CY2006-CY2009 are 

presented in Appendix E). For CY2010, FSIS inspectors performed 1.4 times more total off-line

verification inspection procedures and 1.5 more SSOP and HACCP inspection procedures in 

HIMP market hog establishments than in non-HIMP market hog establishments. This is 

primarily the result of the increased number of 03J01 verifications under HIMP. This 

13
observation supports the determination that FSIS inspectors were ensuring that HIMP market 

hog establishments were complying with all federal regulations.

Table 3- 1 Number of Inspection Procedures Performed per Establishment in HIMP and 

Non-HIMP Market Hog Establishments Under PBIS in CY2010

Procedure 

code1

Number of Inspection Procedures Per 

Establishment Per Calendar Year

HIMP/Non

-HIMP 

Ratio

5 HIMP Market Hog

Establishments

21 Non-HIMP Market Hog

Comparison 

Establishments

01A012 3.8 2.5 1.5

01B01 167.4 152.7 1.1

01B02 156.6 136.5 1.1

01C01 234.4 270.0 0.9

01C02 330.0 303.0 1.1

03A01 3.4 2.5 1.4

03J01 621.4 131.0 4.7

03J02 175.2 154.6 1.1

04C03 226.2 175.60 1.3

05A01 1.4 0.9 1.5

06D01 141.0 152.2 0.9

CY2010 

Total for 

Procedures 2060.8 1482.2 1.4

CY2010 

Total for 

SSOP and 

HACCP 

Procedures3 1692.2 1152.8 1.5

1. See Appendix B for description of inspection procedure codes

2. The 01A01 procedure is performed annually and anytime there are major changes to the 

establishment’s existing SSOP

3. See Appendix A for description of sanitation SOP and HACCP procedures

3.1.2 Number of Off-line FSIS Verification Inspection Procedures for HACCP and 

Sanitation SOP per Establishment Under PHIS

For the years CY2012 and CY2013, comparisons of the ratios of the number of off-line

inspection procedures per establishment in HIMP and non-HIMP market hog establishments 

were made on the basis of mandatory verifications and public health related (PHR) regulations. 

Mandatory verifications are the minimal subset of regulations that inspectors should verify every 

time they perform an inspection task. (Additional regulations listed under an inspection task are 

verified on a random basis and as appropriate). There are 31 mandatory verifications associated 

14
with the 8 FSIS off-line mandatory verification inspection procedures that apply to all market 

hog slaughter establishments. Mandatory verifications are described in Appendix C.

Table 3-2 presents the ratio of number of off-line inspection verification of mandatory 

regulations for CY2012. For CY2012, FSIS inspectors performed 1.4 times more of the off-line

inspection mandatory verifications in HIMP than in non-HIMP market hog establishments and 

1.5 times more SSOP and HACCP mandatory verification regulations. This is due largely to the 

increased verification of 9 CFR 310.18 regulations and to a lesser extent increased verification of 

9 CFR 416 regulation verifications. This is offset partially by reduced verifications of the 9 CFR 

417 regulations.

Table 3- 2 Number of Mandatory Regulation Verifications per Establishment in HIMP and 

Non-HIMP Market Hog Establishments for CY2012

Mandatory 

Regulation 

Verified

Number of Mandatory Regulation Verifications

per Establishment per calendar year

HIMP/NonHIMP Ratio

5 HIMP Hog

Establishments

21 Non-HIMP Hog

Establishments

310.181 10,324.80 4,871.95 2.12

416.1 190.40 249.95 0.76

416.12(a) 561.40 524.38 1.07

416.13(a) 371.00 241.67 1.54

416.13(b) 610.40 595.90 1.02

416.13(c) 963.20 830.43 1.16

416.14 576.20 499.62 1.15

416.16(a) 1,027.00 884.24 1.16

416.16(b) 52.20 128.29 0.41

416.16(c) 410.80 352.38 1.17

417.2(c)(4) 288.00 334.48 0.86

417.2(c)(5) 235.00 302.57 0.78

417.2(c)(6) 254.80 319.19 0.80

417.2(c)(7) 260.80 340.00 0.77

417.3(a)(1) 80.60 116.24 0.69

417.3(a)(2) 211.00 307.05 0.69

417.3(a)(3) 82.40 114.10 0.72

417.3(a)(4) 47.80 94.38 0.51

417.3(b)(1) 28.80 49.86 0.58

417.3(b)(2) 28.60 53.86 0.53

417.3(b)(3) 39.60 82.81 0.48

417.3(b)(4) 23.60 42.67 0.55

417.3(c) 34.00 56.57 0.60

417.4(a)(2)(i) 216.40 269.33 0.80

417.4(a)(2)(ii) 327.20 332.05 0.99

417.4(a)(2)(iii) 344.20 347.29 0.99

15
Mandatory 

Regulation 

Verified

Number of Mandatory Regulation Verifications

per Establishment per calendar year

HIMP/NonHIMP Ratio

5 HIMP Hog

Establishments

21 Non-HIMP Hog

Establishments

417.5(a)(1) 226.60 292.19 0.78

417.5(a)(2) 276.00 331.00 0.83

417.5(a)(3) 437.60 440.48 0.99

417.5(b) 325.20 349.52 0.93

417.5(c) 324.20 344.52 0.94

CY2012 Total 

Mandatory2

Regulations 19,180 14,099 1.36

CY2012 Total 

SSOP and 

HACCP 

Mandatory 

Regulations3 16,493 11,111 1.48

1 Adjusted to reflect the 24 market hogs per 310.18 verification for HIMP market hog 

establishments versus 11 hogs per verification for non-HIMP market hog establishments

2 See Appendix C for description of mandatory regulations

3 See Appendix A for description of sanitation SOP and HACCP procedures 

Table 3-3 presents the ratio of number of off-line inspection verification of mandatory 

regulations for CY2013. In CY2013, FSIS inspectors performed 1.4 times more of the off-line

inspection verifications of mandatory regulations in HIMP market hog establishments than in 

non-HIMP market hog establishments and 1.6 times more SSOP and HACCP mandatory 

verification regulations.

Table 3- 3 Number of Mandatory Regulation Verifications per Establishment in HIMP and 

Non-HIMP Market Hog Establishments for CY2013

Mandatory 

Regulation 

Verified

Number of Mandatory Regulation Verifications

per Establishment per calendar year

HIMP/NonHIMP Ratio

5 HIMP Hog

Establishments 

21 Non-HIMP Hog

Establishments 

310.181 10,804.80 4,850.48 2.23

416.1 273.80 323.52 0.85

416.12(a) 550.20 522.71 1.05

416.13(a) 344.80 201.19 1.71

416.13(b) 568.40 600.67 0.95

416.13(c) 1,036.40 881.95 1.18

416.14 574.80 513.90 1.12

416.16(a) 999.80 808.67 1.24

416.16(b) 60.80 129.00 0.47

416.16(c) 503.00 365.57 1.38

16
Mandatory 

Regulation 

Verified

Number of Mandatory Regulation Verifications

per Establishment per calendar year

HIMP/NonHIMP Ratio

5 HIMP Hog

Establishments 

21 Non-HIMP Hog

Establishments 

417.2(c)(4) 312.80 395.43 0.79

417.2(c)(5) 226.80 283.33 0.80

417.2(c)(6) 239.00 297.57 0.80

417.2(c)(7) 237.60 324.33 0.73

417.3(a)(1) 29.00 51.43 0.56

417.3(a)(2) 99.00 174.24 0.57

417.3(a)(3) 29.80 47.57 0.63

417.3(a)(4) 17.60 51.67 0.34

417.3(b)(1) 11.80 26.24 0.45

417.3(b)(2) 11.80 26.62 0.44

417.3(b)(3) 13.20 46.05 0.29

417.3(b)(4) 12.20 19.10 0.64

417.3(c) 21.40 35.19 0.61

417.4(a)(2)(i) 187.80 247.05 0.76

417.4(a)(2)(ii) 298.60 301.05 0.99

417.4(a)(2)(iii) 296.00 323.52 0.91

417.5(a)(1) 194.20 259.29 0.75

417.5(a)(2) 225.20 291.38 0.77

417.5(a)(3) 400.00 420.81 0.95

417.5(b) 311.00 320.10 0.97

417.5(c) 293.40 321.19 0.91

CY2013 Total 

Mandatory2

Regulations 19,185.0 13,460.8 1.43

CY2013 Total 

SSOP and 

HACCP 

Mandatory 

Regulations3 16,825 10,767 1.56

1 Adjusted to reflect the 24 market hogs per 310.18 verification for HIMP market hog 

establishments versus 11 hogs per verification for non-HIMP market hog establishments

2 See Appendix C for description of mandatory regulations

3 See Appendix A for description of sanitation SOP and HACCP procedures 

Table 3-4 presents the ratio of number of off-line inspection verification of public health 

regulations for CY2012. In CY2012, FSIS inspectors performed an equivalent number of total 

off-line inspection verifications of PHR regulations in HIMP market hog establishments as in 

non-HIMP market hog establishments and 1.1 times more SSOP and HACCP PHR verification 

regulations. 

17
Table 3- 4 Number of Public Health-Related Regulations Verified per Establishment in 

HIMP and Non-HIMP Market Hog Establishments for CY2012

Public Health 

Regulations1

Verified

PHR Regulation Verifications per

Establishment per calendar year

HIMP/Non-HIMP 

Ratio

5 HIMP Hog

Establishments

21 Non-HIMP Hog

Establishments

301.2_Adulterated 26.00 15.48 1.68

381.144(a)2 0.00 0.05 0.00

381.65(a)2 1.80 4.05 0.44

381.91(a)2 0.20 0.52 0.38

381.91(b)2 0.40 0.33 1.20

416.1 190.40 249.95 0.76

416.14 576.20 499.62 1.15

416.15(a) 241.80 168.95 1.43

416.15(b) 122.20 68.76 1.78

416.16(a) 1027.00 884.24 1.16

416.3(b) 37.20 15.33 2.43

416.4(d) 223.20 174.38 1.28

416.6 0.60 2.19 0.27

417.2(c)(4) 288.00 334.48 0.86

417.3(a)(1) 80.60 116.24 0.69

417.3(a)(2) 211.00 307.05 0.69

417.3(a)(3) 82.40 114.10 0.72

417.3(a)(4) 47.80 94.38 0.51

417.3(b)(1) 28.80 49.86 0.58

417.3(b)(3) 39.60 82.81 0.48

417.3(c) 34.00 56.57 0.60

417.4(a) 0.80 3.00 0.27

417.4(a)(1) 0.40 1.38 0.29

417.4(a)(3) 1.20 3.38 0.35

417.4(b) 0.40 1.10 0.37

417.5(a)(1) 226.60 292.19 0.78

417.5(a)(3) 437.60 440.48 0.99

CY2012 Total 

PHR Regulations1 3,926 3,981 0.99

CY2012 Total 

SSOP and 

HACCP PHR 

Regulations 3,023 2,823 1.07

1 See Appendix C for description of public health regulations

2 Regulations from 9 CFR 381 apply only to poultry establishments, but on rare occasions have 

been inappropriately marked as verified at hog establishments. These regulations are included 

for completeness since they are part of the FSIS set of Public Health Regulations that were cited 

18
which apply to all establishments. Due to their very low frequency of being cited, their inclusion 

or non-inclusion does not impact any of the findings or conclusions of this report.

Table 3-5 presents the ratio of number of off-line inspection public health regulation 

verifications for CY2013. In CY2013, FSIS inspectors performed an equivalent number of total 

off-line inspection verifications of HACCP public health-related (PHR) regulations in HIMP 

market hog establishments as in non-HIMP market hog establishments and 1.1 times more SSOP 

and PHR regulation verifications.

Table 3- 5 Public Health-Related Regulations Verified per Establishment in HIMP and 

Non-HIMP Market Hog Establishments for CY2013

Public Health 

Regulations1

Verified

PHR Regulation Verifications per

Establishment per calendar year

HIMP/NonHIMP Ratio

5 HIMP Hog 

Establishments

21 Non-HIMP Hog 

Establishments

301.2_Adulterated 6.20 9.05 0.69

381.144(a)2 0.00 0.19 0.00

381.65(a)2 2.00 2.86 0.70

381.832 0.20 0.10 2.10

381.91(a)2 0.00 0.29 0.00

381.91(b)2 0.20 0.33 0.60

416.1 273.80 323.52 0.85

416.14 574.80 513.90 1.12

416.15(a) 106.00 80.24 1.32

416.15(b) 57.60 39.62 1.45

416.16(a) 999.80 808.67 1.24

416.3(b) 57.00 16.38 3.48

416.4(d) 205.00 201.90 1.02

416.6 0.20 1.86 0.11

417.2(c)(4) 312.80 395.43 0.79

417.3(a)(1) 29.00 51.43 0.56

417.3(a)(2) 99.00 174.24 0.57

417.3(a)(3) 29.80 47.57 0.63

417.3(a)(4) 17.60 51.67 0.34

417.3(b)(1) 11.80 26.24 0.45

417.3(b)(3) 13.20 46.05 0.29

417.3(c) 21.40 35.19 0.61

417.4(a) 0.20 0.86 0.23

417.4(a)(1) 0.20 0.38 0.53

417.4(b) 0.60 0.71 0.84

417.5(a)(1) 194.20 259.29 0.75

417.5(a)(3) 400.00 420.81 0.95

19
Public Health 

Regulations1

PHR Regulation Verifications per

Establishment per calendar year

HIMP/NonHIMP Ratio

CY2013 Total 

PHR 

Regulations1 3,413 3,509 0.97

CY2013 Total 

SSOP and 

HACCP PHR 

Regulations 2,666 2,539 1.05

1 See Appendix C for description of public health regulations. 2 Regulations from 9 CFR 381 apply only to poultry establishments, but on rare occasions have 

been inappropriately marked as verified at hog establishments. These regulations are included 

for completeness since they are part of the FSIS set of Public Health Regulations that were cited 

which apply to all establishments. Due to their very low frequency of being cited, their inclusion 

or non-inclusion does not impact any of the findings or conclusions of this report.

From the CY2010 – CY2013 data, we can conclude that HIMP market hog establishments

receive an equivalent number of verification inspections as non-HIMP market hog 

establishments, which ensures an equivalent scrutiny of compliance with sanitary dressing and 

process controls. Although there are more 9 CFR 416 verifications and fewer 9 CFR 417 

verifications in HIMP, both verifications are considered to address food safety issues and carry 

the same regulatory weight when enforcement actions are initiated.

3.1.3 FSIS Condemnation Rates and HIMP Establishment Sorting Disposition Rates

Under HIMP, establishment sorters assume responsibility for identifying, sorting and disposing 

of noncompliant carcasses and all their associated parts just prior to and in the presence of FSIS 

carcass inspectors positioned at two or three locations on the slaughter line. FSIS inspectors 

inspect each carcass to verify that there has been proper sorting by plant sorters, and that only 

compliant products receive the USDA mark of inspection. Sorting rates are determined by the 

number of carcasses disposed by establishment sorters divided by the total number of market 

hogs slaughtered.

In non-HIMP hog establishments, FSIS inspectors have the responsibility for identifying, sorting, 

and verifying disposition of each carcass to ensure that only compliant products receive the 

USDA mark of inspection. FSIS condemnation rates are the number of carcasses condemned by 

FSIS Public Health Veterinarians (PHVs) divided by the total number of market hog slaughtered. 

This slaughter information was recorded in the FSIS electronic Animal Disease Reporting 

System (eADRS) until 2012 and now is recorded in PHIS. Under the current non-HIMP 

inspection system, FSIS has control of the carcass once it is presented for inspection until final 

inspection is completed. Establishment employees may dispose of carcasses only under FSIS 

supervision or as directed by the PHV.

In PBIS, FSIS employees recorded both ante-mortem and post-mortem condemnations. In PHIS, 

only the post-mortem carcass dispositions made by the PHV (carcasses railed out to the PHV) 

20
are entered into PHIS. Thus, FSIS condemnation rates under PBIS and PHIS are not directly

comparable (see Appendix A).

Table 3-6 presents a summary of the postmortem sorting rates for HIMP market hog

establishments and condemnation rates for the comparison set of non-HIMP market hog

establishments for the years CY2006 to CY2010. Sorting rates in HIMP are determined by the 

number of carcasses disposed by establishment sorters divided by the total number of market 

hogs slaughtered. Condemnation rates in non-HIMP are computed as the ratio of carcasses 

condemned by FSIS inspectors divided by the total number of market swine slaughtered.

Table 3- 6 Sorting and Condemnation Rates for HIMP and Non-HIMP Market Hog 

Establishments for CY2006 to CY2010

2006 2007 2008 2009 2010

Sorting Rates in 5 HIMP Market Hog 

Establishments 0.11% 0.10% 0.10% 0.09% 0.11%

Condemnation Rates in 21 Non-HIMP 

Market Hog Establishments 0.07% 0.07% 0.06% 0.06% 0.06%

Table 3-7 presents a summary of the sorting rates (ante-mortem plus postmortem) for HIMP 

market hog establishments and condemnation rates (ante-mortem plus postmortem) for the 

comparison set of non-HIMP market hog establishments for the years CY2012 to CY2013. The 

sorting rates in HIMP market hog establishments by establishment sorters are statistically 

significantly higher than condemnation rates in non-HIMP market hog establishments for both 

years. This result suggests that employees of market hog slaughter establishments are effective

in executing their responsibility to produce safe and wholesome products by sorting and 

disposing of noncompliant carcasses before they reach FSIS inspectors.

Table 3- 7 Sorting and Condemnation Rates for HIMP and Non-HIMP Market Hog 

Establishments for CY2012 and CY2013

2012 2013

Sorting Rates in 5 HIMP Hog Establishments 0.29% 0.31%

Condemnation Rates in 21 Non-HIMP Market Hog

Establishments 0.26% 0.28%

3.2 Verification of the Establishment Executing its Sanitation SOPs and its 

HACCP System

This section addresses FSIS verification inspection activities related to verification that the 

HIMP market hog establishment is executing its sanitation standard operating procedures 

(Sanitation SOP) and its hazard analysis and critical control point (HACCP) system under 9 CFR 

Parts 416 and 417.

3.2.1 Off-line Inspection Procedures Performed

The sanitation SOP regulations in 9 CFR Part 416 and the HACCP regulations in 9 CFR Part 417 

are among the regulations most strongly related to public health. Sanitation standard operating 

procedures are written procedures that an establishment develops to maintain sanitary conditions 

21
and prevent contamination of product. The establishment must maintain daily records sufficient 

to document implementation and monitoring of sanitation SOPs and any corrective actions taken. 

There are eight inspection procedures in PBIS associated with activities that FSIS inspectors 

perform to verify compliance with the sanitation SOP and HACCP regulations. In PBIS, there 

are seven sanitation SOP and HACCP inspection procedures that apply to all market hog

slaughter establishments. These are 01A01, 01B01, 01B02, 01C01, 01C02, 03A01, 03J01, and 

03J02. In PHIS, these are 01B01, 01B02, 01C01, 01C02, 03J02 and 03J03. (see Appendix A for 

explanation of differences between PBIS and PHIS). 

In CY2010, FSIS inspectors in HIMP market hog establishments performed approximately 1.5 

times more off-line procedures to verify compliance with sanitation SOP and HACCP regulatory 

requirements than in non-HIMP market hog establishments (see Table 3-1 above). In CY2012

and CY2013, FSIS inspectors in HIMP market hog establishments performed approximately 1.5 

and 1.6 times more, respectively, off-line inspections of mandatory regulations to verify 

compliance with sanitation SOP and HACCP regulatory requirements than in non-HIMP market 

hog establishments (see Tables 3-2 and 3-3). Thus, there is more frequent verification of 

compliance with sanitation SOP and HACCP regulation in market hog HIMP market hog 

establishments, which ensures that any noncompliance with sanitary dressing and process 

controls will be more likely to be identified at HIMP establishments than at non-HIMP 

establishments.

3.2.2 Public Health Noncompliance Rates

FSIS inspection program personnel (IPP) perform inspection procedures in federally-inspected 

establishments each day to verify that the establishments are executing their SSOP and HACCP 

system under 9 CFR Parts 416 and 417. If IPP observe a noncompliance with a regulatory 

requirement, they are to document the finding on a noncompliance record (NR) to the 

establishment. Establishments are to respond to the NRs by describing their corrective and 

preventive actions to comply with the applicable regulation.

PBIS and PHIS use different lists of the most serious health-related regulations. PBIS used the 

list of W3NRs which was selected by a group of FSIS experts, while PHIS uses an updated list 

of Public Health Regulations (PHRs) derived through a more transparent and data-driven 

approach that identifies regulations with which there is an elevated rate of noncompliance during

the three months before a Salmonella, E. coli O157: H7, or Listeria monocytogenes (Lm) 

positive.

Eleven inspection procedures in PBIS are used by FSIS inspectors in all market hog slaughter 

establishments. They are 01A01, 01B01, 01B02, 01C01, 01C02, 03A01, 03J01, 03J02, 04C03, 

05A01 and 06D01. See Appendix B for a description of these inspection procedures. The number 

of inspection procedures performed and the number of health-related NRs issued were 

determined for each procedure code for each of the years CY2006 to CY2010 for each HIMP 

and control set of non-HIMP establishment.

Table 3-8 presents a summary of the W3NR noncompliance rates by procedure code for the 5 

years of combined CY2006 to CY2010 data. Health-related noncompliance rates at HIMP 

market hog establishments for individual procedure codes are statistically higher for the three 

22
inspection task codes marked with stars and are not statistically significantly different for 

remaining eight procedure codes. The W3NR rate for total sanitation SOP and HACCP health 

related procedures are statistically significantly higher in HIMP market hog establishments than 

in non-HIMP market hog establishments. These are computed as the sum of W3NR 

noncompliances in 01A01, 01B01, 01B02, 01C01, 01C02, 03A01, 03J01, and 03J02 divided by 

the number of inspections of these procedure codes.

Table 3- 8 Average CY2006-CY2010 W3NR Noncompliance Rates for HIMP and NonHIMP Market Hog Establishments

HIMP Market Hog 

Establishments

Non-HIMP Comparison Market 

Hog Establishments

Procedure 

Code1

NCs Total

Procedures

Market

Hog NC 

Rates

NCs Total 

Procedures

Comparison 

Market Hog

NC Rates

01A01 - 80 0.00% - 3 0.00%

01B01 11 4,757 0.23%* 7 16,305 0.04%

01B02 61 3,914 1.56% 189 14,237 1.33%

01C01 21 6,070 0.35% 95 28,551 0.33%

01C02 187 8,544 2.19% 689 32,544 2.12%

03A01 - 72 0.00% 2 271 0.74%

03J01 187 15,246 1.23%* 84 13,300 0.63%

04C03 17 4,004 0.42%* 7 12,591 0.06%

03J02 28 4,614 0.61% 71 16,070 0.44%

05A01 - 21 0.00% - 95 0.00%

06D01 - 4,282 0.00% - 15,412 0.00%

SSOP and 

HACCP 

HealthRelated 

NC Rates 495 43,297 1.14%* 1,137 121,281 0.94%

* indicates a statistically significant difference at the 0.05 level.

1. See Appendix B for description of procedure codes

The six inspection tasks in PHIS associated with activities that FSIS inspectors perform to verify 

compliance with the sanitation SOP and HACCP regulations are 01B01, 01B02, 01C01, 01C02, 

03J02, and 03J03. See Appendix B for a description of these procedures. Table 3-9 and Table 3-

10 present a summary of the Public Health Regulation (PHR) noncompliance rates for these 

seven inspection tasks by regulation for CY2012 and CY2013, respectively. For CY2012, PHR

noncompliance rates at HIMP market hog establishments are statistically significantly higher for 

four regulations, statistically significantly lower for five regulations, and not statistically 

significantly different for eighteen regulations. Overall, the CY2012 PHR noncompliance rate 

for SSOP and HACCP regulations in HIMP market hog establishments is statistically

significantly lower than that for the 21 comparison non-HIMP market hog establishments. For 

CY2013, PHR noncompliance rates at HIMP market hog establishments are statistically 

significantly higher for three regulations, statistically significantly lower for five regulations, and 

23
not statistically significantly different for nineteen regulations. Overall, the PHR noncompliance 

rate in CY2013 for SSOP and HACCP regulations in HIMP market hog establishments is 

statistically significantly lower than that for the 21 comparison non-HIMP market hog 

establishments.

Table 3- 9 SSOP and HACCP Public Health (PHR) Noncompliance Rates for HIMP and 

Non-HIMP Market Hog Establishments for CY2012

HIMP Market Hog 

Establishments

Non-HIMP Comparison 

Market Hog Establishments

Regulation 

Verified

NC Times 

Verified

NonCompliance 

Rate

NC Times 

Verified

NonCompliance 

Rate

301.2_

Adulterated 12 130 9.23%* 51 296 17.23%

381.144(a)1 - - - 1 0.00%

381.65(a)1 - - - 10 0.00%

381.91(a)1 - - - 1 0.00%

381.91(b)1 - - - 1 0.00%

416.1 45 93 48.39%* 300 892 33.63%

416.14 5 2,881 0.17%* 149 10,492 1.42%

416.15(a) 19 1,209 1.57%* 164 3,548 4.62%

416.15(b) 13 611 2.13%* 102 1,444 7.06%

416.16(a) 71 5,135 1.38%* 90 18,569 0.48%

416.3(b) 2 118 1.69% 10 232 4.31%

416.4(d) 184 927 19.85%* 966 2,883 33.51%

417.2(c)(4) 23 909 2.53%* 59 4,501 1.31%

417.3(a)(1) 3 252 1.19% 10 1,502 0.67%

417.3(a)(2) 47 780 6.03%* 22 4,189 0.53%

417.3(a)(3) 3 266 1.13% 13 1,460 0.89%

417.3(a)(4) 3 91 3.30% 4 578 0.69%

417.3(b)(1) 1 10 10.00% 3 215 1.40%

417.3(b)(3) 2 55 3.64% 3 347 0.86%

417.3(c) 2 28 7.14% 4 246 1.63%

417.4(a) 1 2 50.00% 3 17 17.65%

417.4(a)(1) - 1 0.00% - 6 0.00%

417.4(a)(3) - 4 0.00% - 24 0.00%

417.4(b) - 1 0.00% - 12 0.00%

417.5(a)(1) 3 427 0.70% 11 2,734 0.40%

417.5(a)(3) 5 1,186 0.42% 17 5,076 0.33%

SSOP and 

HACCP 

HealthRelated NC 444 15,116 2.94%* 1,981 59,276 3.34%

24
Rates

* indicates a statistically significant difference at the 0.05 level.

1 Regulations from 9 CFR 381 apply only to poultry establishments, but on rare occasions have 

been inappropriately marked as verified at hog establishments. These regulations are included 

for completeness since they are part of the FSIS set of Public Health Regulations that were cited 

which apply to all establishments. Due to their very low frequency of being cited, their inclusion 

or non-inclusion does not impact any of the findings or conclusions of this report.

Table 3- 10 SSOP and HACCP PHR Noncompliance Rates for HIMP and Non-HIMP 

Market Hog Establishments for CY2013

HIMP Market Hog 

Establishments

Non-HIMP Comparison 

Market Hog Establishments

Regulation 

Verified

NCs Times

Verified

NonCompliance 

Rate

NCs Times 

Verified

NonCompliance 

Rate

301.2_

Adulterated - 31 0.00%* 89 180 49.44%

381.144(a)1 - - - 2 0.00%

381.65(a)1 - 1 0.00% - 6 0.00%

381.831 1 1 100.00% - 2 0.00%

381.91(a)1 - - - 2 0.00%

381.91(b)1 - - - 4 0.00%

416.1 117 465 25.16% 611 2,166 28.21%

416.14 5 2,874 0.17%* 102 10,792 0.95%

416.15(a) 11 530 2.08%* 93 1,685 5.52%

416.15(b) 4 288 1.39%* 72 832 8.65%

416.16(a) 59 4,999 1.18%* 70 16,982 0.41%

416.3(b) 11 211 5.21% 22 261 8.43%

416.4(d) 157 874 17.96%* 1,021 3,283 31.10%

417.2(c)(4) 56 860 6.51%* 96 4,559 2.11%

417.3(a)(1) - 87 0.00% 7 680 1.03%

417.3(a)(2) 11 392 2.81%* 25 2,760 0.91%

417.3(a)(3) 1 91 1.10% 9 601 1.50%

417.3(a)(4) - 30 0.00% 6 503 1.19%

417.3(b)(1) - 2 0.00% 1 187 0.53%

417.3(b)(3) - 8 0.00% 1 396 0.25%

417.3(c) - 21 0.00% 9 146 6.16%

417.4(a) - 1 0.00% - 8 0.00%

417.4(a)(1) - 1 0.00% 1 5 20.00%

417.4(b) - 2 0.00% - 6 0.00%

417.5(a)(1) 1 425 0.24% 4 2,441 0.16%

417.5(a)(3) 6 1,138 0.53% 23 4,829 0.48%

25
HIMP Market Hog 

Establishments

Non-HIMP Comparison 

Market Hog Establishments

Regulation 

Verified

NCs Times

Verified

NonCompliance 

Rate

NCs Times 

Verified

NonCompliance 

Rate

Total SSOP 

and HACCP 

HealthRelated NC 

Rates 440 13,332 3.30%* 2,262 53,318 4.24%

* indicates a statistically significant difference at the 0.05 level.

1 Regulations from 9 CFR 381 apply only to poultry establishments, but on rare occasions have 

been inappropriately marked as verified at hog establishments. These regulations are included 

for completeness since they are part of the FSIS set of Public Health Regulations that were cited 

which apply to all establishments. Due to their very low frequency of being cited, their inclusion 

or non-inclusion does not impact any of the findings or conclusions of this report.

3.2.3 Postmortem Food Safety Disease Conditions (FS-1)

Table 3-11 presents rates of NRs issued at HIMP market hog establishments to document 

inspectors findings of food safety disease FS-1 conditions such as septicemia, pyemia, and 

toxemia as provided in 9 CFR 311.17. In PBIS, the NR rate is computed as the number of NRs 

citing 9 CFR 311.17 divided by the sum of the number of 03J01 and 03J02 procedures 

performed. No NRs are written for these disease conditions in non-HIMP market hog 

establishments since on line FSIS inspectors are responsible for sorting in non-HIMP market hog 

establishments.

A corresponding table for CY2012 and CY2013 is not presented since regulation 9 CFR 311.17 

is not mandatory in PHIS. Thus, under PHIS task assignments, inspectors only verify the 

regulation randomly and are not required to record verifications unless they detect a 

noncompliance. Thus, noncompliance records for 9CFR 311.17 in PHIS are not uniform. 

Inspectors do perform FS-1 inspections on a daily basis as part of the food safety performance 

standard assessment, but performance of the inspection is not recorded in PHIS. (Monthly 

records of these verifications and noncompliances are kept at the facility. They were retrieved 

and are reported later in the report.)

Table 3- 11 Noncompliance Rates for Food Safety Disease Conditions (FS-1) at HIMP 

Market Hog Establishments for CY2006 to CY2010

Year HIMP

2006 0.11%

2007 0.12%

2008 0.20%

2009 0.08%

2010 0.18%

26
3.2.4 Fecal Material, Ingesta, and Milk Contamination (FS-2)

Table 3-12 presents the HIMP and non-HIMP noncompliance rates for fecal material, ingesta, 

and milk contamination (FS-2) on market hog carcasses (9 CFR 310.18) for the years CY2006 

to CY2010. The noncompliance rate is computed as the number of noncompliances citing 9 CFR 

310.18 divided by the sum of the number of 03J01 and 03J02 procedures performed. The fecal

material, ingesta, and milk contamination noncompliance rates at HIMP market hog 

establishments are not statistically significantly different from those in the control set of nonHIMP market hog establishments. 

Table 3- 12 Noncompliance Rates for Fecal Material, Ingesta, and Milk Conditions at 

HIMP and Non-HIMP Comparison Establishments

Year HIMP Non-HIMP

Comparison 

Establishments

2006 1.27% 0.85%

2007 0.89% 0.88%

2008 0.91% 0.56%

2009 0.97% 0.96%

2010 0.95% 0.93%

A corresponding table for CY2012 and CY2013 is presented since 9 CFR 310.18 is a mandatory 

in PHIS, and inspectors are required to enter FS-2 verifications into PHIS. (Monthly records of 

the FS-2 verifications and noncompliances are also kept at the facility. They were retrieved and 

are reported later in the report.) 

Table 3-13 presents the HIMP and non-HIMP noncompliance rates for fecal material, ingesta, 

and milk contamination on market hog carcasses (9 CFR 310.18) for the years CY2012 and 

CY2013. The noncompliance rate is computed as the number of noncompliances citing 9 CFR 

310.18 divided by the number of 9 CFR 310.18 verifications performed. The fecal material, 

ingesta, and milk contamination noncompliance rates at HIMP market hog establishments are not 

statistically significantly different from those in the control set of non-HIMP market hog 

establishments for CY2012 but are statistically significantly lower in CY2013 (Two- Sided Exact 

Fisher p = 0.023).

Table 3- 13 Noncompliance Rates for Fecal Material, Ingesta, and Milk Conditions at 

HIMP and Non-HIMP Market Hog Establishments for CY2012 and CY2013

Year HIMP Non-HIMP

Comparison 

Establishments

2012 0.18% 0.21%

2013 0.15% 0.21%

27
3.2.5 Ante-Mortem Inspection (FS-3)

FSIS inspectors at HIMP and non-HIMP market hog establishments conduct ante-mortem 

inspections of the live animals presented for inspection before the slaughter process begins. At 

HIMP market hog establishments, establishment employees sort hogs for FS-3 conditions prior 

to crossing their designated CCP and FSIS ante-mortem inspection. Table 3-13 presents rate of 

NRs issued at HIMP market hog establishments to document FSIS inspectors’ findings of food 

safety disease conditions at ante-mortem as provided in 9 CFR Part 309 This procedure is not 

applicable in non-HIMP market hog establishments. The noncompliance rate is computed as the 

number of 9 CFR Part 309-related NRs divided by the sum of the number of 03J01 and 03J02 

procedures performed for the years CY2006-CY2010.

A corresponding table for CY2012 and CY2013 is not presented since 9 CFR Part 309 is not 

mandatory in PHIS, and inspectors are not required to enter FS-3 verifications into PHIS unless 

there is a noncompliance. (Monthly records of the verifications and noncompliances are kept at 

the facility. They were retrieved and are reported later in the report.) 

Table 3- 14 Ante-Mortem 9 CFR Part 309 Noncompliance Rates at HIMP Market Hog 

Establishments

Year HIMP

2006 0.06%

2007 0.25%

2008 0.22%

2009 0.13%

2010 0.05%

3.3 Verification of the Outcomes of the Establishment Slaughter HACCP and 

Process Control Plans, Both Organoliptic and Microbiologic

This section addresses FSIS inspection activities related to verification of the establishment’s

slaughter HACCP and process control plans (PCP) concerning the organoleptic detection of FS 

(food safety) and OCP (other consumer protection) defects. The establishment HACCP plan 

addresses the FS defects, while the process control plan addresses OCP concerns.

3.3.1 Food Safety Performance Standards

FSIS has a zero tolerance policy for food safety conditions (e.g. septicemia, toxemia, pyemia)

identified as FS-1 conditions; fecal material, ingesta and milk contamination identified as FS-2 

conditions; and certain conditions identified at ante-mortem (e.g. moribund, severe lameness, 

pyretic, and neurologic conditions) identified as FS-3 conditions. Under HACCP, FSIS detection 

of any food safety disease condition past the CCP represents a noncompliance and deviation of a 

critical limit. FSIS’s performance standards (FS-1, FS-2 and FS-3) for these food safety 

conditions are zero (FSIS 2000). A comparison of market hog HIMP establishment performance 

with food safety performance standards is presented in Table 3-15. The analysis in Table 3-15 

28
for CY2009 to CY2010 is based on FSIS food safety inspection findings for the approximately 2 

year period April 1, 2009 through April 15, 2011. The food safety performance rates for FS-1 

and FS-2 are computed as the number of food safety-related defects found during all 24 carcass 

verifications divided by the total number of verification checks performed. The food safety 

performance rate for FS-3 is computed as the number of ante-mortem related deficiencies

divided by the total number of annual shifts.

The level of food safety defects is exceedingly small. Four of the five HIMP market hog 

establishments had zero FS-1 deficiencies in the two year period CY2012-CY2013 with the fifth 

having 3. This is an overall FS-1 deficiency rate of 3 per 100 thousand market hogs slaughtered. 

The defect rate for FS-2 in CY2012-CY2013 is 5 in ten thousand, which has decreased from 6 in 

ten thousand in CY2009-CY2010 and for both time periods is less than the 75% performance 

level of 2.6 per 100. 

Table 3- 15 Achievement of Food Safety Performance Standards at HIMP Market Hog 

Establishments

Performance 

Standards Based 

on Non-HIMP 

Inspection (% of 

carcasses)

CY2009-CY20101

HIMP 

Establishment 

Performance 

During FSIS 

Inspector 

Verification Checks 

(% of carcasses)

CY2012-CY20132

HIMP 

Establishment 

Performance 

During FSIS 

Inspector 

Verification Checks 

(% of carcasses)

FS-1

Infectious 

(e.g. septicemia, 

toxemia, cysticercus)

0.0%* 0.01% 0.00003%

FS-2

Digestive Content/Milk 

(e.g., fecal material, 

ingesta, milk)fecal 

contamination of 

viscera)

0.0%** 0.06% 0.05%

FS-3

Ante-Mortem Suspect

0.0% 0.00% 0.01%

*FSIS has a zero tolerance policy for Food Safety. Baseline result was 0.0% at 75th percentile.

** FSIS has a zero tolerance policy for Food Safety. Baseline result was 2.6% at 75th percentile.

1 Period of data collection: April 1, 2009 through April 15, 2011

2 Period of data collection: CY2012 – CY2013

3.3.2 Other Consumer Protection Performance Standards

Other Consumer Protection (OCP) standards are non-food safety standards concerned primarily 

with diseases of no public health significance and carcass processing defects. Using RTI data, 

FSIS developed OCP performance standards for HIMP market hog establishments and monitors 

29
HIMP establishment performance to verify that OCP performance standards are being met. A 

comparison of HIMP market hog establishment performance with OCP performance standards is 

given in Table 3-16. The analysis is based on FSIS food safety inspection findings for the two 

year period CY2009 - CY2010 and the two year period CY2012 – CY2013. The HIMP OCP

performance rates are computed as the number of OCP defects found by inspectors divided by 

the number of OCP verification checks performed. All HIMP market hog establishments were 

meeting OCP performance standards.

Table 3- 16 Achievement of OCP Performance Standards at HIMP Market Hog 

Establishments for CY2009 - CY2010 and CY2012 – CY2013

Performance 

Standards 

Based on NonHIMP 

Inspection (% 

of carcasses)

CY2009-CY20101

HIMP 

Establishment 

Performance 

During FSIS 

Inspector 

Verification 

Checks (% of 

carcasses)

CY2012-CY20132

HIMP 

Establishment 

Performance 

During FSIS 

Inspector 

Verification 

Checks (% of 

carcasses)

OCP 1

Carcass Pathology

(e.g., arthritis, 

emaciation, erysipelas) 

4.1% 1.2% 1.7%

Range 

0.05%-2.6%

OCP 2

Visceral Pathology 

(e.g., cystic kidneys, 

enteritis/gastritis,

fecal contamination of 

viscera)

7.2% 2.3% 3.1%

Range

0.4%-4.4%

OCP 3

Miscellaneous (e.g., 

anemia, bile, bruise, 

edema)

20.5% 8.3% 10.7%

Range

3.1%-15.6%

1 Period of data collection: April 1, 2009 through April 15, 2011

2 Period of data collection CY2012 – CY2013

3.3.3 Salmonella Positive Rates

FSIS uses data from its Salmonella verification testing programs to verify that establishments are 

meeting their regulatory obligation of complying with Salmonella performance standards in 9 

CFR 310.25(b). The Agency believes that the higher the percent positive rate, the greater the 

potential for the public to consume a product that may cause foodborne illness.

Table 3-17 presents a summary of the Salmonella percent positive rates for market hog HIMP 

and the control set of 21 non-HIMP market hog establishments for the years CY2006 to CY2010. 

The Salmonella positive rates in HIMP market hog establishments are lower than those in non30
HIMP comparison establishments for the years CY2006 to CY2009 but higher in CY2010. 

However, the differences are not statistically significant for any of the years. Thus, there is no 

statistically significant difference in the Salmonella verification testing results between market 

hog HIMP and non-HIMP market hog establishments for the years CY2006 to CY2010.

Table 3- 17 Salmonella Percent Positive Rates for HIMP and Non-HIMP Market Hog 

Establishments

2006 2007 2008 2009 2010

5 HIMP Market Hog

Establishments 1.06% 0.66% 0.00% 0.00% 2.29%1

21 Non-HIMP Comparison 

Establishments 1.39% 1.44% 1.51% 1.48% 0.69%

1 Two establishments had 2 positives, one had 1 positive.

FSIS discontinued collecting Salmonella verification samples for carcasses in calves/bulls, 

steers/heifers and market hog slaughter classes in July 2011.

In addition to the Salmonella verification testing program, for the thirteen months from August 

2010 to August 2011, FSIS conducted a Salmonella baseline study on market hog

establishments. The program was designed to estimate the percent positive and level of 

microbiological pathogens and indicator bacteria on market hog carcasses, as well as to estimate 

the national prevalence of Salmonella in market hogs. The program collected 3,920 sponge 

samples from market hog carcasses (1,960 at Pre-Evisceration and 1,960 at Post-Chill from 2

separate shifts when available) at 152 establishments that slaughtered market hogs under Federal 

Inspection.

Table 3-18 presents the Salmonella percent positive for HIMP and non-HIMP market hog

establishments at pre-evisceration and post-chill. The difference between HIMP and the 21 nonHIMP comparison establishments is not statistically significant (Two Sided Exact Fisher p 

=0.55). This result is probably attributable to the small sample size relative to the low Salmonella

positive rate. The difference between 5 HIMP market hog establishments and all 147 non-HIMP 

market hog establishments in the baseline study (includes the 21 non-HIMP comparison 

establishments) (0.65% versus 3.05%) is highly statistically significant (Two Sided Exact Fisher 

p < 0.00001).

31
Table 3- 18 Salmonella Positive Rate from Market Hog Baseline Study (August 2010-

August 2011)

Pre-evisceration Post-chill

Plant Type Number

of

Positives

Number 

of

Samples

Salmonella

Percent 

Positive

Number

of

Positives

Number 

of 

Samples

Salmonella 

Percent 

Positive

5 HIMP 

Plants 176 288 61.11% 2 288 0.69%

21 NonHIMP 

Comparison 

Plants 915 1,189 76.96% 16 1,189 1.35%

All 147 

Non-HIMP 

Plants in 

Baseline 

Study 1189 1672 71.11% 51 1672 3.05%

3.3.4 Chemical Residue Sampling

FSIS conducts tests for chemicals—including antibiotics, sulfonamides, and various other drugs, 

pesticides and environmental chemicals—in meat, poultry and egg products destined for human 

consumption. Directed chemical residue testing consists of sampling tissue from randomly 

selected food animals. Directed sampling tasks are generated from FSIS Headquarters for the 

National Residue Program. Table 3-19 presents the number of directed chemical residue samples 

per market hog establishment. As can be expected under random sampling, the number of 

scheduled directed chemical residue samples per market hog establishment is about the same in 

HIMP and non-HIMP market hog establishments.

Table 3- 19 Directed Residue Samples at HIMP and Non-HIMP Market Hog 

Establishments

Year

Directed Residue Samples

HIMP Non-HIMP

Number

of 

Plants

Number

of 

Samples

Samples per 

Plant

Number

of 

Plants

Number

of 

Samples

Samples per 

Plant

2006 4 13 3.25 20 99 4.95

2007 5 55 11.00 21 226 10.76

2008 5 52 10.40 21 311 14.81

2009 5 68 13.60 21 271 12.90

2010 5 126 25.20 21 553 26.33

2012 5 116 23.20 21 545 25.95

2013 5 128 25.60 21 568 27.05

32
Inspector generated chemical residue sampling is a targeted sample as it occurs when the in-plant 

Public Health Veterinarians (PHVs) suspect that an animal may have a violative level of a 

chemical residue. When a chemical residue sample is collected, the carcass is held pending the 

results of laboratory testing, and if a carcass is found to contain violative levels of residues, the 

carcass is condemned.

Table 3-20 presents the number of inspector generated chemical residue samples in HIMP and 

non-HIMP market hog establishments for the years CY2009 - CY2010 and CY2012 – CY2013.

On average inspectors at HIMP market hog establishments collected 2.7 times more chemical 

residue samples than inspectors at non-HIMP market hog establishments for CY2009 – CY2010 

and 1.7 times more for CY2012 – CY2013.

Table 3- 20 Inspector Generated Sampling at HIMP and Non-HIMP Market Hog 

Establishments CY2009 - CY2013

HIMP Non-HIMP

Year Number

of 

Plants

Number

of 

Samples

Samples per 

Plant

Number

of 

Plants

Number

of 

Samples

Samples per 

Plant

2009 5 1,858 371.60 18 2,861 158.94

2010 4 2,515 628.75 19 3,945 207.63

2012 5 2,916 583.20 21 7,561 360.05

2013 5 3,094 618.80 21 7,509 357.57

Over the period CY2006-CY2010, there were 6 violative levels of chemical residues in the 21 

traditional non-HIMP market hog establishments and none in the 5 HIMP market hog

establishments. (0 violations per plant per year in HIMP versus 0.057 in non-HIMP) This 

difference is not statistically significant (Two-Sided Exact Fisher p = 0.067).

Over the period CY2012-CY2013, there were 9 violative levels out of 6,010 chemical residue 

samples (0.15%) in the 5 HIMP market swine establishments and 115 violative levels out of 

15,070 samples (0.76%) in the 21 non-HIMP market swine establishments (1.5 violate chemical 

residue samples per billion HIMP pounds slaughtered versus 4 per billion non-HIMP pounds 

slaughtered). This difference is statistically significant (Two-Sided Exact Fisher p < 0.0001).

This finding suggests that HIMP market hog establishments are exercising active control of 

potential chemical residue hazards in their products. This approach may result from better 

control over contract grower relationships by HIMP market hog establishments.

33
4.0 CONCLUSION

The objective of this report is to evaluate Food Safety and Inspection Service (FSIS) inspection 

findings in market hog slaughter establishments participating in the Hazard Analysis and Critical 

Control Point (HACCP) Inspection Models Project (HIMP) and to determine whether the HIMP 

inspection system is performing as well as the existing inspection system in terms of safety and 

wholesomeness of the products produced and of overall consumer protection. The evaluation is 

based on two time periods: the years CY2006 - CY2010 and the years CY2012 - CY2013. The 

evaluation compares the 5 HIMP market hog establishments with a comparison set of 21 nonHIMP market hog slaughter establishments selected to be comparable with HIMP market hog

establishments with respect to production volume, line speed, and days of slaughter operation.

This report finds that HIMP market hog establishments are receiving more off-line food safety 

related inspection verification checks than the traditional non-HIMP market hog establishments.

HIMP market hog establishments have higher compliance with Sanitation SOP and HACCP 

regulations, lower levels of non-food safety defects, equivalent or better Salmonella verification 

testing positive rates than traditional non-HIMP market hog establishments, and lower levels of 

violative chemical residues. This report finds that under HIMP, market hog establishments are 

receiving an increased level of Sanitation SOP and HACCP inspection. The assumption is made 

that the number of inspection tasks performed per establishment is correlated with production of 

a safe product. The FSIS risk assessments on poultry slaughter (FSIS 2008, 2012, 2014) found 

that more off-line procedures were associated with lower Salmonella and Campylobacter 

prevalence and an increase in public illnesses avoided. Moreover, it is certainly the case that the 

more inspection tasks are performed, the more likely it is that any food safety defects will be

identified by inspection personnel and then dealt with by the establishment. 

Before beginning HIMP, FSIS developed Food Safety (FS) and Other Consumer Protection 

(OCP) performance standards that HIMP market hog establishments should meet (FSIS 2000, 

Cates et al 20014

). To enhance the likelihood that HIMP market hog establishments are 

complying with food safety and OCP performance standards, FSIS has increased the number of 

daily off-line verifications of market hog carcasses from 11 per line in non-HIMP market hog 

establishments to 24 per line in HIMP. For this report, FSIS requested that the District Offices 

provide the paper records stored at individual facilities that inspectors keep on FS and OCP for 

in-plant inspections for the two periods CY2009-CY2010 and CY2012-CY2013. The request 

was limited to these two time periods so as to limit the impact on field personnel. The year 

CY2011 was not included since it is not included in the rest of this evaluation.

A summary of results follows:

• Food safety conditions (FS-1) due to carcasses affected by systemic disease conditions 

such as toxemia and septicemia in HIMP market hog slaughter establishments are below 

1 per 10 thousand carcasses in CY209-CY2010 and are less than 3 in 100 thousand in 

CY2012 and CY2013. Food safety conditions (FS-2), carcass contamination with fecal 

material, ingesta, and milk, were below 6 per 10 thousand carcasses in CY2009-CY2010

and are below 5 per 10 thousand carcasses in CY2012-CY2013.

4 RTI began collecting baseline organoleptic and microbiological data in August 1998, before HIMP program began. 

34

 
• Food safety conditions (FS-3), systemic disease in live animals such as neurologic 

conditions found at ante-mortem, were zero in CY2009-CY2010 and are less than 1 in 10 

thousand for CY2012-CY2013.

• OCP conditions, localized disease conditions such as arthritis (OCP-1 defects), cystic 

kidneys (OCP-2 defects), and bruises (OCP-3 defects), in HIMP market hog 

establishments average about one-half the corresponding OCP performance standards.

• In CY2006-CY2010, the W3NR noncompliance rates for standard SOP and HACCP 

were about 1.2 times higher in HIMP market hog establishments than in non-HIMP 

market hog establishments. In CY2012 and CY2013 the health-related (PHR) 

noncompliance rates for SSOP and HACCP were 1.1 times lower in HIMP market hog

establishments than in non-HIMP market hog establishments. 

• The Salmonella positive rates in HIMP market hog establishments are lower than those in 

non-HIMP comparison establishments for the years CY2006 to CY2009 but higher in 

CY2010. However, the differences are not statistically significant for any year

individually.

• In the thirteen month (August 2010 to August 2011) Salmonella baseline study on market 

hog establishments, the Salmonella positive rate post-chill for HIMP market hog 

establishments is 0.5 times lower (0.69% versus 1.35%) than in the 21 comparison nonHIMP market hog establishments. This difference is not statistically significant, probably 

because of the large sample sizes required to show significant difference between low 

Salmonella rates. The difference between HIMP market hog establishments and all other 

establishments in the baseline study (0.65% versus 3.05%) is highly statistically 

significant (Two Sided Exact Fisher p < 0.00001).

• On average inspectors at HIMP market hog establishments collected 2.7 times more 

chemical residue samples than inspectors at non-HIMP market hog establishments. Over 

the period CY2006-CY2010, there were 6 incidences of violative levels of chemical 

residues in the 21 traditional non-HIMP market hog establishments and none in the 5 

HIMP market hog establishments.

• In the period CY2012 to CY2013, there were 9 violative levels out of 6,010 chemical 

residue samples (0.15%) in the 5 HIMP market hog establishments and 115 violative 

levels out of 15,070 samples (0.76%) in the 21 non-HIMP market hog establishments

(1.5 violate chemical residue samples per billion HIMP pounds slaughtered versus 4 per 

billion non-HIMP pounds slaughtered). This result suggests that HIMP market hog 

establishments are exercising active control of potential chemical hazards in their 

products.

FSIS's evaluation found that market hog slaughter establishments participating in HIMP are 

performing as well as comparable large non-HIMP market hog establishments and meeting FSIS 

expectations for the overall HIMP project. On this basis, FSIS sees no reason to discontinue 

HIMP in market hog establishments. 

35
5.0 REFERENCES

1. Cates SC, Anderson DW, Karns SA, Brown PA. Traditional versus hazard analysis and 

critical control point-based inspection: results from a poultry slaughter project. J Food 

Prot. 2001 64 (6):826-32.

2. Food Safety Inspection Service (FSIS 2008) FSIS Risk Assessment for Guiding Public 

Health-Based Poultry Slaughter Inspection 

http://www.fsis.usda.gov/wps/wcm/connect/07c57a64-932f-4ebb-977b2b10e45a1830/Poultry_Slaughter_Risk_Assess_Jan2008.pdf?MOD=AJPERES

3. Food Safety Inspection Service (FSIS 2000), HACCP-Based Inspection Models Project 

(HIMP): Performance Standards for Young Turkey, Young Chicken, and Market Hog 

HIMP Plants. http://www.fsis.usda.gov/OPPDE/rdad/FRPubs/00-042n.htm

4. Food Safety Inspection Service (FSIS 2012), FSIS Risk Assessment for Guiding Public 

Health-Based Poultry Slaughter Inspection. 

http://www.fsis.usda.gov/wps/wcm/connect/8f374626-ee06-49d3-9d41-

6eb65ad32cbb/Poultry_Slaughter_Risk_Assess_Aug2012.pdf?MOD=AJPERES

5. Food Safety Inspection Service (FSIS 2014), FSIS Risk Assessment for Guiding Public 

Health-Based Poultry Slaughter Inspection: An Implementation Scenario-Based 

Approach. http://www.fsis.usda.gov/wps/wcm/connect/5eab5fe5-e113-491c-afc7-

c4d351443679/PSRA+-++2014-07-30+-+Final.pdf?MOD=AJPERES

4. General Accounting Office (GAO) 2013, More Disclosure and Data Needed to Clarify 

Impact of Changes to Poultry and Hog Inspections 

http://www.gao.gov/assets/660/657386.txt

5. Office of the Inspector General (OIG) 2013, Food Safety and Inspection Service —

Inspection and Enforcement Activities At Hog Slaughter Plants. 

http://www.usda.gov/oig/webdocs/24601-0001-41.pdf

36
6.0 APPENDIX

Appendix A-Differences Between PBIS and PHIS Information Systems

Differences between PBIS and PHIS include the following:

• Inspection verifications in PBIS and PHIS are recorded differently. In PBIS, verifications 

were recorded under the proper inspection task code, but the exact regulation verified was

recorded only if the establishment was noncompliant. Thus, with PBIS data, it was

possible to determine how many times a particular inspection task was performed, and 

how many times an establishment was noncompliant with a particular regulation, but not 

how many times a particular regulation was verified. In PHIS, the regulation number of 

each verification is recorded along with whether it was compliant or not. Thus, in PHIS, 

it is known how many times a particular inspection task was performed, how many times 

particular regulation was verified, and how many times an establishment was 

noncompliant with a particular regulation.

• Some inspection task codes changed during the transition from PBIS to PHIS. For 

example, the inspection task codes 01A01, 03A01, 03J01, 05A01, and 06D01 that were 

used in PBIS are not used in PHIS (See Appendix B for a description of the procedure 

codes.). The verifications performed under these PBIS procedure codes are now 

preformed under different PHIS procedure codes. In addition, some new inspection task

codes were added to PHIS and are not in PBIS.

• Noncompliances rates are computed differently for data from PBIS than from PHIS. For 

PBIS data, noncompliance rates are computed as the total noncompliances for a given 

regulation divided by the total number of inspections for all regulations (This is because 

PBIS only records that an inspection was performed, but not the regulation verified, not 

unless the establishment was noncompliant with the regulation.) In PHIS, noncompliance 

rates are computed as the total noncompliances for a given regulation divided by the total 

number of inspection verifications for that regulation (this is because in PHIS the 

regulation number is recorded for each verification.) The result of this difference is that 

the noncompliance rates for the same regulation under PBIS and PHIS are not directly 

comparable.

• PBIS and PHIS use different lists of the most serious health-related regulations. PBIS 

used the list of W3NRs which was selected by a group of FSIS experts, while PHIS uses 

an updated list of Public Health Regulations (PHRs) that was derived through a more 

transparent and data-driven approach that identifies regulations that have statistically 

significantly higher noncompliance rates in the three months before Salmonella,

Escherichia coli O157: H7, or Listeria monocytogenes (Lm) positives.

In the PBIS dataset (CY2006 to CY2010) there are 11 FSIS off-line verification inspection 

procedures that apply to all market hog slaughter establishments. Each inspection procedure has 

an associated code and the procedures determine the type of inspection activities that FSIS 

personnel perform to verify compliance with specific regulatory requirements. The 11 

verification inspection procedures considered in this HIMP study for CY2006 to CY2010 are:

37
• Verify an establishment’s compliance with the sanitation SOP regulations in 9 CFR 

Sections 416.11 through 416.16 (procedure codes 01A01, 01B01, 01B02, 01C01, 

01C02);

• Verify compliance with the HACCP regulations in 9 CFR Part 417 (procedure codes 

03A01, 03J01, and 03J02);

• Verify compliance with livestock product examination (procedure code 04C03); 

• Verify compliance with generic E. coli testing requirements under 9 CFR 310.25

(procedure code 05A01); and

• Verify compliance with the Sanitation Performance Standards regulations in 9 CFR 

416.1-416.6 (procedure code 06D01).

Under the PHIS dataset (CY2012 to CY2013) there are 9 FSIS off-line verification inspection 

procedures that apply to all market hog slaughter establishments. The 9 verification inspection 

procedures considered in this HIMP study for CY2012 to CY2013 are:

• Verify an establishment’s compliance with the sanitation SOP regulations in 9 CFR 

416.11-416.16 (procedure codes 01B01, 01B02, 01C01, 01C02);

• Verify compliance with the HACCP regulations in 9 CFR Part 417 (procedure codes 

03C02, 03J02);

• Verify livestock zero tolerance verification 9 CFR 310.18 (procedure code 03J03);

• Verify compliance with generic E. coli testing requirements under 9 CFR 310.25 

(procedure code 01E01); and

• Verify compliance with the Sanitation Performance Standards regulations in 9 CFR 

416.1-416.6 (procedure code 01D01) and

There are eight inspection procedures in PBIS associated with activities that FSIS inspectors 

perform to verify compliance with the sanitation SOP and HACCP regulations. These are 

01A01, 01B01, 01B02, 01C01, 01C02, 03A01, 03J01, and 03J02.

There are six inspection procedures in PHIS associated with activities that FSIS inspectors 

perform to verify compliance with the sanitation SOP and HACCP regulations. These are 

01B01, 01B02, 01C01, 01C02, 03J02, and 03J03.

38
Appendix B- Description of PBIS Inspection Task Codes

FSIS inspectors perform inspection verification procedures to verify that establishments are 

executing their sanitation standard operating procedures (SSOP) and hazard analysis and critical 

control point (HACCP) system as specified under federal regulations 9 CFR 416 and 9 CFR 417. 

Table B-1 presents a summary of the 11 PBIS procedure codes considered in this study.

Table B- 1 PBIS Procedure Codes And Procedure Code Descriptions

Procedure Code Description

01A01 Verify that establishment has met regulations for development or 

maintenance of sanitation standard operating procedures (SSOP)

01B01 Pre-operational review of establishment’s SSOP records to verify daily 

documentation of implementation and monitoring of SSOP procedures and 

required corrective actions. 

01B02 Pre-operational review and observation of SSOP including implementation 

and monitoring, maintenance, corrective actions, and recordkeeping. 

Observe sanitation conditions; check one or more areas to ensure 

establishment is clean.

01C01 Review establishment’s operational SSOP records to verify that the 

regulatory requirements for operational sanitation are met. Ensure 

monitoring activities are conducted at required frequency, that the 

corrective actions are initiated to prevent direct contamination, and that 

records are being authenticated. 

01C02 The 01C02 procedure is for operational SSOP verification. It is the same as 

the 01B02 procedure except that it is conducted during operations. It 

inspects one or more areas of the establishment to ensure procedures are 

effective in preventing direct contamination or other adulteration of 

product, observes the establishment perform the monitoring procedures, 

and compares finding to what the establishment has documented.

03A01 Determine establishment met regulation requirements for development and 

implementation of hazard analysis critical control point (HACCP) Plan(s)

03J01 Verify one or more HACCP requirements for monitoring, verification, and 

recordkeeping at a slaughter establishment. The 03J01 procedure is 

designed to provide a “snapshot” of the HACCP system. A 03J01 

noncompliance necessitates performing a 03J02 procedure. 

FSIS Directive 5000.1

03J02 Verify all HACCP requirements at all critical control points in the HACCP 

establishment for a specific production. Verify that the pre-shipment 

review requirements for that specific production have been met. 

FSIS Directive 5000.1

04C04 Verify that poultry slaughter establishments comply with the relevant 

regulations for poultry finished product standards and good commercial 

practices for poultry slaughter 

05A01 Review establishment E. Coli records to determine maintained accuracy in 

accord with regulation—verifies compliance with the basic regulatory 

requirements for E. coli testing in slaughter establishments.

39
Procedure Code Description

06D01 Verify compliance with Sanitation Performance Standards requirements --

addresses the manner in which establishments must be operated and 

maintained to prevent the creation of insanitary conditions, thereby 

ensuring that insanitary conditions are not created, and that product is not 

adulterated.

Table B-2 presents a summary of the 9 PHIS procedure codes considered in this study.

Table B- 2 PHIS Inspection Task Code Description

Inspection Task 

Code

Guidance

01B01 Pre-operational Sanitation SOP verification by review of establishment 

records

01B02 Review the establishment's SSOP and become familiar with the procedures

01C01 Verify operational SSOP records

01C02 Verification of the establishment's operational SSOP

01D01 Verification of the sanitation performance standards

01E01 Generic E. coli Verification

03C02 Verify all 5 HACCP regulatory requirements at all CCPs for specific 

production

03J02 Verification of all 5 HACCP regulatory requirements through the 

review/observation and recordkeeping components.

03J03 Verification of zero tolerance for feces, milk, ingesta on livestock 

carcasses

40
Appendix C: Regulations Descriptions for Market Hog Establishments

Table C-1 provides a list of the 31 mandatory federal regulations that apply to market hog

establishments.

Table C- 1 Mandatory Regulations for Market Hog Establishments

Regulation Regulation Description

310.18 Contamination of carcasses, organs, or other parts

416.1 Operate in a manner to prevent insanitary conditions

416.14 Evaluate effectiveness of SSOP's & maintain plan

416.12(a) develop written procedures

416.13(a) conduct pre-op procedures

416.13(b) conduct other procedures listed in the plan

416.13(c) plant monitors implementation of SSOP procedures

416.16(a) daily records required, responsible individual, initialed and dated

416.16(b) records OK on computers

416.16(c) location and retention of records maintained

417.2(c)(4) List of procedures & frequency

417.2(c)(5) contents of HACCP plan/corrective action

417.2(c)(6) Record keeping system

417.2(c)(7) List of verification procedures/frequency

417.3(a)(1) Identify and eliminate the cause

417.3(a)(2) CCP is under control

417.3(a)(3) Establish measures to prevent recurrence

417.3(a)(4) No adulterated product enters commerce.

417.3(b)(1) Segregate and hold the affected product

417.3(b)(2) Determine the acceptability of the affected product

417.3(b)(3) No adulterated product enters commerce

417.3(b)(4) Reassessment

417.3(c) Document corrective actions

417.4(a)(2)(i) Calibrate process-monitoring instruments

417.4(a)(2)(ii) Direct observations

417.4(a)(2)(iii) Records Review

417.5(a)(1) Written hazard analysis

417.5(a)(2) Written HACCP plan

417.5(a)(3) Records documentation and monitoring of CCP's and Critical Limits

417.5(b) Annotated at time of event

417.5(c) Review prior to shipment

PBIS and PHIS use different lists of the most serious health-related regulations. PBIS used the 

list of W3NRs which was selected by a group of FSIS experts, while PHIS uses an updated list 

of Public Health Regulations (PHRs) that was derived through a more transparent and datadriven approach that identifies regulations that have higher noncompliance rates in the three 

months before Salmonella, E. coli O157: H7, or Listeria monocytogenes (Lm) positives. There 

are 33 PHRs, but only 28 PHRs apply to market hog establishments. Table C-2 provides a list of 

the 28 PHRs that apply to market hog establishments.

41
Table C- 2 Public Health Regulations (PHRs) for Market Hog Establishments

Regulation Regulation Description

381.83 Septicemia or toxemia

416.1 Operate in a manner to prevent insanitary conditions to ensure 

product is not adulterated

416.14 Evaluate effectiveness of SSOP's & maintain plan

416.6 Any room, compartment, equipment or utensil found insanitary or 

could create adulterated product must be marked with a US 

Rejected tag and cannot be used until made acceptable. Only FSIS 

program employee may remove "U.S. Rejected" tag

301.2_Adulterated The term adulterated applies to any carcass, part thereof, meat or 

meat food product under one or more of the following 

circumstances:

381.144(a) Packaging materials not to be composed of any poisonous or 

deleterious substance

381.65(a) Operations must adhere strictly to clean and sanitary practices; 

products must not be adulterated

381.91(a) Certain contaminated carcasses to be condemned

381.91(b) Reprocessing of carcasses contaminated with digestive tract 

contents must be under the supervision of an inspector and 

thereafter found not to be adulterated. 

416.15(a) Appropriate corrective actions

416.15(b) Corrective action, procedures for

416.16(a) Maintain daily records documenting the implementation and 

monitoring of SSOP and corrective actions taken

416.3(b) Constructed, located & operated in a manner that does not deter 

inspection to determine sanitary condition 

416.4(d) Product processing, handling, storage, loading, unloading, and 

during transportation must be protected

417.2(c)(4) List of procedures & frequency must be in the HACCP plan

417.3(a)(1) Identify and eliminate the cause

417.3(a)(2) CCP is under control

417.3(a)(3) Establish measures to prevent recurrence

417.3(a)(4) No adulterated product enters commerce.

417.3(b)(1) Segregate and hold the affected product following unforeseen 

event

417.3(b)(3) No adulterated product enters commerce following unforeseen 

event

42
Regulation Regulation Description

417.3(c) Document corrective actions

417.4(a) Adequacy of HACCP in controlling food safety hazards

417.4(a)(1) Initial validation

417.4(a)(3) Reassessment, at least annually or when necessary

417.4(b) Reassessment of hazard analysis

417.5(a)(1) Establishment shall maintain a written hazard analysis

417.5(a)(3) Records documentation and monitoring of CCP's and Critical 

Limits as prescribed in the HACCP plan

43
Appendix D: HIMP Market Hog Performance Standards

The appendix presents the performance standard categories and performance standards for HIMP 

market hog slaughter establishments.

Table D- 1 Market Hog Performance Standards for HIMP Market Hog Establishments

Performance Standard Categories Plant Performance Standards

FS-1—Condition – Infectious (for example: 

septicemia/toxemia, pyemia, cycticercus)

Zero

FS-2 – Condition – Digestive Content/Milk (for 

example: fecal material, ingesta, milk)

Zero

FS-3 – Ante-mortem Suspect (for example: neurologic 

conditions, moribund, pyrexic, severe lameness)

Zero

OCP-1 – Carcass- Pathology* (for example: arthritis, 

emaciation,, erysipelas,localized abscess, mastitis, 

metritis, mycobacteriosis [M Avium], neoplasms, 

pericarditis, pleuritis,pneumonia, uremia)

4.1%

OCP-2 – Visceral Pathology* (for example: cystic 

kidneys, enteritis/gastritis, fecal contamination of 

viscera, nephritis/pyelonephritis, parasites – other than 

Cysticercus, peritonitis)

7.2%

OCP-3 – Miscellaneous (for example: anemia, bile, 

bruise, edema, external mutilation, fractures, icterus, 

odor, skin lesions, scabs, toenails not removed)

20.5%

44
Appendix E: Inspection Procedures Performed per Establishment in HIMP 

and Non-HIMP Market Hog Establishments Under PBIS CY2006 through 

CY2009

The appendix presents the inspection procedures performed per establishment in HIMP and NonHIMP market hog slaughter establishments for the individual years CY2006 through CY2009.

Table E- 1 Inspection Procedures Performed per Establishment in HIMP and Non-HIMP 

Market Hog Establishments Under PBIS in CY2006

Procedure Code 5 HIMP Market Hog 

Establishments

(Procedures/ 

Establishment)

21 Non-HIMP Market 

Hog Comparison 

Establishments 

(Procedures/

Establishments)

HIMP/NonHIMP Ratio

01A01 3.2 3.8 0.8

01B01 224.8 150.0 1.5

01B02 159.0 134.2 1.2

01C01 258.6 261.2 1.0

01C02 358.4 312.8 1.1

03A01 1.2 1.9 0.6

03J01 549.6 124.4 4.4

03J02 188.6 148.9 1.3

04C03 0.0 0.0 0.0

04C04 0.0 0.0 0.0

05A01 0.4 1.2 0.3

06D01 205.8 143.2 1.4

CY2006 Total for 

Procedures 1949.6 1281.7 1.5

CY2006 Total for SSOP 

and HACCP Procedures 1743.4 1137.2 1.5

45
Table E- 2 Inspection Procedures Performed per Establishment in HIMP and Non-HIMP 

Market Hog Establishments Under PBIS in CY2007

Procedure Code 5 HIMP Market Hog 

Establishments

(Procedures/ 

Establishment)

21 Non-HIMP Market 

Hog Comparison 

Establishments 

(Procedures/

Establishments)

HIMP/Non

HIMP Ratio

01A01 4.2 3.0 1.4

01B01 199.8 161.6 1.2

01B02 161.0 133.6 1.2

01C01 245.8 275.6 0.9

01C02 347.8 314.4 1.1

03A01 2.2 2.0 1.1

03J01 621.2 127.6 4.9

03J02 187.8 149.0 1.3

04C03 160.0 106.9 1.5

04C04 0.0 2.1 0.0

05A01 1.2 1.0 1.2

06D01 174.8 145.0 1.2

CY2007 Total for 

Procedures 2105.8 1421.8 1.5

CY2007 Total for SSOP 

and HACCP Procedures 1769.8 1166.8 1.5

46
Table E- 3 Inspection Procedures Performed per Establishment in HIMP and Non-HIMP 

Market Hog Establishments Under PBIS in CY2008

Procedure Code 5 HIMP Market Hog 

Establishments

(Procedures/ 

Establishment)

21 NonHIMP Market 

Hog Comparison 

Establishments 

(Procedures/ 

Establishments)

HIMP/Non

HIMP Ratio

01A01 2.8 3.1 0.9

01B01 186.4 158.3 1.2

01B02 151.4 136.8 1.1

01C01 239.0 277.8 0.9

01C02 341.6 313.5 1.1

03A01 5.6 3.4 1.6

03J01 630.2 122.3 5.2

03J02 192.4 157.9 1.2

04C03 204.0 152.6 1.3

04C04 0.0 4.7 0.0

05A01 0.6 0.6 1.1

06D01 170.0 149.2 1.1

CY2008 Total for 

Procedures 2124.0 1480.2 1.4

CY2008 Total for SSOP 

and HACCP Procedures 1749.4 1173.1 1.5

47
Table E- 4 Inspection Procedures Performed per Establishment in HIMP and Non-HIMP 

Market Hog Establishments Under PBIS in CY2009

Procedure Code 5 HIMP Market Hog 

Establishments

(Procedures/ 

Establishment)

21 NonHIMP Market 

Hog Comparison 

Establishments 

(Procedures/ 

Establishments)

HIMP/Non

HIMP Ratio

01A01 2.0 2.5 0.8

01B01 173.0 153.8 1.1

01B02 154.8 136.8 1.1

01C01 236.2 275.0 0.9

01C02 331.0 306.0 1.1

03A01 2.0 3.1 0.6

03J01 626.8 128.0 4.9

03J02 178.8 154.9 1.2

04C03 210.6 164.5 1.3

04C04 0.0 5.1 0.0

05A01 0.6 0.8 0.7

06D01 164.8 144.2 1.1

CY2009 Total for 

Procedures 2080.6 1474.9 1.4

CY2009 Total for SSOP 

and HACCP Procedures 1704.6 1160.2 1.5

48