Putting Glass Walls on New York's Slaughterhouses So We Can See Behind Closed Doors
Hilltown Pork, Inc., New York

Address: 12948 Rt 22, Canaan, NY 12029
Establishment No.: m4018

USDA Inspection Report: 4 Nov 2010

Code: 03G02
Violation: 417.4(a)(3), 417.5(a)(1), 417.5(a)(2), 430.4(b)(3)

Citation: At approximately 1340 hours while conducting the recordkeeping component of an unscheduled 03G02 procedure task I observed the following while reviewing the establishments Fully Cooked, Not Shelf Stable HACCP plan; the establishment has not identified potential Biological Hazards (Listeria Monocytogenes (Lm), Clostridium Perfrigens) at any step of the process in the Hazard Analysis on pages 3, 4 or 5 for their Fully Cooked, Not Shelf Stable products. The establishment has identified Sleeves, Hands, Gloves, Aprons and Lugs as a potential hazard and has identified Unsanitary Conditions as the Biological Hazard at the Slice/Split step of the process but does not identify the potential Biological hazard of Lm/ Listeria Species under the Potential Hazard section of the Hazard Analysis on page 1. The Preventive Measures outlined on page 1 in the Hazard Analysis for the Slice/ Split step states "[quote redacted] ". Review of the establishment's supporting documentation, Protocol for Processing and Packaging Fully Cooked-Not Shelf Stable Products does not address/ identify all potential areas of direct product contact as identified in the Hazard Analysis or in the actual production process such as aprons, gloves, hands, sleeves and trays. The establishment has determined that no CCP's are necessary for their Fully Cooked, Not Shelf Stable program in their Hazard Analysis and has Justified their decision by stating "[quote redacted]" Raw, Not Ground) programs. On 9/15/10 the establishment had reassessed and implemented a new 03B and 03C program and thus has changed the location of their CCP from [redacted] no longer  supports the control or justification for the decisions made as stated in their Hazard Analysis and no reassessment has been conducted due to the changes that could affect the hazard analysis or alter the HACCP plan. The establishments Fully Cooked, Not Shelf Stable program was last reassessed and signed on 10/7/09. This is a failure to meet: 9CFR 417.5(a)(1), 9CFR 417.5(a)(2); 9CFR 417.4(a)(3) and 9CFR 430.4(b)(3). I verbally informed HACCP/ QC Manager, immediately of the non-compliances. This document serves as written notification that your failure to comply with regulatory requirement(s) could result in additional administrative or regulatory action.


417.4(a)(3) Reassessment of the HACCP plan. Every establishment shall reassess the adequacy of the HACCP plan at least annually and whenever any changes occur that could affect the hazard analysis or alter the HACCP plan. Such changes may include, but are not limited to, changes in: raw materials or source of raw materials; product formulation; slaughter or processing methods or systems; production volume; personnel; packaging; finished product distribution systems; or, the intended use or consumers of the finished product. The reassessment shall be performed by an individual trained in accordance with 417.7 of this part. The HACCP plan shall be modified immediately whenever a reassessment reveals that the plan no longer meets the requirements of 417.2(c) of this part.

417.5(a) The establishment shall maintain the following records documenting the establishment’s HACCP plan:
(1) The written hazard analysis prescribed in 417.2(a) of this part, including all supporting documentation;

417.5(a)(2) The written HACCP plan, including decisionmaking documents associated with the selection and development of CCP’s and critical limits, and documents supporting both the monitoring and verification procedures selected and the frequency of those procedures.

430.4(b) In order to maintain the sanitary conditions necessary to meet this requirement, an establishment producing post-lethality exposed RTE product must comply with the requirements included in one of the three following alternatives:
(3) Alternative 3. Use of sanitation measures only.


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