No meat, poultry or egg product establishment operates in the US without a Federal Grant of Inspection. We build the HACCP plan, Sanitation SOPs and documentation FSIS requires to get there.
The Food Safety and Inspection Service, FSIS, is the public health agency within the US Department of Agriculture responsible for ensuring that meat, poultry and processed egg products sold in interstate and foreign commerce are safe, wholesome and correctly labelled. FSIS operates under three founding statutes: the Federal Meat Inspection Act of 1906, the Poultry Products Inspection Act of 1968, and the Egg Products Inspection Act, amended in 1997.
Under these Acts, FSIS inspects all amenable meat, poultry and processed egg products sold in interstate commerce. Inspection covers ante-mortem inspection of the live animal, post-mortem inspection of the carcass and internal organs, and inspection of facilities, equipment, personnel, transportation and records. Inspection program personnel are present at all times in egg products plants and virtually all slaughter establishments during production, and at least part of each production day in establishments that further process meat and poultry products.
The cornerstone of modern FSIS regulation is the 1996 Pathogen Reduction, HACCP, final rule, which has two components: requirements designed to reduce the occurrence and numbers of pathogenic microorganisms on meat and poultry products, and the requirement for every establishment to develop and implement its own HACCP system under 9 CFR Part 417.
No establishment producing amenable products can operate without a Federal Grant of Inspection. Products that pass inspection bear the official mark of inspection, the consumer-facing signal that the product has been produced under FSIS oversight.
To obtain a Federal Grant of Inspection, an establishment needs to meet five core requirements before a conditional grant is issued.
A facility meeting Sanitation Performance Standards and other facility requirements under 9 CFR Part 416, 9 CFR 307.1, 9 CFR 381.36 and 9 CFR 533.3, depending on product type.
Written Sanitation Standard Operating Procedures under 9 CFR 416.12 to 416.16, covering pre-operational and operational sanitation.
A HACCP system designed under 9 CFR Part 417, identifying hazards, critical control points, critical limits, and monitoring and verification activities.
A written recall procedure under 9 CFR Part 418, describing how the establishment would remove product from commerce if needed.
FSIS label approval following the agency's labelling policies, using FSIS Form 7234-1 for applications requiring approval.
A conditional Grant of Inspection is issued when the District Manager determines the establishment meets the requirements for inspection. During the 90 calendar days that follow, the District Manager monitors the establishment through inspection program personnel and information recorded in the Public Health Information System. No sooner than 90 calendar days after issuing the conditional grant, if the District Manager determines the HACCP system has been validated under 9 CFR 417.4 and all other requirements are met, the final Grant of Inspection is issued.
A major proposed rule that would have reshaped Salmonella regulation for raw poultry was withdrawn in 2025, and FSIS is now developing a different approach.
On 7 August 2024, FSIS published a proposed rule and proposed determination that raw chicken carcasses, chicken parts, comminuted chicken, and comminuted turkey products contaminated with certain Salmonella levels and serotypes would be considered adulterated under the Poultry Products Inspection Act. After 7,089 comments during a comment period that closed 17 January 2025, FSIS withdrew both the proposed rule and the proposed determination, effective 25 April 2025.
Proposed Salmonella Framework for Raw Poultry Products formally withdrawn following review of public comments.
Secretary Rollins announces a comprehensive plan to strengthen USDA's efforts to combat foodborne illness, emphasising science-based, practical strategies.
FSIS holds a public meeting to gather input on alternative performance standard parameters and policy options, with particular attention to small and very small producers.
For poultry establishments, the practical reality is that the existing Salmonella Verification Testing Program and performance standard categories remain in place and continue to be enforced, with monthly category postings continuing on schedule. What has changed is that the more sweeping adulterant-based framework proposed in 2024 is not moving forward in its original form. Whatever replaces it is likely to draw on the input gathered through the January 2026 public meeting, including alternative performance standard parameters and approaches tailored to small and very small producers.
For establishments, this means continuing to focus on what is currently enforced, process control reflected in Salmonella performance standard category, while monitoring for whatever new framework eventually emerges. A HACCP plan and process control programme that performs well against the current categories is a reasonable foundation regardless of how the eventual framework is structured.
While the broader framework is in flux, the existing category system continues to operate and is published monthly.
FSIS samples establishments producing young chicken and turkey carcasses, raw chicken parts, and not-ready-to-eat comminuted chicken and turkey products. Based on sampling results over a reference period of one completed 52-week moving window, establishments are classified into one of three categories.
Best performance against the relevant Salmonella performance standard.
Meets the standard but with a less consistent performance history.
Not meeting the performance standard. Subject to increased scrutiny.
Individual establishment category information is posted monthly on the FSIS Salmonella Verification Testing Program Monthly Posting page, and aggregate sampling results showing the number of establishments in each category are also published. As of March 2026, this category information is also being incorporated into the Meat, Poultry, and Egg Product Inspection Directory dataset and dashboard, making it more accessible to buyers and the public. A Category 1 classification is a meaningful commercial signal as well as a regulatory one, since buyers increasingly reference these categories when evaluating suppliers.
FSIS compliance is a legal requirement for any establishment producing amenable meat, poultry or egg products for interstate or foreign commerce.
Businesses applying for a Federal Grant of Inspection for the first time, building the HACCP plan, Sanitation SOPs and other documentation required.
Existing FSIS-inspected establishments adding new products or processes that require HACCP plan updates and hazard analysis revalidation.
Operations needing to improve or maintain Category 1 status under the Salmonella Verification Testing Program.
Businesses needing to revise HACCP plans, add critical control points, or address Sanitation SOP gaps following FSIS findings.
Establishments needing HACCP plan validation support appropriate to their scale, drawing on FSIS's small plant resources and guidance.
International producers planning to export amenable products to the US, needing to understand the Grant of Inspection and equivalence framework.
We cover the full scope of FSIS consulting, from first Grant of Inspection application through to ongoing performance management.
A review of facility, Sanitation SOPs, HACCP plan, recall procedures and labelling against FSIS requirements, identifying gaps and producing a written action plan.
Development of a written HACCP plan identifying hazards, critical control points and critical limits, validated to the scientific standard FSIS expects, including post-process hazards such as post-cooking contamination.
Development of Sanitation Standard Operating Procedures and facility review against Sanitation Performance Standards under 9 CFR Part 416.
Preparation of the full documentation package for a conditional Grant of Inspection application, and support through the 90-day conditional period to final grant.
Development and testing of written recall procedures, ensuring the plan reflects current distribution and product mix.
Review of process control programmes to support improvement toward, or maintenance of, Category 1 status under the Salmonella Verification Testing Program.
Preparation of FSIS Form 7234-1 applications and supporting documentation for label approval.
Revision of HACCP plans following noncompliance records, including revalidation of hazard analysis where verification testing identifies gaps.
A full mock verification reviewing HACCP, Sanitation SOPs, SPS and records as FSIS inspection program personnel would.
HACCP plans are only as strong as the people monitoring critical control points and recording the results. Building team understanding of why each control point matters, and how to recognise when a process deviates from its critical limits, through training reduces the risk of the gaps that lead to noncompliance records. We recommend pairing this consulting programme with relevant training delivered through Confi Food, and can advise on the right approach during the initial consultation.
The process follows a defined sequence. Our part of the process typically takes a few weeks. The 90-day minimum conditional period and FSIS scheduling are set by regulation and outside our control.
| Stage | What happens | Our role | Duration |
|---|---|---|---|
| 1. Gap assessment | Facility, processes and existing documentation are reviewed against the five Grant of Inspection requirements. | We conduct the assessment and deliver a written action plan. | 2 to 3 days |
| 2. Sanitation SOPs and SPS | Sanitation Standard Operating Procedures are developed, and facility is reviewed against Sanitation Performance Standards. | We develop Sanitation SOPs and identify any facility gaps. | 3 to 5 days |
| 3. HACCP plan development | A HACCP plan is designed under 9 CFR Part 417, covering all products and processes, including post-process hazards. | We develop the HACCP plan in collaboration with your team. | 1 to 2 weeks |
| 4. Recall procedure & labels | A written recall procedure is developed under 9 CFR Part 418, and label approval applications are prepared. | We develop the recall plan and prepare label submissions. | 3 to 5 days |
| 5. Grant of Inspection application | The application package is submitted to FSIS for conditional Grant of Inspection. | We prepare and review the full submission package. | 2 to 3 days |
| 6. Conditional period | FSIS monitors the establishment for a minimum of 90 days before deciding on the final grant. | We provide support to validate the HACCP system during this period. | Minimum 90 days (FSIS-set) |
| 7. HACCP validation | The District Manager confirms the HACCP system is validated under 9 CFR 417.4. | We support validation activities and documentation. | Within conditional period |
| 8. Final Grant of Inspection | FSIS issues the final Grant of Inspection, and the establishment can use the official mark of inspection. | We remain available for ongoing compliance support. | Up to FSIS |
Our gap assessment confirms whether you're starting from scratch or operating with gaps, and reviews against the same five core areas FSIS does.
For new establishments, the assessment covers all five Grant of Inspection requirements: facility against Sanitation Performance Standards, Sanitation SOPs, HACCP plan under 9 CFR Part 417, recall procedures under 9 CFR Part 418, and label approval status.
For operating establishments, the assessment focuses on ongoing verification readiness: whether the HACCP plan still reflects current products and processes, whether Sanitation SOPs match what inspection program personnel observe in practice, and, for poultry, current Salmonella performance category and what would be needed to improve it.
We assess the facility against Sanitation Performance Standards and relevant CFR sections for your product type.
We review or develop the HACCP plan, with particular attention to hazards introduced after key control points, such as post-cooking contamination.
We review Sanitation SOPs and supporting records against what would be observed during pre-operational and operational checks.
We produce a written gap assessment with a prioritised action plan.
For establishments responding to a noncompliance record, we offer a focused review targeting the specific finding and the HACCP revalidation it requires.
The same issues appear across FSIS verification activities regardless of product type. Knowing where these gaps cluster is the most effective preparation.
A HACCP plan that dismisses a hazard such as Salmonella as not reasonably likely to occur based on cooking, without accounting for hazards introduced after cooking, such as post-cooking contamination, leaves a gap that routine verification testing can expose, sometimes resulting in suspension.
Sanitation Standard Operating Procedures that describe one set of pre-operational and operational practices, while inspection program personnel observe something different during checks, create a documentation-versus-reality gap that FSIS identifies quickly.
Facility condition issues, such as structural maintenance, drainage, or pest control, are assessed separately from process-specific HACCP controls, and can generate noncompliance records even where the HACCP plan itself is sound.
Monitoring and verification records that are completed but do not demonstrate the HACCP plan is controlling the identified hazards, particularly where a pathogen is found that the plan's monitoring did not catch, point to a gap between documentation and actual control.
A written recall procedure under 9 CFR Part 418 that has not been tested through a mock recall, or that does not reflect current distribution channels and product mix, may not function as intended if a real recall is needed.
Establishments that change products, ingredients, or processes without revalidating the HACCP plan leave hazard analysis based on a process that no longer matches current production.
FSIS jurisdiction is specific to amenable meat, poultry and egg products. Understanding where it sits relative to FDA and voluntary certification clarifies what applies to your products.
| USDA FSIS | FDA FSMA | GFSI certification (SQF, BRCGS) | |
|---|---|---|---|
| Jurisdiction | Meat, poultry, processed egg products | Most other foods | Voluntary, often layered on either |
| Inspection model | Continuous/daily on-site presence | Periodic inspection | Scheduled audits |
| Core requirement | HACCP under 9 CFR Part 417 | HARPC under 21 CFR Part 117 | Scheme-specific management system |
| Our consulting | USDA FSIS | FDA FSMA | SQF |
What drives the timeline and cost of an FSIS compliance project. We provide a written proposal with a fixed fee after the initial consultation.
Timeline
How long our consulting work takes
Cost factors
What drives the consulting fee
No existing FSIS relationship, full documentation package needed. Our consulting work typically takes 3 to 5 weeks. The 90-day minimum conditional period and FSIS scheduling are separate and outside our control.
Existing establishments responding to a specific noncompliance record needing HACCP revalidation. Our consulting work typically takes 1 to 2 weeks depending on scope.
Poultry establishments working toward or maintaining Category 1 status, focused on process control review.
A single-product, single-process establishment requires less HACCP documentation than a multi-product facility with varied processing steps.
Small and very small plants may qualify for different validation support pathways, which we factor into the proposed scope.
Establishments already certified to SQF or BRCGS often have HACCP and sanitation documentation that can be adapted toward FSIS-specific requirements.
A gap assessment only, a full Grant of Inspection package, or a focused noncompliance response each carry different fees. All scopes are defined in writing before work begins.
FSIS inspection is generally provided at no direct charge for normal operating hours, though overtime and certain export certification fees apply and are separate from our consulting fees.
Answers to the questions we hear most often from meat, poultry and egg product establishments.
The Food Safety and Inspection Service, FSIS, is the public health agency within the US Department of Agriculture responsible for ensuring that meat, poultry and processed egg products sold in interstate and foreign commerce are safe, wholesome and correctly labelled. FSIS operates under the Federal Meat Inspection Act of 1906, the Poultry Products Inspection Act of 1968, and the Egg Products Inspection Act, amended in 1997. No establishment can produce amenable meat, poultry or egg products for commerce without a Federal Grant of Inspection from FSIS, and inspection program personnel are present in virtually all slaughter establishments during production and at least part of each production day in processing establishments.
To obtain a Federal Grant of Inspection, an establishment must have a suitable facility meeting Sanitation Performance Standards and other facility requirements under 9 CFR Part 416 and related sections, a Sanitation Standard Operating Procedure under 9 CFR 416.12 to 416.16, a HACCP plan designed under 9 CFR Part 417, a written recall procedure under 9 CFR Part 418, and approved labels. A conditional Grant of Inspection is issued first, and no sooner than 90 calendar days later, once the District Manager confirms the HACCP system has been validated under 9 CFR 417.4 and all other requirements are met, a final Grant of Inspection is issued.
The Pathogen Reduction, Hazard Analysis and Critical Control Point, HACCP, final rule was issued by FSIS in 1996 and remains the cornerstone of meat and poultry inspection. It has two components: requirements designed to reduce the occurrence and numbers of pathogenic microorganisms on meat and poultry products, and the requirement for every establishment to develop and implement a HACCP system identifying food safety hazards, critical control points, critical limits, and monitoring and verification activities specific to its own products and processes.
FSIS published a proposed rule and proposed determination titled Salmonella Framework for Raw Poultry Products on 7 August 2024, which would have established that raw chicken carcasses, chicken parts, comminuted chicken, and comminuted turkey products contaminated with certain Salmonella levels and serotypes are adulterated under the Poultry Products Inspection Act. After receiving 7,089 comments during the comment period that closed on 17 January 2025, FSIS withdrew the proposed rule and proposed determination, effective 25 April 2025. Following the withdrawal, Secretary of Agriculture Brooke Rollins announced a comprehensive plan on 15 July 2025 to strengthen USDA's efforts against foodborne illness, and FSIS held a public meeting on 14 January 2026 to gather input on alternative approaches to reducing Salmonella in poultry.
The Salmonella Verification Testing Program samples establishments producing young chicken and turkey carcasses, raw chicken parts, and not-ready-to-eat comminuted chicken and turkey products, so FSIS can monitor an establishment's process control over time. Based on sampling results over a reference period of one completed 52-week moving window, establishments are classified into Category 1, 2 or 3, with Category 1 representing the best performance against the relevant Salmonella performance standard. FSIS posts individual establishment category information monthly, and these categories are also now included in the Meat, Poultry, and Egg Product Inspection Directory dataset and dashboard.
An FSIS gap assessment reviews an establishment's facility, Sanitation Standard Operating Procedures, HACCP plan, recall procedures and labelling against the requirements for a Federal Grant of Inspection or, for already-operating establishments, against ongoing verification expectations. It covers Sanitation Performance Standards under 9 CFR Part 416, hazard analysis and critical control points under 9 CFR Part 417, recall plan requirements under 9 CFR Part 418, and, where applicable, Salmonella Verification Testing Program performance category.
The most common FSIS issues are: HACCP plans that dismiss a hazard, such as Salmonella, as not reasonably likely to occur based on a process step, such as cooking, without accounting for hazards introduced afterward, such as post-cooking contamination. Sanitation SOPs not matching what inspection program personnel observe during pre-operational and operational sanitation checks. Sanitation Performance Standards issues with facility condition, such as structural maintenance or pest control, that are separate from process-specific HACCP controls. Recordkeeping that does not demonstrate the HACCP plan is controlling the hazards identified, particularly where verification testing finds a pathogen the plan's monitoring did not catch. Recall plans under 9 CFR Part 418 that have not been tested or updated to reflect current distribution.
FSIS has set 1 January 2028 as the uniform compliance date for new meat and poultry product labelling regulations published between 1 January 2025 and 31 December 2026. This uniform compliance date approach allows establishments to plan label changes arising from multiple rules together instead of responding to each rule's individual effective date separately.
Our consulting work moves fast. From gap assessment to a validated HACCP plan and Sanitation SOPs ready for submission, most establishments are there in a few weeks. The conditional Grant of Inspection process itself includes a minimum 90-day period set by FSIS regulation before a final Grant of Inspection can be issued, and FSIS review and inspection scheduling are outside our control.
Yes. Gap assessments, HACCP plan development, Sanitation SOP documentation, and Grant of Inspection application preparation are all available remotely. We work with establishments across the United States. On-site visits are available for mock inspections and where a physical review of facility layout against Sanitation Performance Standards is needed.
You can commission any of these on their own, with an agreed scope and a written quote, without taking on ongoing consulting. See all food safety services.
To check the whole operation against the law of each market.
Read about A regulatory compliance review →Where a plan exists and attracts findings.
Read about A HACCP plan review →To establish whether your controls were ever proven capable.
Read about A verification and validation review →Tell us about your products, your facility and your current FSIS status. We will tell you exactly what's needed for your Grant of Inspection.