consideration may be the allocation of time for in-commerce surveillance activities by CID personnel. For example, if feasible, it may be more efficient and effective to use 100% of the time of 12 employees for in-commerce surveillance activities rather than the proposed 10% of the time of 120 employees. Employees dedicated full-time to surveillance activities could be trained to understand the high-priority businesses where they are most needed. That could facilitate collaboration with other jurisdictions. FSIS should state more clearly how it uses risk-based priorities when determining how to use the time set aside for in-commerce surveillance, both initial and followup.

  1. Establish a plan to evaluate the impact of followup surveillance to determine whether establishments are improving as a result of followup surveillance (e.g., as shown by a reduction in violations or in noncompliance) on the basis of data captured in the ICS. FSIS should develop a strategy to evaluate and validate the ICS system (for both initial and followup surveillance).

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