Under 9 CFR 417, a USDA FSIS-inspected meat or poultry plant needs a hazard analysis and a HACCP plan for each product with a hazard reasonably likely to occur. Part 416 adds written Sanitation SOPs, and HACCP monitoring records are kept for at least 1 or 2 years.
This guide is for HACCP coordinators in FSIS-inspected plants and for Gulf importers who audit US suppliers.
What does 9 CFR 417 require in a HACCP plan?
FSIS covers cattle, sheep, swine, goats, equines and any domesticated bird. Before inspection starts, a plant needs written Sanitation SOPs and recall procedures, a hazard analysis and a HACCP plan (304.3 for meat, 381.22 for poultry). A conditional grant lasts up to 90 days, and the plan must be validated in that time.
The hazard analysis covers hazards before, during and after entry into the plant, with a flow chart and the intended use (417.2(a)). A hazard is "reasonably likely to occur" when a prudent establishment would control it because it has happened before or plausibly could.
A written plan is needed for each product with such a hazard. Section 417.2(b) of 9 CFR Part 417 names nine processing categories, such as slaughter, raw ground and fully cooked, not shelf stable.
FSIS tests raw beef for seven STEC serogroups and Salmonella (Directive 10010.1, Revision 6). Post-lethality exposed ready-to-eat product needs one of three Listeria Alternatives (430.4).
The plan lists seven things: hazards, critical control points (CCPs), critical limits, monitoring procedures and frequency, corrective actions, a recordkeeping system and verification procedures (417.2(c)). The responsible establishment individual signs and dates it on acceptance, on any change and at least annually on reassessment (417.2(d)). If buyers also ask for Codex HACCP, our guide covers that system.
Corrective actions remove the cause, restore control at the CCP, prevent recurrence and keep unsafe product out of commerce (417.3). Ongoing verification includes instrument calibration, direct observation and record review (417.4).
What records does FSIS expect on file, and for how long?
| Requirement | 9 CFR reference | What to keep | How long or how often |
|---|---|---|---|
| Hazard analysis | 417.2(a), 417.5(a)(1) | Written analysis, flow chart, intended use, support for each "not reasonably likely" decision | Kept current with the plan |
| HACCP plan | 417.2(b) to (d), 417.5(a)(2) | Plan per product or category, CCP and critical-limit decision documents | Signed at acceptance, at any change and at annual reassessment |
| Monitoring, calibration, corrective-action and verification records | 417.5(a)(3), (b) | Actual values with product code or slaughter lot, each entry dated, timed and initialed at the time | At least 1 year for slaughter and refrigerated product. At least 2 years for frozen, preserved or shelf-stable product |
| Pre-shipment review | 417.5(c) | Check that records are complete, limits were met and corrective actions taken, dated and signed by the reviewer | Before each shipment |
| Reassessment record | 417.4(a)(3)(ii) | Reasons for changing or not changing the plan | Each reassessment |
| Sanitation SOPs and daily records | 416.12, 416.16 | Signed SOPs with pre-operational procedures, daily records initialed and dated | Records at least 6 months |
| Poultry slaughter microbial sampling | 381.65(g), (h) | Written procedures and sampling results | At least 1 year |
| Recall procedures | 418.3 | Written recall procedures | Kept current |
Where practicable, someone who did not make the records does the pre-shipment review, preferably a HACCP-trained person or a senior plant official, and dates and signs it (417.5(c)). Monitoring and verification records may move off site after 6 months if you can produce them within 24 hours of a request (417.5(e)). Since 8 May 2012, each reassessment needs a record, but an annual one that changes nothing needs no documented basis.
What do the Sanitation SOP rules in 416.11 to 416.17 require?
Each plant writes, implements and maintains Sanitation SOPs for the daily procedures before and during operations that prevent direct contamination (416.11, 416.12). The person with overall authority on site, or someone more senior, signs and dates them at first implementation and after any change. Pre-operational procedures must at least cover cleaning food-contact surfaces, and the SOPs name frequencies and responsible employees.
The plant monitors them daily (416.13) and evaluates whether they work, revising them when facilities, equipment, operations or staff change (416.14). Corrective action covers product disposition, restoring sanitary conditions and preventing recurrence (416.15). Daily records stay on site for 48 hours, then may move off site if available within 24 hours (416.16).
Despite what some summaries say, sections 416.11 to 416.17 do not require validation. They ask for routine evaluation of effectiveness. The separate sanitation performance standards in 416.1 to 416.6 cover pest control, water, plumbing, equipment and hygiene.
What do FSIS inspectors check, and when can they suspend inspection?
Inspection program personnel work from FSIS Directive 5000.1, Revision 8, issued on 10 January 2025. Revision 8 tells inspectors to consider whether a noncompliance is linked to past findings and to look for trends that show a systemic problem. Directive 5000.6 sets the hazard analysis verification task.
Section 417.6 gives five grounds for finding a HACCP system inadequate. The plan does not meet Part 417, staff do not perform plan tasks, corrective actions are not taken, records are not kept, or adulterated product is produced or shipped.
Under Part 500, FSIS can take a withholding action or suspend inspection without prior notice. Grounds include no HACCP plan, no Sanitation SOPs, or shipped adulterated product (500.3). Multiple or recurring 417.6 findings can lead to action with prior notice, and the plant has three business days to respond (500.4, 500.5).
Where does poultry Salmonella policy stand in 2026?
FSIS proposed a Salmonella framework for raw poultry on 7 August 2024. FSIS withdrew it on 25 April 2025, held a public meeting on 14 January 2026, and had published no replacement proposal by 4 October 2026.
Breaded stuffed chicken is the exception. A final determination makes not-ready-to-eat breaded stuffed chicken with Salmonella at 1 CFU/g or more adulterated, effective 1 May 2025. FSIS first delayed its sampling to 3 November 2025, then in a notice of 2 December 2025 postponed it with no new date. The determination applies, and verification sampling waits.
Poultry Salmonella performance standards are not codified in 9 CFR, where 381.94(b) is reserved. A Federal Register notice of 11 February 2016 set them for raw chicken parts and comminuted chicken and turkey. Raw beef standards are codified in 310.25(b): 1.0% for steers and heifers, 2.7% for cows and bulls and 7.5% for ground beef.
Poultry slaughter plants already need written procedures against fecal contamination and enteric pathogens, with microbial sampling (381.65(f), (g)). Maximum line speeds under the New Poultry Inspection System are 140 birds a minute for young chickens and 55 for turkeys. A proposal of 19 February 2026 would raise them to 175 and 60, and it is still proposed.
What should a GCC importer know about US meat and poultry?
No GCC country appears on the FSIS eligible foreign establishments list, and eligibility needs an FSIS equivalence finding for the country's whole inspection system. A Gulf plant cannot qualify with a 9 CFR 417 plan alone.
US plants can ship to the Gulf, within each country's rules. The FSIS export library for the United Arab Emirates, updated 11 August 2026, says all federally inspected establishments are eligible. Saudi Arabia does not allow US poultry or pork imports, except for US diplomatic or military use, and takes beef and veal under conditions.
Halal is separate from HACCP. Halal-labelled product for the UAE needs a Certificate of Islamic Slaughter from a Muslim organisation the UAE recognises. FSIS says it is not responsible for certifying religious slaughter, and our guide to halal poultry slaughter for the UAE covers that side.
When you audit a US supplier, ask for the signed HACCP plan, the hazard analysis, the latest reassessment record, pre-shipment review records and the Sanitation SOPs.
How AGS can help
Both kits are editable Microsoft Word and Excel files, and each has a 9 CFR Part 417 compliance matrix.
- U.S. Meat HACCP Management System (9 CFR 417 & 416, USDA FSIS): 188 documents, including a HACCP plan template, six Sanitation SOP documents and 18 HACCP models.
- U.S. Poultry HACCP Management System (9 CFR 417, 416 & 381, USDA FSIS): 180 documents, including a HACCP plan template, a pre-shipment review record and 18 HACCP models.
Frequently asked questions
Who may write or reassess a HACCP plan?
Only someone who has completed a course in applying the seven HACCP principles to meat, poultry or egg products, including writing a plan and reviewing records, may do this. That person need not be your employee and may adapt a generic model (417.7).
What counts as a small or very small plant?
Since 1996 FSIS has used large for 500 or more employees, small for 10 to 499, and very small for fewer than 10 employees or annual sales under $2.5 million. A March 2026 advance notice asks whether to update them.
Does FDA's FSVP rule apply to imported meat and poultry?
No. It does not apply to meat, poultry and egg products subject to USDA at import (21 CFR 1.501(h)).
How fast must a plant report product that should not have shipped?
Within 24 hours of learning that adulterated or misbranded product has entered commerce, the plant notifies its local FSIS District Office (418.2).
AGS provides independent documentation toolkits. This guide and the referenced kits are not affiliated with, endorsed by or approved by the US Department of Agriculture or its Food Safety and Inspection Service. It is general information, not legal advice, and what applies depends on your products, processing categories and size.
Reviewed October 2026. Facts checked against the sources current at publication.
