Should a NR be issued if the FSIS generic HACCP model was used for developing the HACCP plan?
A2: No, a NR should be issued when there is regulatory noncompliance. The generic HACCP models are intended to be used as guidance documents. A generic HACCP model may be used by an establishment to assist it in developing its HACCP plan. The important question is whether the resultant plan meets all of the applicable regulatory requirements in 9 CFR Part 417.