Comment from Jeff Emerson

I am Jeff Emerson, owner of naturalfarms, inc. plant #402 in Oklahoma I appreciate the opportunity on docket no #FSIS-2009-0019 HACCP Systems Validaiton. The agency has not provided a clear and supportable case of the existence of a food safety problem which this validation initiative will resolve. I oppose the issue of revalidation and have many concerns about the Agencys compliance guidance document. It consists of unrealistic expectations that create excesive burdens, depending on how they are implemented or potentially misinterpreted/manipulated by Agency inspection personnel, on establishments like mine. The compliance guidance document is too vague and does not adequately related to the affected industry (us being a small processor). I believe that the Agency and the meat industry may be better served if establishments focused their reassessment activities at the end of the year on ensuring that the scientific documentation identified within HACCP food safety systems relates to the hazard that is being controlled and that all pertinent critical parameters of the scientific supporting documentation are identified. Thanks for your time and consideration Jeffrey Emerson owner establishment #402 06/20/12