What Is FSIS Notice 42-25?
In September 2025, the Food Safety and Inspection Service (FSIS) issued Notice 42-25, updating how inspectors conduct and document pre-operational sanitation verification. On paper, it's a four-page notice. In reality, it's a significant shift in how both USDA inspectors and establishments must think about sanitation verification.
This notice updates portions of FSIS Directive 5000.1 Revision 6 and FSIS Directive 8000.1, clarifying:
- How inspection program personnel (IPPs) are to select and verify pre-op records,
- What constitutes "direct observation of sanitation activities," and
- How noncompliances are to be documented in PHIS.
Pre-Op Verification in Plain English
Before production starts, plants must verify that all food-contact surfaces, equipment, and rooms are clean and free of product residue. Inspectors then verify that verification — it's a two-layer check.
Notice 42-25 tightens that loop by requiring IPPs to focus on three things:
1. Observation over paper
Inspectors must observe pre-op activities directly at least once per shift per sanitation type (dry vs. wet cleaning).
2. Immediate NR documentation
If contamination is found after the establishment's pre-op release, IPPs are to issue NRs under 9 CFR 416.13(c) — not just mark "observe and notify."
3. Record verification timing
Inspectors must verify records after the plant's own verification is complete — not during active clean-up.
Key Changes From Previous Procedure
Old Expectation vs. New Under Notice 42-25:
Record Review Timing: IPPs could review pre-op records any time during the day → Now they must review records immediately after plant verification and before production begins.
Direct Observation: Was recommended "as needed" → Required once per shift per cleaning type (dry and wet).
NR Citations: NRs for contamination could cite §416.4 or §416.5 → Must be cited under §416.13(c) — failure to implement sanitation procedures.
Contamination Focus: Focus was on visible product residue → Now includes "indirect contamination risks" such as condensation, overspray, and tool storage.
What This Means for Establishments
1. More Real-Time Observation
Expect inspectors on the floor earlier — often while your QA team is still signing off pre-op. Plants should train their sanitation crew and QA leads to articulate their process when asked: "What are you verifying right now?"
2. Record Timing Matters
Since IPPs must review records right after your QA sign-off, your forms need to be ready and legible on the spot. Digital records (through U.S. AgriDocs) ensure the data is time-stamped and accessible instantly — no binder shuffle.
3. Documentation Language Is Now Scrutinized
FSIS is emphasizing what plants write in the "Results" section. Generic phrases like "OK" or "clean" won't cut it anymore. Expect inspectors to look for specific observations (e.g., "no visible residue on slicer blade, surface dry, sanitizer applied @ ppm").
Common Pitfalls Plants Should Avoid
- Late sign-offs that don't reflect actual completion times.
- Incomplete pre-op zones (e.g., missed ceiling fans or drains).
- Crew confusion when asked to describe their verification steps.
- Copy-paste records that repeat phrasing daily — FSIS may view as "lack of actual observation."
How U.S. AgriDocs Simplifies Pre-Op Verification
With U.S. AgriDocs, plants can digitally log each zone's pre-op status and auto-timestamp verifications to match the new FSIS requirements. Our system lets QA managers attach photos, note observations, and flag any corrective actions — so when IPPs review, you're already audit-proof.
Bottom Line
FSIS Notice 42-25 is not just an inspection tweak — it's a mindset shift. Plants must treat pre-op verification as a documented process, not a routine task.
Those who embrace digital tools will have nothing to fear when an inspector walks in with a clipboard and a stopwatch.