BEEF HARVESTING (SLAUGHTER) HAZARDOUS ANALYSIS FOR SMALL & VERY SMALL USDA INSPECTED ESTABLISHMENTS - CONVENTIONAL AND RITUAL - PART 6 0F 10 PARTS
SSOP PROCEDURES FOR SRM – HARVESTING OPERATIONS
The following protocols concerning Specific Risk Materials (SRM’s) from cattle harvested at ABC Establishment is listed below;
1. Plant personnel will follow all previous SOPs.
2. Cattle harvested at our Establishment are considered to be both under and over thirty- (30) months of age.
3. SRM’s are defined as being the skull, brain, trigeminal ganglia, eyes, tonsils, vertebral column, neck bones, lumbar vertebrae, wings of the sacrum, distal ileum, spinal cord, and dorsal root ganglia.
4. Removal of the Distal Ileum – See separate SSOP procedures regarding the removal of the distal ileum as per FSIS Notice 58-05.
5. Removal of Spinal Cord – The spinal cord is removed in its entirety on the slaughter floor just prior to post evisceration steam vacuuming. Lifting of the cord tissue out of the vertebral canal is achieved by the use of a Trim Vacuum System. If any spinal cord remnant is discovered, the carcass will be retained and re-worked.
6. Any carcass that is found to be harboring fragments of SRM’s will be retained and re-worked and subject to further inspection.
7. SRM materials are separated at the earliest opportunity. SRM materials are placed into an inedible container and moved to the inedible area.
8. Any head that is retained by the USDA will be tagged and discarded. All beef heads are to be inspected by the USDA prior to condemning. The discarded head will place in inedible rendering.
9. Monitoring forms for proper SRM removal is performed.
10. SRM’s are processed through Darling International’s rendering system. The SRM’s are exposed to 275°F temperature for a minimum of one (1) hour. An annual letter is on file stating that the product will not be sold for ruminant feed.
Annual Cattle Letters of Guarantee are sent to cattle suppliers regarding Title 21 Part 589.2000 of the Code of Federal Regulations (Effective August 4, 1997) that prohibits the feeding of ruminant meat and bone meal to ruminant animals. These documents are filed in sequential order for references.
SSOP PROCEDURES FOR SPECIFIC RISK MATERIALS CATTLE UNDER AND OVER 30 MONTHS OF AGE
OVERVIEW
ABC shall abide in full to FSIS Notice 56-07, dated 8/31/2007. All previous and germane FSIS notice/Directives with regards to SRM shall be followed as well.
This SRM “Final Rule” makes permanent with certain changes, interim regulations that the FSIS issued in January 2004 to prevent potential human exposure to bovine spongiform encephalopathy (BSE) agent. Like the interim regulations, this SRM Final Rule prescribes requirements for the handling and disposition of SRM’s and requires that all non-ambulatory disabled livestock that is offered for slaughter be condemned.
All related records of the Final Rule shall be kept for approximately one- (1) year.
NON-AMBULATORY DISABLED CATTLE
q As per CFR 309.2 (b) the term downer is replaced with “non-ambulatory disabled livestock,” (NADL). NADL is defined, as being livestock that cannot rise from a recumbent position or that cannot walk, including, but not limited to, those broken appendages, severed tendons or ligaments, nerve paralysis, fractured vertebral column, or metabolic conditions.
q As per CFR 309.3(e) still requires that NADL that are offered for slaughter be condemned. However this requirement now also clarifies that the FSIS inspection personnel will determine the disposition of cattle that become non-ambulatory disabled after such cattle have passed ante-mortem inspection on a case-by-case basis.
q 9 CFR 309.13(b) does not apply to our operations – veal calves.
q As per 9 CFR 311.27 continues to prohibit for use as human food of the parts and carcasses of cattle slaughtered for humane reasons in the absence of a USDA inspector.
AIR-INJECTION STUNNING AND MS BEEF
q 9 CFR 313.15(B) (2) & 9 CFR 310.13(a) (2) (iv)(C) continues to prohibit the use of stunning devices that deliberately inject compressed air into the cranial cavity of the cattle.
q As per 9 CFR 319.5(b) continues to prohibit mechanically separated beef (MS beef) for human food. CB does not produce MS beef.
SRM REGULATIONS
q Cattle slaughtered and further processed at our establishment are in the category of both under and over thirty- (30) months of age or more.
q 9 CFR 310.22 (a) continues to define SRM’s for livestock of thirty- (30) months of age or more as being;
o Skull
o Brain
o Eyes
o Trigeminal ganglia
o Spinal cord
o The vertebral column, excluding the vertebrae of the tail, the transverse processes of the thoracic and lumbar vertebrae and the wings of the sacrum
o Dorsal root ganglia (DRG)
o Tonsils
o Distal ileum
q As per CFR 310.22(a) i.e. non-domestic livestock, this section of CFR 310.22(a) does not apply, as livestock are not processed at our establishment from another country. CB processes only domestic livestock.
q As per CFR 310.22(b) SRM’s are considered to be inedible and are not fit for human food.
q As per CFR 310.22(c) that the proper disposal of SRM’s is in accordance with 9 CFR 314.1 and 314.3. The spinal cord from cattle thirty- (30) months of age or older are removed at our establishment and properly disposed of into a rendering trailer.
q As per CFR 310.22(d) are in accordance with 9 CFR 310.22(a) (3) regarding the use of small intestine for human food.
q 9 CFR 310.22(e) requires that the process is described with written documentation for the removal, segregation, and disposition of SRM’s (9 CFR 310.22(e) (1).
q Cattle are stunned on the front of the skull with a captive bolt stunner, as per 9 CFR 313.15(b) (2) and 9 CFR 310.13(a) (2) (IV) (C). The head is de-hided and removed by cutting through the cartilage between the atlas bone and skull. Special precaution is exercised so as not to puncture the eyeballs. The beef head is placed onto a rack with the brain sucked out of the skull and is washed with cold water to remove any possible contaminants. The head is transferred to the USDA inspection rack for inspection presentation to the USDA. Afterward, the head is transported to a boning table where the tongue, cheeks, lips and head meat trimmings are removed. These meat items are placed into clean barrels marked edible. The head (skull, eyes, and trigeminal ganglia intact) are disposed into the inedible screw and directly discharged into a waiting rendering trailer outside the facility.
q Removal, (when applicable) of the distal ileum. The distal portion of the ileum, at the point of attachment to the small intestine to cecum directed proximally 80 inches towards the rumen is considered to be the SRM. Following the evisceration production stage, the small intestine is placed into a buggy and is inspected by the USDA. Following USDA inspection the buggies contents are subsequently elevated to the offal table where the small intestine is segregated from the other organs. Using a knife, approximately 80- inches or more of the uncoiled and trimmed small intestine, beginning at the ceco-colic junction, (where the large intestine meets the cecum) and moving towards the jejunum, (the middle section of the small intestine) is cut away with a knife. The distal portion of the ileum and the attachment of the small intestine towards the rumen are then disposed into an inedible chute. Following the disposal of the distal ileum into the inedible chute, the small intestine is then cut away and gathered just prior to cleaning and braiding.
q Beef tongue trimming and removal of tonsils. Following USDA inspection plant personnel will trim the beef tongue and cut out the area approximately 4 to 6 inches from the windpipe orifice in order to accurately remove the area where the tonsil is located. The areas of the tongue that are removed, lymph nodes, visible tonsils, (palatine and lingual), salivary glands and a transverse cut caudal located behind the last vallate papillae. Edible tongue trim is collected and trimmed and placed into a white edible barrel and transferred to the offal cooler for chilling. The tonsils are placed into an inedible marked barrel and disposed into the inedible screw conveyor that discharges the SRM outside the facility and into a rendering trailer.
q Removal of the spinal cord - Harvest. After the splitting of a carcass is accomplished, the spinal cord tissue is removed by using a Trim Vacuum System. The spinal tissue is automatically discharged to an outside storage tank.
q Removal of the spinal cord - Deboning. Prior to the deboning process, any residual spinal tissue is scraped with a designated scrapper and is placed into a marked inedible barrel with the contents disposed into a rendering trailer.
q Vertebral column & dorsal root ganglia (DRG) – Deboning. The vertebral column/dorsal root ganglia are processed in the deboning cooler. An upper conveyor line transfers the vertebral where residual meat is removed with a whizard knife. The vertebral is then placed onto another upper conveyor line where it’s automatically discharged into a rendering trailer.
q No carcasses or parts that have SRM’s are delivered/processed to our establishment from another establishment.
9 CFR 310.22 (f) are sanitation requirements for equipment used to cut through SRMs of livestock thirty (30) months of age or older:
q Skull, eyes, and trigeminal ganglia: Designated yellow handled knives are dipped into an SRM dedicated knife sterilizer after each head is trimmed. Sterilizer for the knives is measured at 180°F or higher. Knives, hooks, and steals are to be placed in the sterilizer a minimum of 4 to 6 seconds. The cutting table that the heads are placed and trimmed on are washed with water every five- (5) heads.
q Spinal cord: Harvest & Deboning Process: The splitting saw is sterilized with hot water that is automatically circulating during the splitting process. The spinal cord is removed directly after the splitting saw operation by the means of a Trim/Vacuum System. When applicable, yellow-colored hand-held tools are sterilized in a knife sterilizer after each carcass. Sterilizers for the hand-held equipment are measured at 180°F or higher.
q Vertebral column & dorsal root ganglia: The only affected areas where there is contact with equipment is at the Harvest splitting saw and the spinal cord removal process stations at harvest and prior to the deboning station. The sanitation requirements for the vertebral column and the dorsal root ganglia fall in the same category as the spinal cord.
q Tonsils: Yellow handled knives are dipped into a knife sterilizer (4 to 6 seconds) after each head is processed. The sterilizer is measured at 180°F or higher.
q Distal ileum: No sanitation requirements are required of this process based on the described processing of the small intestine.
q 9CFR 310.22 (g) follows FSIS Directive 6100.4, dated 9/13/2007. The shipping, (when applicable) and delivery of carcass parts that may have attached materials that are considered to be SRM’s by the USDA are to be properly removed and disposed of by the receiving Establishment.
ü A Certificate of Analysis (COA) shall be documented for every order and filed for any needed future references.
ü Each carcass part or whole carcass that is transported, (when applicable) to another establishment shall bear the mark of inspection of this establishment #007 as per FSIS Notice 38-09, dated 5/7/2009.
ü ABC shall be responsible and maintains control of the carcass part(s) while in transit. The COA will be accompanied with each delivery that identifies that the carcass parts are from livestock that is under and over 30- (thirty) months of age and states that the customer is the responsible party to remove and properly dispose of any SRM’s that remain attached.
ü The COA contains the Date, Vendor Name, Purchase Order, Seal Number, Slaughter Date, and Invoice Number.
ü The customer will sign and date each COA and note their establishment number and return the original document to our establishment thus documenting that proper removal and final disposition will take place for each carcass part received as per their HACCP, SSOP and/or Prerequisite Programs. Accurate records reflecting this procedure will be maintained by plant management of each delivery and presented to the USDA upon request.
q As per 9 CFR 310.22(h) provides that materials that are designated as SRM’s if they are from cattle 30 months of age or older be deemed as being SRM’s unless the establishment can demonstrate through documentation that the materials are from an animal that was younger than 30 months of age at the time of slaughter. This does not apply to our establishment.
MONITORING OF SRM’S
This Pre-requisite Program has been designed for the proper removal, segregation, and disposition of SRM’s. The recordkeeping forms on the following page are used to monitor SRM’s in the Harvesting and De-boning processes. Each SRM is identified with direct observations and verifications being noted verifying that each SRM is being monitored, (removed, segregated and disposed of) and addressed as per FSIS Notice 56-07, dated 8/31/07.
Any deviations to this Pre-requisite Program shall be noted on the Operational Deficiency/ Corrective Action form with a reassessment being conducted. An annual reassessment of this SSOP will be conducted at least once a year. All germane documentation of these procedures shall be available to the USDA upon request.