The days of combinatorial CCPs

By?Steve Sayer

“The world is changed by your example, not by your opinion.”

- Paulo Coelho de Souza is a brilliant Brazilian lyricist and novelist and a member of the Brazilian Academy of Letters since 2002. His sublime novel - The Alchemist - became an international best-seller.

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This USDA / FSIS HACCP story started nearly 27 years ago on Aug.1996.

Only a month earlier - the USDA / FSIS had published their ground breaking Pathogen Reduction Hazard Analysis Mega Reg Final Ruling in the Federal Register on Jul. 25, 1996 as cited below

Scene Set Up

LOCATION - South Gate, California - due east of downtown Los Angeles, California.

COMPANY - Alpha Meat Packing Company, Inc. (AMPC Est.749) was a USDA / FSIS inspected establishment that held operations six (6) days a week. I was employed at AMPC for 18 years, ending in Jan. 2000.

PRODUCTS / OPERATIONS / CUSTOMERS - Case-ready raw domestic only beef, pork / and - whole lamb carcasses imported from Australia.

When applicable, raw meats were sawed with B-16 Butcher Boy table saws and an AEW carcass breaking saw; knife trimming and packaged / labeled to specifications as per the multiple customers - and - USDA / FSIS regulations.

No allergens, no injections.

A very simple and straight forward process.

All fresh meats were placed onto various sized styrofoam trays with soaker pads, when applicable, and were over-wrapped / heat sealed by automatic wrapping machines and were placed into a 2 mil. thick plastic Master Pack that were hermetically sealed after being injected with a food grade Tri-mix gas utilizing the 'suck-out and flush-in' CVP equipment.

AMPC's customers were several major supermarket outlets in California / parts of Nevada and Arizona. All raw meats were muscle meat cuts that included beef, lamb, pork and then the very popular offal items.

AMPC had eight (8) production lines and on average - 110 employees - of which 100 were production employees (including departmental QA / QC heads) with the remaining ten (10) employees being drivers, maintenance, night time sanitation, shipping / receiving and office / management staff.

RAW PRODUCT SUPPLIERS - Farmer John (FJ), a vertically integrated pork harvesting (slaughter) establishment located in Vernon, California - supplied AMPCs fresh pork loins (rib end / sirloin attached) delivered on stainless steel racks (each rack holding 100 pork loins) on wheels with a blue plastic cover that extended down to the top of the wheels for added protection during delivery.

FJ squared-off Pork butts were delivered boxed with food grade paper as were such pork offal items such as raw pig tails, snoots, stomachs, and hocks.

Monfort / ConAgra out of Colorado supplied AMPC with boxed 4-bone beef short ribs, flanks, skirt steaks (inside / outside), beef hocks and beef offal items such as number 1 tongues, bleached regular / honeycomb tripe, beef hearts, spleens, liver, and beef neck bones - that arrived sealed in cry-o vac.

AMPC also performed fine grind to the lamb trimmings and utilized a grinder and Hollymatic patty machine - as the finished lamb patties were over-wrapped, labeled and placed into Tri-mix gas bags.

The only added feature - at that time - was a USDA pre-approved Partial Quality Control Program (PQC) fat test - performed daily - in house - to ensure the lamb patties never exceeded 30% fat.

AMPC also had in place three (3) other USDA pre-approved PQC programs regarding;

Choice graded / labeled beef;

Boneless meat Inspection for pork / lamb / beef;

And a catch-weight program which pacified AMPC's regulatory requirements with USDA / FSIS.

AMPC (classified as a very small plant) had five (5) critical control points (CCP) on Jan. 25, 2000 - when the last tier of HACCP implementation became mandatory.

Four (4) CCP's were identified as Biological hazards - and - one (1) CCP for Physical hazards - multiple species.

Note that the year AMPC actually put in place their HACCP system - Aug.1996 - after receiving a Silliker Laboratory accreditation letterhead based on a Silliker committee review of our first HACCP system.

When Jan. 25, 2000 rolled around - AMPC had accumulated nearly four (4) years of historical HACCP data to draw from.

Depicted below is the actual CCP decision-tree that AMPC HACCP committee utilized back in '95 to make decisions needed to determine the biological, chemical and physical hazards to each specific process step of AMPC's inaugural flow chart for RNGB and RGB (lamb only).

During the early stages of the MEGA REG HACCP implementation - which was tiered in over three (3) years - based on an establishments number of employees in Large plants on Jan. 26, 1998 / Small plants on Jan. 25 1999, / and Very Small plants on Jan. 25, 2000.

SSOP's went into effect first - for all USDA / FSIS inspected establishments on Jan. 27,1997.

Prudent move by USDA and a sheer indicator of how dirty many USDA establishments were at that time.

Most USDA / FSIS inspected establishments were "HACCP Greenhorns" and relied heavily - at the get-go, on consultants and trade associations to help kick start their USDA / FSIS HACCP systems.

So - how in the hell - are you wondering - could raw not ground beef (RNGB) and raw ground lamb (RGB) have five (5) CCPs?

During those Lewis and Clark days of early USDA HACCP was your assigned six (6-month) resident USDA Inspector-In-Charge (IIC) when selected USDA inspectors still had / displayed their shiny federal badges as pictured below and would periodically carry their version of the Beatles "Maxwell's Silver Hammer" song with their ball-point pens.

Selected GS-9 USDA inspectors at middle processing establishments were self - anointed "HA-SIP Experts," who were as Green as AMPC (and industry) was - and in selected incidences - even Green-er.

AMPC went the full 15 rounds with some Non Compliances cited towards our customized HACCP system as AMPC won three out of four early on - involving the USDA's Non compliance sublime appeal process - which ultimately enhanced both AMPC and plant level / district level / USDA FSIS inspectors awareness that the HACCP systems are the establishments - not the USDA's.

Discussions with others in industry during those early days was that the change of inspection for many FSIS inspectors was a major thinking / inspecting paradigm shift for them - as it was for industry.

The days of USDA of eyeing, scratch and sniff organoleptic inspection and hammering away their process deficiency records (PDRs) went down with the sun for good at midnight on Jan. 25, 2000.

ALPHA MEAT PACKING COMPANY'S CRITICAL CONTROL POINTS 1996 - 2000

1.CCP 1Biological (B) - { Enteric pathogens E. coi O157:H7 and salmonella } - Receiving surface temperature spec and organoleptic inspection of product received at 43 degrees F., or lower.

2. CCP (2B) - { Enteric pathogens E. coli O157:H7 and salmonella } - Ambient temperature of storage coolers 39 degrees F., or lower - 24/7/365.

3. CCP (3B) - { Enteric pathogens E. coli O157:H7 and salmonella } - Product temperature at pack-off - surface temperature of 43 degrees F., or lower.

4. CCP (4B) - { Enteric pathogens E. coi O157:H7 and salmonella } - Shipping surface temperature spec of product shipped at 43 degrees F., or lower.

5. CCP (1P) physical - { Metal detection involving 3.0 mm ferrous, non-ferrous and stainless steel }.

AMPC 'WOULD-HAVE-BEEN' HACCP SYSTEM IN POST-BELLUM 2023

1. CCP 1Biological (B) - { Enteric pathogens E. coli O157:H7 and salmonella} - Receiving surface temperature spec of product received at 43 degrees F., or lower.

TRANSFORMED FROM A CCP INTO A PREREQUISITE PROGRAM WITH THE SAME PARAMETERS

2. CCP (2B) - { Enteric pathogens E. coli O157:H7 and salmonella } - Ambient temperature of storage coolers 38 degrees F or lower,

TRANSFORMED FROM A CCP INTO A PREREQUISITE PROGRAM WITH THE SAME PARAMETERS

3. CCP (3B) - { Enteric pathogens E. coli O157:H7 and the SIX NON-0157 STECS and salmonella } - Product surface temperatures at pack-off - 43 degrees F., or lower.

TRANSFORMED INTO CCP 1B AND ADDED IN THE SIX (6) NON-0157 STECS in 2014 as per USDA / FSIS requirements.

4. CCP (4B) { Enteric pathogens E. coli O157:H7 and salmonella} - Shipping surface temperature spec of product received at 43 degrees F., or lower.

TRANSFORMED INTO A PREREQUISITE PROGRAM

5. CCP (1P) - Physical { Metal detection involving 3.0 mm ferrous, non-ferrous and stainless steel. }

TRANSFORMED FROM A CCP INTO A PREREQUISITE PROGRAM WITH THE SAME PARAMETERS.

Finally, ground lamb made into patties would have been tested for Enteric pathogens E. coli O157:H7 and the SIX NON-0157 STECS and salmonella by an ISO 17025 laboratory with results received before final shipment.

The HACCP system revisions listed above were clearly justified in 2000 based on approximately four (4) years of historical data which clearly evinced that the four (4) CCP's that were transformed into Prerequisite Programs and daisy-chained to HACCP - had zero non-compliance related NR's cited by USDA / FSIS.

And of course AMPC First (and only) Science-based CCP biological reference was the popular get-out-of-jail card - the Tompkins R. B. study evincing the significance of time-temperature growth of food-borne pathogens as depicted above.

From left to right, Chris Pecci, VP of Finances / HR, Regis Winter, Plant Manager and myself VP of Operations / HR.

The smocks red worded patches in the picture read 'H.A.C.C.P. Certified.'

AMPC had twenty-one (21) employees (when applicable, in Spanish) that were HACCP certified by the National Meat Association via the sublime services of the HACCP Consulting Group, LLC (HCG).

This intriguing HACCP three day course (22 hours) Nov. 9th - 11th 1995 was held in Los Angeles, California. The full to the brim HACCP class was aptly presented by the smart / clever / soft-spoken Dr. Joseph Blair of the HACCP Consulting Group, LLC.

A SSOP one day course (8 hours) Sept. 11,1996 was held in El Segundo, California.

This excellent and informative sold-out SSOP class was conducted by the knowledgeable, impressive, and always laughing - Mr. Robert Savage of the HACCP Consulting Group, LLC.

When SSOP's (?9 CFR 416?) became mandatory by USDA / FSIS on Jan. 27,1997, the transition for AMPC was easy because of strict personal hygiene practices, intense / on-going bi-lingual employee food and OSHA training that had been in place since the late '80s and 90s that included what would turn out to be - similar USDA themed SSOPs, SPSs and GMP's.

The owner of AMPC, Stan Fittinger, was truly committed to both food safety and OSHA safety and always provided the needed wherewithal to ensure that every employee felt valued and treated as a MVP.

And they were.

Not too unlike IN-N-Out Burgers operations in 2023.

The letter below was dated Feb.17,1998 and was from John Howard, Chief of CAL/OSHA acknowledging AMPC lowering our incidences of reportable injuries and illnesses by 88% starting from 1990 to 1997.

The California Voluntary Protection Program (Cal/VPP) is designed to recognize employers and their employees who have implemented safety and health programs that effectively prevent and control occupational hazards. These programs go beyond minimal Cal/OSHA standards and provide the best feasible protection at the site.

Like HACCP - AMPC's Top Managements total and consistent commitment - and active employee participation R the key elements in achieving CAL/VPP recognition. CAL/VPP establishments are considered to be leaders in the field of workplace safety and health.

Successful applicants approved for participation in CAL/VPP receive State and national recognition and are 'exempt' from CAL/OSHA programmed inspections.

And finally, AMPC had a bi-lingual trenchant aphorism on the walls and integrated with bi-lingual employee training since the 1980s that read in English / Spanish:

"You can't have a clean plant unless it's a safe plant - and you can't have a safe plant it's a clean plant."

"No se puede tener una planta limpia a menos que sea una planta segura, y no se puede tener una planta segura si es una planta limpia".

A sure double - double if their ever was one.

AMPC always stayed ahead of the many regulatory agencies that governed our operations.

That is how others and myself at AMPC approached the MEGA REG of 1996.

Blame it all on the owner of AMPC - Stan Fittinger.

Period.

XTRA XTRA XTRA !

Major News Stories in the MEGA REG year of 1996

Ebay and Ask Jeeves is started.

IBM's Deep Blue defeats Chess Champion Gary Kasparov.

'Hello Dolly' the sheep - became the first mammal to be successfully cloned.

Prince Charles / Diana, Princess of Wales got divorced.

Mad Cow Disease hits Britain (BSE) causing the mass slaughter of herds of cows.

In Technology - DVD's were launched in Japan.

The number of users on the Internet exceeded -10 million - for the first time.

All 27 years ago.

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The following past LinkedIn post were derived / learned from others during my 18 years at AMPC.

FUTURE LINKEDIN POST