Foreign Material Controls in the Red Meat Industry
August 20, 2014?? By Steve Sayer?(Revised 4/17/2022)
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The USDA Food Safety and Inspection Service (FSIS) is responsible for ensuring that U.S. meat and poultry products offered to consumers are safe, wholesome, unadulterated, and properly labeled.
In fulfilling these responsibilities, the agency’s laboratories perform periodically microbiological analysis of meat products, including pre-scheduled checks for foreign materials in the likes of metals, wood, plastics, buckshot, and glass, etc.
Prevention of this type of contamination begins on the farm or ranch where the livestock are raised. Producers of livestock have implemented their own safeguards to assure foreign materials do not enter the meat supply.
For beef, both national (USDA) and state regulatory programs work diligently to ensure domestic and imported beef, and beef by-product are the safest and highest quality beef possible.
Only wholesome, unadulterated products are eligible to bear the mark of USDA when they enter into the general commerce. In the case of foreign material contamination, the latest statistics evinces that the incidence in USDA-inspected establishments remains small.
If USDA inspectors find products containing foreign materials because the establishment did not properly segregate and dispose of contaminated product, inspectors (of course) have the arm-twisting power to take regulatory control actions by issuing non-compliance records that require the establishment to develop a written corrective action and preventive measure(s), while contemporaneously ensuring no harmful product has entered into the general commerce.
In the event contaminated product does enter into commerce, establishments are advised to initiate a recall that would be announced by the USDA through the media and its website.
FSIS does not require, meat processing establishments to have detection technology available in the likes of metal detectors (ferrous, non-ferrous, and stainless steel) and/or X-ray machines (metals, wood, plastics, etc.), in order to eschew physical contamination.
Customers do.
Ditto with GFSI and NSLP - they are your 'customers' too.
And a growing portion of your customers - are driving harder and harder towards GFSI - or else be dropped. It is of course - already happening.
USDA - inspected establishments must have supportable justification from academia studies and/or in-house validation and well-documented risk analysis and studies regarding how the procedures they shall employ will detect possible foreign materials present.
If foreign material contamination occurs, inspection program personnel must verify that the establishment follows their detection, segregation, and final product disposition procedures to ensure the contamination is removed.
This is all accomplished by having mandatory Hazard Analysis and Critical Control Points (HACCP) designed to preclude any chemical, physical, or biological hazard(s) from cross contaminating the otherwise wholesome meats.
Below is an example, one of many, for the criteria for objectionable materials for raw boneless beef.
CRITERIA FOR OBJECTIONABLE MATERIALS FOR RAW BONELESS BEEF
4 defects > 0.5 inch in its greatest dimension = re-work the entire 2,000 pound bin of boneless beef
(The definition of 0.5 inch in its greatest dimension is 0.5 inches in length, width, and/or diameter. Which if you do cite, you shall have the obligation to proffer historical data / academia studies that justifies 0.5 inches.)
HACCP AND PREREQUISITE PROGRAMS
USDA inspectors verify that the HACCP requirements associated with a Prerequisite Program for foreign material are met on a continuing basis.
For example, inspectors verify the requirements associated with a Prerequisite Program for foreign material in a raw ground beef process by performing verification procedures on the detection devices themselves and by reviewing the establishment’s applicable HACCP recordkeeping.
A USDA-regulated HACCP system requires that an establishment must conduct a hazard analysis to determine the food safety hazards reasonably likely to occur in the production process and identify the preventive measures that the establishment can apply to control those hazards. Historical data and customer complaints shall also considered when creating a hazard analysis.
If the establishment’s detection equipment is calibrated (well - documented) and finds product with foreign material contamination within the levels of detection, the Prerequisite Program would be considered as operating as designed, and detection is successful.
The establishment should evaluate / document the rejected product and, based on the findings of the product(s) evaluation(s), determine the root cause of the contamination. Then the establishment should evaluate the incident to determine whether additional controls are needed to preclude the presence of foreign material in the future.
And justify it.
There's some keen / trick 2022 software out there for logging of such findings. Using Control Charts and Histograms for all foreign materials is a must in 2022.
The study of foreign materials found in food is called Microanalytical Entomology. A must buy as pictured below. The U.S. FDA and the Association of Official Analytical Chemists (AOAC) have published reference articles, books, and methods on this subject that discuss methods of analyses, contaminant identification, and contaminant significance.
LIVESTOCK
In addition to the large dollar amounts that processors and manufacturers spend annually to ensure foreign objects are detected and removed from domestic meat products, livestock producers are also implementing their own safeguards to keep foreign objects, like buckshot, from entering the food supply. Livestock producers are educating their employees and neighbors not to fire shotguns for herd control, and not to allow hunting of other wildlife in the vicinity of cattle herds.
Buckshot can inadvertently hit cattle from such practices, and the financial losses are magnified when the plant must detect and remove this foreign material later in the manufacturing process. As a result, livestock producers are increasing their efforts to reduce this potential source of contamination.
VOLUNTARY SAFEGUARDS
There presently exists a voluntary governmental program for beef establishments that produce fresh boneless beef and frozen ground beef for the nation’s schools and a variety of institutions that requires objectionable materials to be removed. This program is named the National School Lunch Program (NSLP).
The program requires a written technical proposal approved by governmental auditors from the Agricultural Market Service (AMS) that involves written procedures from the transportation of livestock (humane handling of livestock) thru the entire continuum of beef slaughter, fabrication, and ground beef to cold storage and a secured final shipment.
The NSLP involves and promotes both food safety (HACCP program and FSIS inspection) and food quality requirements (i.e., fat percentage, net weights, and objectionable materials removal) that must meet AMS set parameters addressed within each USDA establishment’s technical proposal requirements.
The AMS’ technical proposal ISO 9000 series requires the plan, do, check, and act format on every process step (from transportation of livestock to final delivery of finished beef products) to generate excellent conditioned beef and frozen ground beef.
One key element of the program is the detection and elimination of objectionable materials (natural tissues of meats) as well as foreign physical materials (metals, plastics, stones, and glass) as discussed.
A typical description involving objectionable materials in a plan, do, check, and act format of a NSLP technical proposal is partially cited below.
Description of Process—Objectionable materials
Major lymph glands (pre-femoral, popliteal, and pre-scapular) thymus gland, and the sciatic nerve (lies medial to the outside round). All bone, cartilage, and the following heavy connective tissues; white fibrous—shoulder tendon, elbow tendon, silver skin (from the outside round), sacrociatic ligament, opaque periosteum, serous membrane (peritoneum), tendinous ends of shanks, gracilis membrane, patelleras ligament (associated with the stifle joint), Achilles tendon, and the yellow elastin, back strap, and abdominal tunic.
Trained quality assurance personnel ensure that the following objectionable materials are removed using a knife: the major lymph glands (pre-femoral, popliteal, and pre-scapular), thymus gland, bone cartilage, sciatic nerve, shoulder tendon, elbow tendon, sacrociatic ligament, opaque periosteum, tendinous ends of the shanks, patellar ligament?(stifle joint), and internal fat (kidney, pelvic, and heart fat). {Thanks - Steve Olson and company}
Plan:?
How will QA meet the production step?
All boneless beef products that are intended for the NSLP program shall be subject to visual inspection to ensure that the above objectionable materials are removed and placed into an inedible container. An approximate 30-pound sample of boneless beef shall randomly be taken from a combo bin (containing raw boneless beef) and re-inspected for any objectionable materials; approximately every two (2) hours, plus or minus 15 minutes.
Do:?
The actual production step.
Beef carcasses are de-boned by skilled and trained (documented - signatures - dates) butchers. Achilles tendons and external fibrous tissues are removed by the butchers prior to de-boning the hind shank. The rump portion of each carcass is opened by knife cuts to separate muscle groups, exposing other tissues, such as silver skin, gracilis membranes, sacrociatic ligaments, popliteal lymph nodes, abdominal tunic, and pre-formal lymph nodes, which shall be removed. Back straps are removed by butterflying open the neck and back portion of the beef chuck, once the bone is removed. The neck portion and the strap are trimmed off.
USDA-inspected establishments must have in place supportable justification from academia studies and/or in-house validation studies regarding how the procedures they employ will detect any possible foreign materials present.
The back portion are pulled out to expose the attaching membrane, which is cut by a knife and cleanly pulled away from the muscle tissue.
Boneless shoulder clods are then turned upside down exposing the interior side of the muscle and the pre-scapular lymph nodes. At the two areas where the shoulder and elbow tendons protrude, the clod is checked on the butt end where the shoulder tendon protrudes approximately 1 to 2 inches, depending on the size of the shoulder clod, and at the point portion where the elbow tendon protrudes is also checked for defects.
Afterwards, the boneless beef travels down a conveyer belt and ends up accumulating directly into a combo bins. At this juncture, personnel visually examine the boneless beef trimmings. The boneless beef that is destined for the NSLP program is placed into cardboard bins lined with a food grade plastic liner, fully?and properly labeled at the end of pack-off (and clean #1 pallets!). At this point of the process, on-going trained QA personnel shall perform the on-line inspection for objectionable materials.
Check:?
How do you verify using quality assurance check?
As the combo bins of boneless beef that are destined for the NSLP are in the filling process, an on-line Partial Quality Control program is performed and documented by trained QA personnel. At approximately every two (2) hours plus (beginning from the start of each production shift if school lunch product is being processed), plus or minus 15 minutes, an approximate 30-pound grab sample of product is removed from a combo bin and placed inside an edible labeled tote and inspected by a trained QA.
An off-line organoleptic (visual / organoleptic) re-inspection is performed afterwards under enhanced lighting of at least 30-foot candle power. The boneless beef is then scored using a criterion for on-line inspection for boning defects. If the criterion is exceeded, all product produced from the last acceptable check shall be tagged, re-worked, re-inspected, and documented.
领英推荐
IN SUMMARY
The NSLP is a demanding and unforgiving program that’s stricter than any other commercial or governmental food safety program today.
By reading through the NSLP's ISO 9000 based plan, do, check, and act format, it’s imperative that constant employee training is required in order for the program to meet all of the AMS requirements and guidelines. Failure to follow selected AMS guidelines can lead to a QUICK disqualification status. Plants can get reinstated by forwarding a cause and effect corrective action that is approved by selected officials at the AMS.
The Global Food Safety Initiative (GFSI) involving Safe Quality Food (SQF), British Retail Consortium (BRC), and the FSSC 22,000 does not contain any such detailed requirements. However, if USDA establishments have the ability to adopt both the NSLP and GFSI programs into their operations, such pro-active programs will power their operations several levels higher than that of their competitors.
ONE CAN HAVE THE VERY BEST QA / QC / HACCP / OCCUPATIONAL SAFETY WRITTEN PROGRAMS WITH ALL THE BELLS AND WHISTLES - BUT IF ONE DOES NOT HAVE DISCIPLINED AND WELL-TRAINED EMPLOYEES - ONE HAS NOTHING ...............
PERIOD.
I’ve always advised qualifying companies who are vertically integrated (slaughter, fabrication, and grinding) that want to have both the NSLP and GFSI programs integrated within their company operations to successfully implement and accomplish the myriad standards involving the NSLP first - - - before attempting GFSI certification.
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I once consulted a vertically integrated beef slaughter operation attain first the NSLP (including a Robust humane handling program as per NSLP requirements) and thereafter BRC.
It worked well and made the transition to BRC requirements and methodology sooooooo much easier. In all honesty, it was agreed in the early planning stages to include a number of pre-BRC requirements work for both the NSLP and BRC to save time and monies. We also included industrial safety into the entire scope.
The tell-tale trails of historical documentation, management commitment, and constant employee training that’s required to meet the many standards of the NSLP naturally prepares and blends in oooh soooo smoothly to a company’s operations towards the demanding, but alway$ rewarding, international standards of GFSI.
XTRA XTRA XTRA TAKE
# Besides this is how the entire food / beverage industry should be today - under the benchmarks of GFSI and (when applicable) NSLP.
It would save lives / monies - including unscheduled trips to the bathroom while swigging away on a Pepto-Bismol bottle at 2:00 AM.
Strawberries from Mexico, USA baby formula, and peanut butter.
Incredible.
Could having a FDA inspector daily, like the USDA, avoided the baby formula and peanut butter incidents?
Yes or no?
Maybe.
But the system failed.
Why?
People, complacency and failure of FDA - and most of all - failure by top plant management on down.
Why?
Let your own fingers do the www. Both FDA and USDA recalls were down, down, down during Covid -19.
Why?
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On the other side of the coin, a good percentage of the USDA inspected small and very small plants would not survive GFSI - including selected large plants.
# Ask any parent the above statement - if - they could have their Tommy or Susie back due to a deadly virulent pathogen they consumed from meat.
I would side with the parents.
Yes, I'm fully aware too - that there would still be deaths and sickness related to meat if everyone was GFSI certified. I'm also aware that the BIG 4 in the USA who are GFSI certified have contributed to selected recalls, deaths and sickness in their well documented past themselves.
And let me remind you for the 20th time - not one single child has died from consuming ground beef supplied by the NSLP.
Not one.
Since 2002 through 2022.
Yes, wow.
Good job USDA and AMS.
But in reality - the industry is already inching towards GFSI and NSLP - since the late 1990s when GFSI was born.
Variables of todays slow world economy including (and helped on) the residual effects of Covid-19 - and - the Russian Putin / government killing innocents like 20th century Hitler - and - omnipresent employee shortages here in the USA, among other viable reasons.
The most valuable entity in the scheme of food safety and quality are still - the people.
POULTRY NEEDS
START WAY UPSTREAM AND CLEAN UP / SANITIZE THOSE SELECTED HATCHERIES AND TRANSPORTATION VEHICLES. GOODNESS GRACIOUS.
DECLARE THE "TOP 3 SALMONELLA PATHOGEN STRAINS" AS ADULTERANTS.
ENFORCE EXISTING GFSI / USDA / FDA SAFETY RULES UNDER A SINGLE FOOD / BEVERAGE GOVERNING USA AGENCY.
Call me a food safety radical if you like - but kids / older folks are much more valuable to me than the almighty dollar - nooooo contest.
Change is in the air - but it's still gonna be a long time.
Hope I'm wrong.
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Shawn Stevens and the others at Meatingplace.com have useful information that you can digest in only 5 to 10 minutes - Monday through Friday - and - you'll be up to date on what's happening around the world in the meat industry.
Mr. Stevens is an attorney, he knows the regs in and out and has the keen abilities to sketch up control charts, CCP's and hazardous analysis' himself.
Yes.
He's one of those.
Be glad he's not your next un-scheduled food safety auditor.
He digs deep - Mariana trench deep.
LEGALLY SPEAKING BY?SHAWN?STEVENS
Shawn Stevens is the founding member of Food Industry Counsel LLC, the only law firm in the U.S. that represents the food industry exclusively.
Stevens works with to help them protect their brand by complying with FDA and USDA regulations, reducing risk, managing recalls, and defending high-profile foodborne illness claims.
What will be the biggest drivers of recalls in 2022?
(The views and opinions expressed in this blog are strictly those of the author.)
As COVID entered and then changed our world, the numbers of total food product recalls decreased substantially. From historical highs of about 700 recalls in 2018 and 2019, the numbers dropped to lows hovering closer to 400 in 2020 and 2021. As we settle firmly into 2022, we predict the numbers of recalls this year will increase substantially.
So, what will be the main drivers of recalls in 2022? Based upon current trends in the industry, as well as an assessment of historical trends, we can make some predictions about where the highest risk areas lie. It’s no secret that the top three causes of recalls overall are pathogens, undeclared allergens and foreign materials. All three will likely continue to be major influencers. And, we predict that they will continue to drive the total numbers of future recalls even higher.
In the category of pathogens, companies will continue to struggle with recalls because of the presence of harmful pathogens. Moving forward, FSIS will continue to be less tolerant of?Salmonella?in ground meat and poultry products. On the FDA side, more frequent inspections, increased numbers of swab-a-thons, ever-expanding definitions of “ready-to-eat,” and zero tolerance for?Listeria?will continue to lead to high numbers of recalls. Additionally, the persistence of?Listeria?in food processing environments will continue to intermittently contaminate large amounts of products over large periods of time. Of all the recalls of pathogens over the last year, more than half involve products produced over extended periods of time.
Each year, undeclared allergens continue to compete with pathogens as a leading cause of food product recalls. Unfortunately, industry continues to struggle with the control of allergens for a wide variety of reasons. As a result, FDA and FSIS will likely continue to look for ways (i.e., during inspections) to look for weaknesses and incentivize companies to invest more resources in the control of allergens. Unfortunately, even when a company is doing everything right, a single mistake from a single ingredient supplier can lead to a massive food product recall.?
Foreign materials will also continue to be a leading cause of recalls. Increasingly, in response to increasing consumer demand, companies continue to push the limits of employees and infrastructure to produce larger volumes. In many cases, food production infrastructure and equipment is not being properly maintained or is being “run to failure.”?
Separately, technologies such as magnets and metal detection can only identify so many types and sizes of foreign materials. As a result, more and more companies are moving toward X-ray and other scanning technologies. The move by more companies further down the supply stream to newer and more capable technologies will result in more recalls of more products containing foreign materials that evaded detection earlier in the supply stream. The net result is that, eventually, the entire industry will be forced to move to these new technologies.
Thus, the risk of recalls is increasing. As we move deeper into 2022, your next recall may be waiting just around the next corner. Continue to be self-critical and self-audit, looking for practices or patterns that could ultimately lead to an unexpected recall.
2/14/2022
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Sayer, a 41 year-veteran of the beef / poultry / pork industries, is a consultant / auditor at S&R Consulting / Auditing LLC, in San Clemente, Calif. Reach him [email protected]