HAZARDOUS ANALYSIS FOR SMALL/VERY SMALL USDA BEEF HARVESTING ESTABLISHMENTS - CONVENTIONAL/ RITUAL - PART 9 0F 10 PARTS

SSOP PROCEDURES FOR SPECIFIC RISK MATERIALS - CATTLE 30 MONTHS OF AGE OR OLDER

OVERVIEW

ABC company shall abide in full to FSIS Notice 56-07, dated 8/31/2007. All previous and germane FSIS Notices/Directives with regards to Specified Risk Materials (SRM) will 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 will be kept for no longer than one (1) year

NON-AMBULATORY DISABLED CATTLE

?? 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.

?? 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.

• ?? 9 CFR 309.13(b) does not apply to our operations – veal calves.
• ?? 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

?? 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.

?? As per 9 CFR 319.5(b) continues to prohibit mechanically separated beef (MS beef) for human food. ABC company does not produce MS beef.

SRM REGULATIONS

?? Cattle slaughtered and further processed at our establishment are in the category of thirty (30) months of age or more.

?? 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 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

?? 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. ABC company processes only domestic livestock.

?? As per CFR 310. 22(b) SRM’s are considered to be inedible and are not fit for human food. As per 9 CFR 417.5, a reassessment of HACCP & SSOP programs was made for the calendar year of 2006 on 1/3/2007. This reassessment of historical data showed no deviations to ABCs SRM SSOP programs.

?? 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 is removed at our establishment and properly disposed of into a rendering trailer.

?? 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.

?? 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).

?? 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 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, brain and trigeminal ganglia intact) is disposed into the inedible screw and directly discharged into an awaiting rendering trailer outside the facility.

?? Removal of the distal ileum. The distal portion of the ileum, at the point of attachment to the small intestines 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 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 is 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.

?? 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.

?? Removal of the spinal cord - Harvest. After the splitting of a carcass is accomplished, the spinal cord tissue is removed with an orange handled knife and a scrapper. The spinal tissue is placed into a vacuum located by this process step that automatically discharges the spinal tissue outside the facility.

?? 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.

?? Vertebral column & dorsal root ganglia (DRG) – Deboning. The vertebral column/dorsal root ganglia are processed in the deboning cooler. The vertebral is transferred by an upper conveyor line 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.

?? 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) years of age or older:

?? Skull, brain, eyes and trigeminal ganglia: Designated orange 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. The cutting table that the heads are placed and trimmed on are washed with water every five (5) head. In the event any brain matter or other spillage occurs, the table will be washed and sanitized.

?? 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 with designated orange handled knives and a spinal cord scraper. The 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.

?? 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.

?? Tonsils: Orange handled knives are dipped into a knife sterilizer after each tongue is processed. The sterilizer is measured at 180°F or higher.

?? Distal ileum: No sanitation requirements are required of this process based on the described processing of the small intestine.

?? 9CFR 310.22 (g) follows FSIS Notice 68-05 dated 10/6/2005. The shipping 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.

?? A Certificate of Analysis (COA) as depicted on the right is documented for every order and filed for any needed future references.

?? ABC company is 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 30 months of age or older and states that the customer is the responsible party to remove and properly dispose of any SRM’s that remain attached.

?? The COA contains the Date, Vendor Name, Purchase Order, Seal Number, Slaughter Date, and Invoice Number.

?? 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.

?? 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 SSOP 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 SSOP will 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 this SSOP will be available to the USDA upon request.