PRE-REQUISITE PROGRAM FOR SPECIFIC RISK MATERIALS (SRM'S) FOR CATTLE 30 MONTHS OF AGE OR OLDER

Currently, Steve Sayer is a workplace safety *consultant #accredited auditor to *OSHA, *EPA, *#GFSI, *USDA, *FDA, *Human Resources, *#and Humane Handling of feed birds and animals and is a technical writer for multiple industries, as well as a part-time maintenance worker for California State Beaches.

(The views and opinions expressed in this blog are strictly those of the author.)

By Steve Sayer

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“Necessity is the mother of invention.”?

―?Plato

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KNOWLEDGE ARTICLE - If you have more questions about this topic, please submit them through askFSIS:?https://www.fsis.usda.gov/contact-us/askfsis

What is a prerequisite program?

Prerequisite programs are written procedures that describe particular activities of an establishment/plant that can be used to support decisions made in the hazard analysis.?Prerequisite programs do not control food safety hazards.?Good Manufacturing Practices (GMPs) or Sanitation Standard Operating Procedures (SOPs) are examples of prerequisite programs.

If you have any questions about the information in this Knowledge Article or any other questions about this topic, you can submit them to the FSIS Policy Experts at askFSIS by clicking on this link and filling out the web form to submit your question:?https://www.fsis.usda.gov/contact-us/askfsis

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As we make our way to actual evisceration stage of a beef harvesting establishment the ground rules concerning SRM's is listed below as a typical prerequisite program that is daisy chained to a vertically integrated beef harvesting establishment HACCP system.

SPECIAL NOTE: When the new SRM ruling went into effect due to a Holstein cow popping a positive for Mad Cow Disease in Dec. 2003 the entire small intestines were to be removed, denatured and sent to a render. To counter lost sales to the entire small intestine - some harvesting establishments began selling the large intestine - and continue to so today.

("Whenever I go to Ensenada BC, which was often prior to COVID, I always asked the Associates at the taco stands, in Spanish, "do you respectfully have beef gut tacos, Senior?" They are always shocked that a Gringo would order beef gut tacos, including too - beef tongue tacos. If you have never tried beef gut tacos or beef tongue - try them - you'll love them - with of course - a Dr. Pepper on the (bottled water only) rocks.)

The "2003 Cow That Ruined Christmas" also brought on plenty many Export Verification Programs to selected non-domestic markets world-wide. All that did was make for more easy money for other consultants and myself if the establishment did not want to bother or know how to scribble one up.

When I keyboarded the below SRM prerequisite program, the USDA did an Excellent Job with other agencies (APHIS, FDA, CDC) to assist smaller plants with their programs with detailed pictures and drawings.

Keep in mind that the risk of contracting BSE is very, very, very small in the USA.

(Tell that to the media, will ya'!).

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OVERVIEW

XYG shall abide in full to FSIS Directive 6100.4, dated 9/13/2007. All previous and germane FSIS Notices/Directives with regards to Specified Risk Materials (SRM) shall be followed as well. Further and more specific information regarding the removal/disposal of SRM’s in both harvesting and raw not ground beef operations are in XYZ’S Best Practices for Harvesting and Raw Not Ground Beef. NOTE: All livestock that is harvested at XYZ’s shall be considered to be thirty (30) months of age or older. (Amended 1/32/2022).

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 are offered for slaughter be condemned.?

All related records of the Final Rule shall be kept for no longer than one (1) year.

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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.

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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. XYZ does not produce MS beef.

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SRM USDA/FSIS 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;

Skull

Brain

Eyes

Trigeminal ganglia

Spinal cord

Vertebral column (excluding the vertebrae of the tail, the transverse processes of the thoracic and lumbar vertebrae and (do not forget ...) the wings of the sacrum)

Dorsal root ganglia (DRG)

Tonsils

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. XYZ processes only domestic livestock.

As per CFR 310.22(b) SRM’s IS considered to be inedible and are not fit for human food.?

As per CFR 310.22(c) that the proper disposal of SRM’s are 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.

As per CFR 310.22(d) are in accordance to 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 eye balls.

The beef head is placed onto a rack. The brain material is pressure vacuumed out using a Jarvis SRM Removal System where it is automatically segregated and discharged through a vacuum system to an outside receiving container that will store only brain and spinal cord tissue materials.?XYZ shall split three (3) heads per shift to assure compliance is achieved.?A plastic plug is inserted into the skull to eschew any brain leakage from the stun gun. The head is then washed with cold water prior to the USDA inspection rack (Effective March 6, 2009).

The head is transferred to the USDA inspection rack for inspection presentation to the USDA. Afterwards, 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) are disposed into the inedible screw and directly discharged into an awaiting rendering trailer outside the facility.

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Removal of the distal ileum.

The distal portion of the ileum, at the point of the attachment to the small intestines to cecum directed approximately 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.?

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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 wind pipe 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.

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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 our Vacuum Powered TrimVac and is automatically discharged and segregated through a vacuum system to an outside receiving container that will store only brain and spinal tissue materials. In case of TrimVac malfunction, XYZ shall use an orange handle knife and scrapper to assure compliance is achieved.?

Removal of the spinal cord – Raw not Ground Beef.

Prior to the de-boning process any residual spinal tissue is scrapped with a designated scrapper and is placed into a marked inedible barrel with the contents disposed into a rendering trailer.?

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Vertebral column & dorsal root ganglia (DRG) – Raw not Ground Beef.?

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:?

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Skull, eyes and trigeminal ganglia:

Designated orange handled knives are dipped (at least 4 to 6 seconds) into a SRM dedicated knife sterilizer (signage is in both Spanish and English) 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 hot water every five (5) heads.

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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 our Vacuum Powered TrimVac and is automatically discharged segregated through a vacuum system to an outside receiving container that will store only brain and spinal tissue materials. In case of TrimVac malfunction, XYZ shall use an orange handle knife and scrapper to assure compliance is achieved.

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Vertebral column & dorsal root ganglia:

The only affected areas where that 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 spinal cord.

Tonsils:

Orange handled knives are dipped into a knife sterilizer after each tongue is processed. Sterilizer is measured at 180°F or higher and 4 to 6 seconds is achieved and monitored and document with applicable signatures and dates.

Distal ileum:

Established SSOP requirements are required of this process based on the described processing of the small intestine.

9CFR 310.22 (g) follows FSIS Directive 6100.4, dated 9/13/07. The shipping and delivery of carcass parts or whole carcasses that may have attached materials (vertebral column) that are considered to be a SRM by the USDA are to be properly removed and disposed by the receiving Establishment and verified by XYZ company. (Amended 3/20/2009).

The blade of the carcass breaking saw shall be dipped into a measured chemical solution after each carcass is sawed to guard against possible contamination.

A Certificate of Analysis (COA) shall be documented for every order and filed for any needed future references.

Each carcass part or whole carcass that is transported to another establishment shall bear the mark of inspection of this Establishment #007 as per FSIS Notice 38-09 dated 5/7/09.

XYZ is responsible and maintains control of the carcass part(s) while in transit by applying a unique seal and padlock. The COA will be accompanied with each delivery that identifies that the carcasses are from livestock that are 30 months of age or older and states that the receiving customer and XYZ are responsible for the removal and properly disposal of?SRM’s (vertebral column) that remain attached. The attached COA shall document that all carcasses received (the number of the carcass shall be stated with each individual load) will have the vertebral column properly removed and disposed of within the parameters indicated in FSIS Directive 6100.4, dated 9/13/2007.

The COA contains the Date, Purchase Order, Seal Number, Slaughter Date, number of carcasses sent, and Invoice Number.?

The customer shall 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 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 at our establishment.MONITORING/CORRECTIVE ACTIONS OF SRM’S?

This Prerequisite 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) and addressed as per FSIS Directive 6100.4, dated 9/13/07. This monitoring shall be carried out three (3) times each harvest shift.

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 Pre-requisite Program shall be conducted at least once a year. Any amendments to this Pre-requisite Program shall be noted under the HACCP amendment record. All germane documentation shall be available to the USDA upon request.

Date ________________________ ???????????????Seal # ____________________________

PO # ________________________????????????????

Slaughter Date _________________ ??????????????Invoice # __________________________

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Date: Apr. 9 2009

Dear Valued Customer,

It has been recognized by our USDA IIC that all cattle that are slaughtered at our Establishment are considered to be cattle thirty (30) months of age or more.

In light of the above and as per FSIS Notice 56-07, dated 8/31/2007, regarding Specified Risk Materials (SRM’s), this letter is giving notice to you that certain parts of the anatomy may still have attached materials that are considered to be SRM’s. SRM’s are identified by the USDA as being:

Brain

Skull

Eyes

Tonsils

Trigeminal Ganglia

Spinal Cord

Vertebral Column (excluding the vertebrae of the tail, the transverse process of the thoracic & lumbar vertebrae and those - wings of the sacrum).

Dorsal Root Ganglia

Distal Ileum

As per FSIS Notice 68-05, dated 10/6/2005, specifically 9 CFR 310.22 (g), ABP is responsible and maintains control of carcass parts while in transit to your facility. However, after receiving product(s) from XYZ, the proper removal and disposal of any possible SRM’s become your Establishments responsibility. It is also the responsibility of your Establishment to have in place written and verifiable procedures that details the removal and proper inedible disposal of any SRM materials by means of your HACCP, SSOP and/or Pre-requisite Programs.

Please have an authorized employee sign and date below with each delivery that you have received this letter of declaration and return it to our driver. This letter is strictly confidential and will only be presented to the USDA upon request. Thank you.

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Plant Manager, XYZ??Date ??????????????? ????Receiving Customer Name?????????Date

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????????????????????? Customer Signature

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??????????????????????????????????????????Name of Company ??Establishment Number?

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ONE BEEF EXPORT EXAMPLE OF MANY

Beef exports to Japan must meet specified requirements under the USDA Export Verification (EV) Program.?These requirements apply to U.S. companies—slaughterers, fabricators, and/or processors—that supply beef and beef products as listed on the?USDA Food Safety and Inspection Service (FSIS) website.?

The specified requirements for exports to Japan include:

• Beef and beef products must be derived from: 1) Cattle that were born, raised, and slaughtered in the U.S. or from cattle that are legally imported from countries eligible to export to Japan listed on the FSIS Export Library criteria. 2) Imported meat destined for shipment to Japan must come from meat that is legally imported from countries that are eligible to export to Japan listed on the FSIS Export Library criteria.
• Beef and beef products mean all edible parts of cattle and products derived from such parts of cattle and are produced in a manner that ensures the hygienic removal of the specified risk materials (SRMs).?With respect to heads, only tongues, cheek meat (Masseter Muscle), and skins of heads are eligible for export to Japan; all other parts of the head must be excluded from exports to Japan.
• Specified risk materials (SRMs) mean: tonsils and distal ileum from cattle of all ages; and brain, eyes, spinal cord, skull including head meat (but excluding cheek meat-Masseter Muscle), dorsal root ganglia, and vertebral column (excluding vertebrae of the tail, transverse processes of the thoracic and lumbar vertebrae, and wings of the sacrum) from cattle 30 months of age and older at the time of slaughter.

Carcasses, beef, and beef products must be uniquely identified and controlled up until the time of shipment.Companies already on the approved listing for Japan will continue to be approved for the past LT30 protocol and can continue to ship the product produced prior to May 17th?under that protocol and FSIS Export Certificates.?Existing approved companies requesting to produce and ship product under the new protocol and QAD 1030J procedure will need to update and submit their changes to QAD for a desk audit and approval to the new protocol.Only eligible products may be issued an FSIS Export Certificate.?The Agricultural Marketing Service (AMS) verifies that cattle and meat products meet the specified product requirements, as outlined in QAD 1030J Procedure, through an approved?USDA Quality System Assessment Program (QSA)?or?USDA Process Verified Program (PVP).?These programs ensure that a company’s requirements are supported by a documented quality management system and are verified through audits conducted by AMS.