Zero tolerances
Despite what the USDA may say - your customized HACCP system is YOUR COMPANY’S, not THEIRS. All you need to do is follow and meet (and know) all germane Directives and Notices and be able to verify and validate your HACCP system.

Zero tolerances

“Bovines are unique in a way that they have four stomach compartments to digest their food. Those compartments are rumen, reticulum, omasum, and abomasum.

Of these, rumen is the largest compartment, and it can hold as much as 50 gallons of food and other ingested substances. The most important part about rumen is that it contains huge amount of different microbes, including bacteria, fungi, protozoa, and others.”

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-?From MicrobeWiki, the student-edited microbiology resource

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Not all beef slaughter establishments tie the weasand (esophagus) after the head is severed with a Specific Risk Material (SRM) designated knife at the juncture of the atlas and axis vertebrae - but the sensible majority do.

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Some slaughter establishments will use kite like string to stop the flow of rumen: while others incorporate plastic clips that works much like a clothes line, effectively precluding the flow of the rumen onto the carcass, surrounding carcasses, including the slaughter floor and line workers.

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After the weasand is tied, a long, skinny, and circular steel rod (one end is shaped for a hand grip: the other is curled like porky pigs tail) is used to separate the weasand from the trachea as well as pushing the weasand back up towards the lungs. It is vital that two (2) steel rods are incorporated at this HACCP step. One being sanitized with 180 degrees F., water - while the rod is in use.

This effectively places the weasand out of the way until evisceration is performed. There should be two weasand rods: with one always sitting in a hot water sterilizer of 180 degrees F. or more water - and as mentioned in previous blogs - with everyone on the harvesting line utilizing the two knife/steel system. A must.

The weasand is edible, but not all slaughter companies elect to save them. However companies that do save the weasand are required by FSIS to apply the USDA's oxymoronic zero tolerance standard for fecal, ingesta, and milk matter.

So officially, we run into our first of several mandatory governmental regulatory requirements: way, way up stream involving a mandatory critical control point (CCP).

And you middle processors thought everyone in industry could pick and choose their own unique CCP under the USDA's 1996 Mega Reg Ruling. Not in slaughter.

In the interim, the fore shanks (at the carpals and metacarpals joints) and hind shanks (at the tarsals and metatarsals joints) are cut off and are either denatured and sent to rendering or are saved and sold, after cleaning and de-hairing is accomplished.

FSIS Directive 6420.2, dated 3/31/2014?–?“Verification of procedures for controlling fecal material, ingesta, and milk in slaughter establishments,”?plays an integral food safety role involving beef carcasses, weasand, head and cheek meat.

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Beef carcass examination requirements are listed on page 13 of the Directive pictured directly above.

Under "Ripley's Believe it or not category" - selected harvesting facilities (including too - some USDA inspectors) are not aware of the number of carcasses that are subject to the zero tolerance standard.

Goodness gracious ... .

The amount to be checked (based on the above USDA/FSIS Directive) is based on the expected volume amount for the day at hand:

  • 100 or fewer – 2 carcasses or 4 halves if split:
  • 101 to 250 – 4 carcasses or 8 halves if split:
  • 251 to 500 – 7 carcasses or 14 halves if split:
  • More than 500 – 11 carcasses or 22 halves if split

That's it.

Why do any more?

The Directive states that carcasses that are subject for zero tolerance by the establishment are to be:?“randomly inspected.”

The best methodology to fulfill “random” is to state:?“ABC company shall check X amount of carcasses approximately every two- (2) hours, plus or minus 15 minutes.”

Too many times I’ve seen slaughter, food and beverage plants meet “random” by stating in their HACCP system:?“XYZ company shall check X amount of carcasses every two - (2) hours.”??

What eventually happens is XYZ company places themselves superfluously into a tight and non-flexible corner by not including:?“approximately?every 2 hours,?plus or minus 15 minutes.”??

I’ve answered a number of non-compliance records (NR’s) for slaughter establishments on both sides of the Mississippi who were cited a HACCP failure because they recorded their observations several minutes past?- “every 2 hours.”

Despite what the USDA may say - your customized HACCP system is YOUR COMPANY’S, not THEIRS.

All you need to do is follow and meet (and know) all germane Directives and Notices and be able to verify and validate your HACCP system.

Is that really asking too much?

To some it is.

Remarkably, the USDA’s zero tolerance Directive IS NOT specific to the actual quantity of weasand, head and cheek meat that is to be examined for zero tolerance: only that it is to be random. Next time, I’ll disclose an antiquated but effective formula that objectively meets this Directive and is as random as one can get.

In addition, we'll take a side road and follow the severed beef head (after it passes USDA post-mortem inspection) where we'll run into the before mentioned USDA mandatory CCP: head and cheek meat and the mandatory zero tolerance standard.

Finally, we’ll resume with SRM’s when we remove the tonsils from the beef tongue.

Everything (more times than naught) begins and everything eventually comes back full circle to slaughter.

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Trust me.

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NOTE: If just harvesting feed animals isn't enough in of itself, consider the hot humid months in say, Florida, where there is no air conditioning in an environment with blood, guts and severed heads - that these hard workers labor in - sometimes six (6) days a week, 11 hours a day. Employee turnover rates in harvesting runs on average 90 to 110% a year.

When people get tired in harvesting - and even the younger people do - then safety accidents are more likely to occur as well as critical dressing stages of hide removal that gets sloppy which results with cross-contamination after knocking is performed.

The same is applicable when employees are in a rush on a Saturday or the day before or after a holiday - as they rush and get sloppy so they can end their shift It's important that Line Supervisors are aware of these variable situations and rotate jobs and really observe and make adjustments when needed.

I myself have worked on slaughter lines, both the high and low benches, and it is a tough, loud, physical, dangerous and demanding environment. My hat goes off for these workers. Most work hard, and some send home 1/2 of their checks to their families south of the border.

So the next time you order a rib eye at your favorite restaurant, you should have a general idea of the sheer labor it took to be able to bite into that tasty medium rare piece of meat next to your favorite vegetables and of course - a baked potatoes with all the toppings.

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On Tuesday, I'll run a new "Human Resource - re-visted blog" on March 1, 2022.

5/8/2014 (revised 02/27/2022)

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Scheduled For Friday March 4th 2022

PRE-REQUISITE PROGRAM - CHEMICAL RESIDUE WHEN RECEIVING CATTLE

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Christine Testa REHS RS, CPFS

International food safety mentor partnering to create a culture of food safety .

2 年

Thank you for sharing

回复
Frank McLaughlin

Consultant at Rockyfjord Food Safety Consulting

2 年

I would like to add that lately both USDA and third party GFSI have played “gotcha” with the “randomness of random”. Noncompliance for one and all just selecting a random carcass or head. One must prove randomness by utilizing a table of random numbers, random number generator, etc.to select carcasses and parts for ZT.

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