Assuring Food Safety of Red Meat for Domestic and International Consumers Kevin Smith Director, Export Services U.S. Meat Export Federation
What does this mean? Can be very different depending on the product Raw items Chilled Frozen Cured/processed Fully cooked Canned/Shelf Stable Covered by different regulatory agencies FDA FSIS Can involve APHIS Can involve EPA
U.S. Food Safety Management Systems Scientific Community USDA ARS Universities Private NCBA NPB Procedures for sampling, analysis and risk assessment Industry Production Processing Distribution Retail Food Service Regulators USDA APHIS USDA FSIS FDA EPA Consumer CDC Sentinal Site Epidemiological Data Base on Food Borne Illness
Source: FSIS 2011: October to December 2010 Quarterly report
Beef Food Safety & & Quality Assurance 010904 Prohibited UNITED Feed SOP STATES v2.doc Prohibited DEPARTMENT Feed Program OF AGRICULTURE SOP \ Effective: Replaces SYSTEMS AND AND FOOD PROGRAMS SAFETY AND INSPECTION SERVICE WASHINGTON, DC Index: Beef Number: 2.2.15 2.2.12 2.2.16 Page Page 1 of 12 of 2 PURPOSE: Suppliers of slaughter Index: cattle Beef must Slaughter certify non-use of prohibited Number: mammalian 2.2.13 protein Page in their 1 of 3 cattle finishing rations (i.e., 2.2 2.2 2.2 Carcass Issued: Replaces: ruminant meat & bone 2.2 Carcass meal). In 1997, FDA banned the use of Issued: such ingredients in feed Replaces: for ruminant animals. The FDA Spinal Live Beef Cattle Cord Dentition Removal Receiving / / BSE Precautionary 28-04 5-04 9-04 Program ban was implemented 1/12/04 1/23/04 5/20/04 FSIS Non-Ambulatory NOTICE BSE Precautionary Program PRE-REQUISITE SRM to Age Segregation Control prevent the Program introduction of BSE (Bovine X BSE Spongiform Precautionary Encephalopathy) Program into the U.S. cattle herd. This initiative is intended to support U.S. efforts to keep the nation's cattle herd BSE-free. SSOP PRE-REQUISITE HACCP SSOP INTERIM VERIFICATION PROCEDURE HACCP GUIDANCE INSTRUCTIONS FOR NON-AMBULATORY FOR THE ADMINISTRATIVE PROCEDURE MORTEM INSPECTION FOR THE BOVINE SPONGIFORM DISABLED INTERIM GUIDANCE ADMINISTRATIVE ENCEPHALOPHATHY FINAL CATTLE RULE AND (BSE) REGARDING SURVEILLANCE AGE DETERMINATION PROGRAM SPECIFIED GUIDANCE RISK MATERIALS (SRMs) IN CATTLE PROCEDU All direct suppliers FSIS SAMPLE of cattle COLLECTION are required to FROM certify CATTLE their compliance CONDEMNED to the FDA DURING ruminant ANTE- feeding ban for prohibited RE: mammalian protein (ruminant meat & bone meal). This requirement applies to the owner/agent of cattle that are slaughtered at any beef slaughter facility (USA & Canada). 1.0 PURPOSE NOTE: FSIS PERSONNEL ARE NOT TO IMPLEMENT THE SAMPLE FDA Cattle feeders 1.0 1.0 To are PURPOSE COLLECTION define required spinal to cord keep PROCEDURES removal invoices procedures and IN labeling THIS and for NOTICE verification all feed UNTIL activities. they receive JUNE 1, that 2004 contains animal protein products, REQUIRM 2.0 To This BACKGROUND detail program the handling has been of non-ambulatory, established define injured, procedures BSE Sampled to verify [Headless], the age of or cattle whether or I. not the To PURPOSE address animal protein the regulatory is prohibited requirements (required for by SRM CFR [Specified 589.2000). Risk Material] removal, ENTS Requires rejected from a spinal visual animals assessment cord delivered to be completely to of a bovine facility. removed teeth A number [dentition]. from of the actions beef are carcass. available Spinal for cord each is www.access.gpo.gov/nara/cfr/waisidx_00/21cfr589_00.htm control, and disposal. I. PURPOSE identified situation 2.0 APPLICATION listed. an SRM The [Specified action used Risk will Material] depend for on BSE individual carcasses circumstances 30 months and of if the age I. This 2.0 PURPOSE FSIS APPLICATION and animal This older. policy is notice obviously is applicable provides suffering. Veterinary for all cattle Medical slaughtered Officers and (VMOs) to be applied guidance by the for Plant AFFIDAVITS - FREQUENCY: implementing new regulatory requirements regarding non-ambulatory disabled cattle and This 3.0 This 2.0 notice Manager REFERENCE policy is applicable to all Facilities and to be applied by the Quality Assurance SPECIAL provides or designee. INSTRUCTIONS < Veterinary Medical Officers (VMOs) with the methodology to use This procedures notice for contains determining updated by information dentition whether from FSIS cattle Notice are 30 18-03, months dated of age 5/27/03. and older. That when 3.1 2.1 Manager Prohibited verifying 3.0 9 If CFR REFERENCES a non-ambulatory 310.22 or designee. Feed Affidavits are required initially for all current suppliers (by that an (a)(1) establishment animal is has either properly on or designed off the truck procedures it must to be meet stunned the notice 3.2 immediately, 3.0 3.1 04/01/01). expires USDA REFERENCES 9CFR 310.22(a)(1) Directive on 6/1/04. bled and 7160.3 In light sent to of off-site recent events, rendering, FSIS incinerator, will be collecting landfill, brain or alkaline samples requirements of 9 310.22 for the removal, segregation, and disposition of specified II. from 4.0 digestion. 3.1 cattle 3.2 DEFINITION BACKGROUND New 9CFR 310.22 Specified at federally-inspected suppliers Risk Material (after Control 04/01/01) establishments Program are [2.2.13] required for the purpose to complete of BSE affidavits testing. before cattle are risk materials (SRMs). Also, this notice provides inspection program personnel with Therefore, 4.1 2.2 3.2 3.3 slaughtered. Spinal NEVER Beef BSE FSIS cord Precautionary Dentition is DRAG issuing removal Program A new SENSIBLE applies Program sample 2.2.12 to the collection, ANIMAL actual "cord-like" documentation, material and present shipping in the instructions procedures vertebrae FSIS 3.0 3.3 4.0 for verifying that an establishment is executing its programs so that there is Affidavits NON-AMBULATORY USDA issued BACKGROUND to column inspection three Specific must groove regulations program be Risk renewed after Material ANIMALS and personnel, the a carcass annually notice (including DELIVERED particularly in is the for split. skull, Federal all This cattle DURING Public brain, is Register not suppliers. Health trigeminal to PRODUCTION be on Veterinarians confused January ganglia, 12, with HOURS eyes, proper (PHVs). 2004, sheath. 3.1 vertebral in 4.1 removal, response Specifically Dead On Sheath January column, segregation, to Arrival is the trained the 12, diagnosis spinal thin 2004, and FSIS outer cord USDA-FSIS disposal by PHVs covering and will dorsal of SRMs. of that collect issued a root positive spinal the new ganglia brain cord case regulatory is samples. of of contained cattle Bovine policy The 30 Spongiform with-in. months defining samples of SRM s will age and MONITORING: be Encephalopathy shipped 5.0 3.1.1 older Verification of PROCEDURE Beef The and to the Cattle animal the of (BSE) USDA small must this in Animal an intestine program be adult assessed and Holstein distal will Plant to ileum monitored Health cow assure in and Inspection the it tonsil is as State dead. follows: of of Service all If Washington. there ages). (APHIS) is any These question National or NOTE: At some establishments that do not slaughter but that process bone-in parts of Veterinary 5.1 regulations doubt, 4.0 1. 5.0 Slaughter Affidavit BACKGROUND PROCEDURE Services and it must the be notice Audit: Laboratory stunned will Will prevent to (NVSL) conduct assure human in it random Ames, is dead, exposure Iowa, audits before to materials of another disposing direct APHIS-designated that cattle it to scientific an suppliers off-site studies for signed and current cattle 5.1.1 carcasses, Enforcement Investigation Analysis Officer may be called upon to laboratory. rendering 4.1 have demonstrated "Prohibited Spinal On A trained January facility. cords Feed monitor 12, will Dead-on-Arrival as containing Affidavit". be 2004, [Quality removed USDA-FSIS Assurance the BSE This in animals slaughter, agent will issued or in apply are Designee] not before new cattle to permitted infected cattle the regulatory will carcass slaughtered be into placed a policy wash. Rendering prior with the disease. at defining facilities to Facility USDA SRM s This within 6 months of when perform 5.1.2 under of verification of the design of the procedures in the absence of an available FSIS notice the head Beef Either audit any inspection Cattle. circumstances. manual provides is initiated. to systems visually VMOs guidance This or assess audit suction in will all equipment carcasses implementing be conducted are for age. acceptable the policy minimally methods contained twice in docket per for year. VMO. removal. 3.2 5.0 5.2 Non-Ambulatory PROCEDURE Age will be determined [SLAUGHTER] and Still by on dentition the Truck assessment. #03-025IF II. 5.1.3 3.2.1 BACKGROUND The ("Prohibition animal will of the stunned Use of Specified and bled then Risk dispatched Materials for to Human off-site Food rendering and 2. 5.3 Feedlot Spinal A Cattle trained cord 30 Audit: team Months material Individual member, of is age to be and who cattle disposed older knowledgeable suppliers will to be inedible identified will rendering be and by randomly able the following to recognize selected parameters. for the an second on-site feeding record Requirements for the Disposition of Non-Ambulatory Disable Cattle"), that nonambulatory BSE backbone 3.2.2 is a reportable USDA disabled disease cattle be notified are in the unfit United of for any human rejected States. food. In Non-Ambulatory cooperation In addition, with this animal. FSIS, notice APHIS The animal leads II. REGULATORY 5.1.4 facility. set audit. 5.3.1 of Removal permanent Three These permanent processes reviews REQUIREMENTS incisor will must incisors teeth, consist address examines are of present. the an spinal audit the teeth of cord feedlot prior removal to rations head from inspection the for entire presence/absence to of animal proteins, determine and 5.3.2 associated One from age. tooth the review of neck the area second of purchase back pair through of invoices incisors the loin. is and erupting. labels of feeds containing IS any animal protein products. provides an ongoing, 5.1.5 TO BE VMOs comprehensive, retained guidance until on USDA interagency distinguishing gives direction surveillance cattle as 30 to months program whether of for age the BSE. and animal Using older will from the be A. What 5.1.1 This 5.3.3 Mis-splits are If will Two the apply pairs age [closed regulatory of of the permanent cattle spinal animal requirements slaughtered column] is incisors. determined are related to facilities be to corrected be SRMs? 30 within months 6 the months of use age of of and a vertebral when older, the the audit is initiated. This younger Federal saw. subjected carcass 5.4 Meat cattle. Cattle Inspection Although to identified testing Act, cattle for to BSE. be 21 of 30 U.S.C. any Reference months age 603, must of part 9CFR age have of and the 311.27 older FSIS tonsils will ante-mortem and be marked entire small examination with intestine edible ink. audit will be be conducted identified as minimally such post twice hide per pulling year. via identification with a circle-3 disposed and 5.1.6 inspection 3.2.3 5.5 Mis-splits of If Non-Ambulatory as an inedible, procedure animal that is cattle can questionable will not 30 include arrival be months corrected the animals of collection undeterminable age are are and identified not older of permitted a brain have on is sample the additional to into slaughter be a identified from Tyson specified cattle. side Fresh as must For Mature risk Meats the be 9 on CFR both 310.22(a) hindquarters defines and SRMs both as: forequarters and a mark on the neck [dorsal from BQA EXEMPTION materials first identified time, Rendering and (SRMs) FSIS subjected with PHVs Facility blue that to will also ink subsequent under on collect may the any contain backbone brain circumstances. skeletal samples the BSE for maturity subsequent from agent verification cattle in cattle that diversion infected are as condemned identified to with inedible the during the wither Feeders to atlas] participating with edible in sanctioned blue marking Beef ink. Quality The head Assurance will be identified (BQA) programs, disease. with a blue and that < These ante-mortem rendering 3.2.4 corrective SRMs Any inspection must Non-Ambulatory action cattle be disposed that section federally-inspected are of 30 animals as this months inedible. document rejected of age Consequently, establishments. [Section and are to older. be 9.1.2.2]. sent VMOs The to APHIS a must landfill, verify Area incineration, that (1) mark have the brain, skull, eyes, trigeminal ganglia, spinal cord, vertebral column carcasses Veterinary or 6.0 on a defined the nose CCP of the for head prohibited post hide mammalian pulling. The proteins, carcass can will then be exempted be further from the 5.2 Processing alkaline and VERIFICATION Inspector-in-Charge parts digestion. of cattle 30 months (AVIC) of will age focus and older upon are sample properly collection identified activities and by (excluding the vertebrae of the tail, the transverse processes of the thoracic lumbar handled. APHIS 5.2.1 identified 4.0 6.1 Feedlot at NON-AMBULATORY Neck Prior locations bones prior to Audit. the other start or the vertebrae, BQA than of completion operations status federally-inspected IN THE which must of YARDS Quality contain the be slaughter current Assurance establishments spinal and cords, process will an are generate audit with (e.g., not of rendering to the the a be use random prohibited processed of a ribbon protein vertebrae, through and the wings of the sacrum), and dorsal root ganglia (DRG) of cattle 30 operations 4.1 tied timetable CCP Injured onto any conducted the AMR to and on-farm). Not determine front systems. USDA within shank FSIS Ante-Mortem the the [under audit past time the 12 tendon PHVs will take Inspected frames. months. and samples and tied from Passed. on bottom]. all cattle showing signs of months 5.2.2 4.1.1 5.1.2 6.2 of Plant Sample age The The and programs animal head Group: older, dropper will and must 10 be heads stunned be / de-jointer 1x/hour place and to bled will of ensure production. be then required that dispatched spinal to sanitize cords to an are off-site equipment completely rendering after each central Among nervous other system requirements, (CNS) disorders, the new regulations as well as the at 9 types CFR of 309.2(b) cattle that state may that be nonambulatory higher at removed facility. animal. 6.3 During Non-Ambulatory before production, bones are 10 on processed heads arrival will animals through be visually are the not 1st NON- COMPLIANCE assessed permitted step "pre-sizer". to into determine a Rendering carcass Facility age. 5.2.3 risk for disabled being livestock, infected with including the agent cattle, believed are livestock cause that BSE, cannot based, rise in from part, a on recumbent European (2) under 5.1.3 If a current, 6.4 the Mis-splits Cattle The any data. tonsils circumstances. head signed with position These and or the bones hooks affidavit or cattle, the first distal in will pair which that cannot while ileum be of permanent required from the walk, at federally-inspected (for spinal which to owner/agent incisors cord removal sanitized is has present not including, but not establishments, of the been in not 180ºF on-record distal over completely ileum water 24 months limited to, those are with under must between with, cattle removed broken the be and each will not < achieved must 4.2 head. under USDA be slaughtered appendages, control of by sorted FSIS disposing 30 CNS months out Suspect until severed and will of of tendons have the age. the entire AMR [SAMPLED The Prohibited process or the ligaments, brain small following sample intestine) FOR before Feed will BSE denote the affidavit nerve collected of or all "pre-sizing" HEADLESS] paralysis, either cattle. over completed. or 30 featherbone months of age: saw step. 4.2.1 5.1.4 6.4.1 Such Refer Heads Three bones to permanent with Headless may seepage be Cattle whizzard incisors of Procedure brain are trimmed. tissue present. [Reference [knock-hole fractured Beef from by Program the captive vertebral trained 2.2.14 bolt FSIS column or Section PHV de-horn metabolic or an 5.2.4 available conditions. APHIS The technician new regulation with direct at 9 supervision CFR 309.3(e) and states oversight that non-ambulatory by the FSIS PHV. 9 3.1.5] fracture] 6.4.2 Vertebrae One or tooth eyes bones of will the with not second be spinal processed pair cord of remaining incisors through CANNOT erupting. the head be wash diverted or allowed into edible the CFR 310.22(b) and (c) state that SRMs are inedible and shall not be used for disabled product, 4.2.2 head 6.4.3 cattle Plant table. Two Edible shall will pairs Heads Rendering, be stun/bleed/denature of condemned. permanent of this or nature BPI Consequently, incisors. product will animal be unless inspected on-premise these the cattle, spinal off-line [but which cords do by not USDA may are bring removed. be and on into the disposed plant of human premise Under FSIS food housing Notice and shall the 18-03 be disposed slaughter FSIS establishment, contacted of in accordance APHIS cannot whenever with 9 CFR enter the specific 314.1 slaughter cattle and 314.3. proper], into inedible rendering, landfill, or incineration. establishment. were presented X X X
New Technologies and Research 2010 Beef Industry Food Safety Summit: Tracing pathogen contamination through post-harvest environment Effect of wet or dried distiller s grains on fecal prevalence of E. coli O157-H7 Quantitative herd-level evaluation of Salmonella shedding on dairies Evaluation of different temperatures and exposure times of hot water to reduce pathogen levels E. coli O157-H7 and S. Typhimurium survival and transfer during marinated beef production Industry practices being used to address E. coli O157-H7 Dietary orange peel and pulp can reduce Salmonella in Sheep Evaluation of an experimental sodium chlorate product with and without nitroethane Evaluation of gallium maltolate on fecal shedding of Salmonella in experimentally-infected cattle Effect of vitamin D Supplementation on fecal shedding of E. coli O157-H7 in naturally colonized cattle Source: 2010 Beef Industry Safety Summit Executive Summary
New Technologies and Research The National Pork Board reports project such as: Optimization of antimicrobials for control of Listeria monocytogenes and for acceptable pork product quality The development of a novel immunosensor to detect Salmonella Surface Material, Temperature, and Soil Effects on Pathogen Growth in Condensate Use of ationic peptides as feed additives to improve innate immunity and reduce gut colonization with Salmonella and Campylobacter in weaned pigs
Industry Response to Pathogen Risk Preharvest Ranch Auction Market Feedlot Pre-harvest to Harvest Interface Holding Pens Washing Dehairing Harvest Steam Vacuum Acid Wash Hurdles Postharvest Fabrication Grinding At Retail SOURCE: G.C. Smith (Beef Industry E. coli Summit, San Antonio, TX, 2003)
Audits
PQA Plus is broken into Good Production Practices (GPP) GPP #1: Establish and implement an efficient and effective herd health management plan. GPP # 2: Use an appropriate veterinarian/client/patient relationship (VCPR) as the basis for medication decision-making. GPP #3: Use antibiotics responsibly. GPP #4: Identify and track all treated animals. GPP #5: Maintain medication and treatment records. Source: National Pork Board PQA Plus Training Module: 2009
PQA Plus GPP (continued) GPP #6: Properly store, label, and account for all drug products and medicated feeds. GPP #7: Educate all animal caretakers on proper administration techniques, needle-use procedures, observance of withdrawal times and methods to avoid marketing adulterated products for human food. GPP #8: Follow appropriate on-farm feed and commercial feed processor procedures. GPP #9: Develop, implement and document an animal caretaker training program. GPP # 10: Provide proper swine care to improve swine well-being. Source: National Pork Board PQA Plus Training Module: 2009
Procurement
Definition of Food Safety is Key Different definitions create multiple standards, multiple certifications, and greater complexity Creates more opportunities for document errors Have alternative programs to manage different standards, but not optimal Affidavits Export Verification Programs
Product Active Ingre. U.S. Wthdr. Rec. Wthdr. (JP) Company ChlorMax 50 Chlortetracyclin e 0 days 10 days Alpharma Chloratet 50 Chlortetracyclin e 0 days 10 days ADMAH Dectomax inject Doramectin 24 days 60 days Pfizer Benzathine Penicillin inject Benzathine Penicillin 50 days FARAD Draxxin inject Tulathromycin 5 days 33 days Pfizer
Roles of U.S. Government in Controlling BSE Food & Drug Administration (FDA) Animal & Plant Health Inspection Service (APHIS) Food Safety & Inspection Service (FSIS) Monitor & Enforce Feed Ban Conduct BSE Surveillance to Determine Prevalence & Verify Effectiveness of BSE Firewalls in U.S. Monitor & enforce the Removal of SRM s & Other New BSE- Related Regulations Protecting the health of the U.S. cattle herd Protecting the human food supply Agriculture Marketing Service (AMS) Provide auditing service to certify marketing programs (e.g., BEV)
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