BEST BUSINESS PRACTICES FOR PRODUCING BEEF HARVESTING, RAW NOT GROUND BEEF, RAW GROUND BEEF - PART 1

By Steve Sayer

INTRODUCTION

This series shall examine the step-by-step process that is required for manufacturing wholesome and properly labeled raw meat at a factious FSIS/USDA beef harvesting, raw not ground beef, raw ground beef establishment in 2022.

The three (3) processes of this vertically integrated USDA establishment shall be:

BEEF HARVESTING OF CATTLE

RAW NOT GROUND BEEF

RAW GROUND BEEF

_______________________________________________________________________

BEST BUSINESS PRACTICES

ABC Meat Company's high standards of product safety and quality is our guarantee to all of our valued customers of our commitment to producing fresh and wholesome raw beef products through our pro-active science-based interventions and our consistently high quality systems.

Effective sanitary dressing and process control procedures help to support Critical Control Points (CCP) that prevent, eliminate, or reduce to an acceptable level food safety hazards that are reasonably likely to occur in our Harvest process that can directly effect our Raw Not Ground Beef and Raw Ground Beef Operations.

All of our written and verifiable food safety interventions, employee training and extensive time-tested programs exceed the requirements set by the Food Safety Inspection Service (FSIS) United States Department of Agricultural (USDA).

SSOP – Sanitation Standard Operating Procedures – Every USDA inspected facility must establish standards for sanitation and define those procedures. SSOP’s deal with the general sanitation of all direct product contact areas such as cutting boards, conveyor lines, hand-held tools, etc. Program procedures also address personal hygienic practices and direct product handling during the course of production. 

HACCP – Hazard Analysis (and) Critical Control Points deals with the three (3) hazards that may contaminate meat; biological, chemical and physical hazards. Our customized HACCP Programs are verifiable science-based systems that define and determine “Critical Control Points” (CCP’s) throughout the continuum of harvesting, processing, grinding, storage and shipping .

GMP – Good Manufacturing Practices were originally developed by the Food and Drug Administration, (FDA). GMP’s deal with what HACCP and SSOP’s do not directly address; objectionable material elimination program, net weight control, pest abatement programs, etc. GMP’s play an important supporting role of our HACCP, SSOP, SOP, & Pre-Requisite programs.

PRE-REQUISITE PROGRAM – Entails SRM’s & Drug Residue.

Microbiological Testing – “Science-based systems” deal directly with time-tested interventions and standards set by academia in which governmental agencies set their directives and policies upon. Pathogen interventions such as lactic acid spraying, carcass steam vacuums, hot water pasteurization, product temperature control and microbiological testing of meat products, including product contact and non-contact surfaces are but a few science based interventions that have been incorporated into our programs. ABC has on site an AOAC/USDA recognized microbiological laboratory that allows us to monitor the efficacy of our sanitation practices as well as verification/validation of our science based interventions. 

HACCP, SSOP & GMP Training – ABC has in place time tested and well designed bilingual employee training programs that involves individual job descriptions, good personal hygiene practices, total food safety and CAL/OSHA safety that centers on the concepts of HACCP, SSOP’s, and GMP’s; Plant management views our employees as being one of our biggest assets. Refresher courses for all employees are carried through and documented on a continuing basis.

ABC has three (3) HACCP Systems incorporated at our establishment;

HACCP for Harvesting of Cattle

HACCP for Raw Not Ground Beef 

HACCP for Raw Ground Beef 

_____________________________________________________

SUPPORT DOCUMENTATION 

The information listed directly below supports the decisions process that is used in the determination of our HACCP Systems:

There is not a regulatory requirement for the control of temperature involving red meat or poultry products. Therefore we are using a study by the USDA that was released prior to HACCP becoming mandatory for the very small plants, (USDA. ARS. FSIS. Proposed rules of 1995 under the Federal Register 60:6881-9881).

A page from the training manual for the development of a HACCP Plan published by the USDA for the very small plant Table 1, USDA.ARS.FSIS. Proposed rules of 1995 under the Federal Register 60:6881-9881)

We have a study by R. B. Tompkin and P. W. Bodnaruk on the control of E. coil 0157:H7 & Salmonella in ground beef/poultry as well as slaughter operations. This report has been accepted by the agency as a valid and comprehensive study on the control of this pathogen.

This report states, “It is accepted that when present E coli 0157:H7 and the six (6) NON - O157:H7 STECS is on the surface of carcasses, not internal tissues,” “After chilling is unlikely that E coli 0157:H7 will multiply during subsequent fabrication because the lower limit for multiplication of E. coli 0157:H7 is 44.6º F – 46.4º F (7º C - 8º C). Furthermore, laboratory data based in optimum conditions indicate that: At 50º F the time to increase 10-fold is estimated to being fifty (50) hours. At 60º F the time to increase 10-fold is estimated to be twenty-one (21) hours.

We have a study by A. Castillo, L. M. Lucia, K. J. Goodsin, J. W. Savell, and G. R. Acuff on the use of lactic acid treatments for reducing bacteria of fecal origin on beef carcasses. This report from the Journal of Food Protection, Vol. 61, No. 7, 1998 evinces this treatment to reduce bacterial contamination on beef carcasses.

Our CCP’s in the slaughter process is ZERO TOLERANCE and the Lactic Acid Spray. The edible blood and bile has a CCP at the refrigeration stage to be checked the following morning with a surface temperature of 44.6º F or lower.

 MONITORING

BEEF SLAUGHTER PLAN

(CCP 1B) - The Lactic Acid is checked for PSI, lactic acid %, temperature and time duration. The lactic acid is applied to the carcasses and variety meats. The PSI, lactic acid %, temperature and time durations shall be documented / accomplished at the start and at the end of each harvesting day and every two (2) hours plus or minus 20 minutes.

(CCP 2B) - ZERO TOLERANCE for fecal, ingesta and milk matter is performed carcass sides including Head and Cheek meat. The ZERO TOLERANCE for carcasses is checked every hour, plus or minus 20 minutes, by randomly selecting three (3) carcass sides. The Head and Cheek meat applies ZERO TOLERANCE after twelve (12) hours three (3) separate thirty (30) pound samples during the course of harvesting in order that random sampling is achieved.

(CCP 3B) - The edible blood and bile is checked the following production day for temperature control of 44.6º F., or below.

RAW NOT GROUND MEAT PRODUCTS

(CCP 1B) – The Raw Not Ground Meat Products have a critical control point involving the surface temperature of 44.6ºF or below at the packaging operation. Temperatures shall be documented every two (2) hours plus or minus twenty (20) minutes.

RAW GROUND BEEF PRODUCTS (SCHOOL LUNCH PROGRAM)

(CCP 1B) - The Raw Ground Beef Products have a critical control point involving surface temperature of 44.6º F or below at the packaging operation. Temperatures shall be documented every two (2) hours plus or minus twenty (20) minutes.

FREQUENCY

The Beef Slaughter Plan has three (3) CCP’s: the Lactic Acid Spray, ZERO TOLERANCE and the Chilling Process for edible blood and bile. We have historical data to support the effectiveness of all three (3) CCP’s. The current frequencies for these CCP’s are in the Hazard Analysis for Beef Slaughter.

Following discussions with the Technical Center, District Office and the National Meat Association, it was determined that there is no scientific data to determine frequency of the testing regarding surface temperatures. When we started with HACCP in 1999 we were documenting CCP’s for surface temperature every two (2) hours plus or minus twenty (20) minutes during operations. During this time period of approximately one (1) year we did not have any deviations or abuse of temperature of the meat products that we were producing, therefore it had been proven as acceptable We changed our frequency for the Raw Not Ground Meat Products from every two (2) hours, plus or minus 20 minutes to twice per shift. The Raw Ground Beef operations also has their surface temperature checked at least twice per shift.

CRITICAL LIMITS

ABCs Harvest operations have several critical limits that are monitored and recorded which evinces their effectiveness.

HOT WATER PASTEURIZATION/HAND HELD STEAM VACCUM

Studies by Tanya Roberts, USDA/Economic Research Center, Scott A. Malcolm, John Hopkins University and Clare A. Narrod, USDA/FSIS/OPHS/ERAD performed probabilistic Risk Assessment using hot water pasteurization. Significant log reductions after occultation ranged in the area of 3.0 logs at 165°F with time duration of 10 seconds. 

Hand/held steam vacuums – Castillo et al. 1999a; Dorsa et al. 1996; Kochevar et al; Sofos et al. 1999.

COMMERCIAL PRODUCTS:

ABC manufactures and distributes raw boneless beef and dissimilar raw beef cuts products to food distributors, further processors and fast food chains. No added ingredients (Allergens) are used. Presently ABC is self-supplier with no outside meats delivered.

This manuals objective is to evince each harvesting step in the format of Plan, Do, Check & Act, (PDCA) which is the basis of ISO 9000 Standards. ABC fully realizes that the planned intervention steps that we have put into place are the foundation of food safety and quality at our establishment. Our goal is to reduce and eliminate virulent pathogens in our wholesome meat products.

This Harvest/Raw Not Ground Beef Food Safety Manual is an eclectic compendium of programs that ABC has in place that directly affects the production of fresh and wholesome raw meat products. Training and additional training of employees shall be the method with producing consistently wholesome raw meat products.

TABLE OF CONTENTS

PAGES 1 through 5 … General Introduction – Table of Contents 

PAGE 6 … Management Structure American Beef Packers 

PAGE 7 … Support Documentation – HACCP - Harvesting

PAGE 8… Domestic Origin

PAGE 9 … Specific Risk Material Letter – 2008

PAGE 10 … E. coli O157:H7 Intervention/Elimination Letter

          Requirements for Delivery Drivers of Livestock

 PAGES 11 through 18 … Pre-requisite Program Procedures for SRM’s 

                     – Harvesting Operations          

PAGES 19 … Quality Control/Assurance – Harvest

PAGES 20 through 23… Receiving Cattle

PAGE 24 … Corrals

PAGES 25 through 27 … Humane Handling

PAGES 28 & 29 … Non-Ambulatory Disabled Cattle

PAGE 30 … Washing of Livestock

PAGES 31 through 34 … Stunning Operation

PAGES 35 through 37 … Sticking/Bleeding Operations 

 PAGS 38 & 39 … Tying & Rodding of the Esophagus

PAGES 40 through 43 … Head/Fore-Feet Removal Operation

PAGES 44 & 45 … Head Wash Operation

PAGES 46 through 49 … Hind-Shank Removal Operation

PAGES 50 through 53 … Udder Removal Operation

PAGES 54 through 57… Skinning Operation 

PAGES 58 through 62 … Bung Dropping & Brisket Operation

PAGES 63 through 68 … Pre-Evisceration, Trimming, Steam Vacuum

                     & Lactic Acid Spray

PAGES 69 through 71 … Cleaning/Bleaching Tripe Operation

PAGES 72 through 75 … Small Intestines Operation

PAGES 76 through 78 … Variety Meat (Offal) Operation

PAGES 79 through 87 … De-boning of Heads & Beef Tongue Operation

 PAGES 88 & 92 … Head, Weasand, (when applicable), & Cheek Meat

                  Inspection (CCP 2B) ZERO TOLERANCE

PAGES 93 through 95 … Splitting Operation

PAGES 96 through 98 … Spinal Cord Removal

PAGE 99 … Rail Outs (USDA Final Disposition)

PAGES 100 through 102 … Post Trimming and Steam Vacuuming Operation 

                       – Lower and Upper Areas

PAGE 103 … Final Rail Inspection – Rail Outs (Inspexx 200 Spray)

 PAGE 104 … SSOP Procedures for Tail Removal (When Applicable)

 PAGES 105 through 108 … Hot Water Pasteurization Cabinet Operation

PAGES 109 & 110 … Scribe Saw Operation

PAGE 111 … Final Carcass (cold) Wash Cabinet Operation

PAGES 112 through 114 … Lactic Acid Spray Cabinet Operation

                       (CCP 1B)

PAGE 115 … In-House – Final Rail Inspection

PAGES 116 through 120 … Final Carcass Inspection – (CCP 2B)

                          ZERO TOLERANCE

PAGE 121 … Packaging Operation

PAGES 122 & 123 … Cold Storage

PAGE 124 … Shipping/Transferring

PAGES 125 ... Return Product Procedures                         

PAGES 126 through 131 … Shipping Protocols of E. coli O157:H7 Product

PAGE 132 through 149 … Microbiological Testing Protocols & Lotting, 

                    Traceability

 PAGE 150 through 166 … SPS Protocols

PAGE 167 through 171 … RNGB QC Program

PAGES 172 through 206 … RNGB HACCP Decision Making

PAGE 207 … General Food & Employee Training Overview

PAGE 208 …General Sanitation Overview

PAGES 209 through 219 … Preventive Maintenance Program & MSOP’s

PAGE 220 … Food Defense Program Overview

PAGE 221 …Edible Bile

PAGE 222- 224 … Edible Blood

_______________________________________________________________________

SUPPORT DOCUMENTATION 

The information listed directly below supports the decisions process that is used in the determination of our HACCP Systems:

There is not a regulatory requirement for the control of temperature involving red meat or poultry products. Therefore we are using a study by the USDA that was released prior to HACCP becoming mandatory for the very small plants, (USDA,ARS.FSIS). (Proposed rules of 1995 under the Federal Register 60:6881-9881).

A page from the training manual for the development of a HACCP Plan published by the USDA for the very small plant Table 1, “Characteristics of Growth for Nine Pathogens Associated with Meat and Poultry Products,” and Table A-1 Limiting Conditions for Pathogen Growth,” published by the Food and Drug Administration.

We have a study by A. Castillo, L. M. Lucia, K. J. Goodsin, J. W. Savell, and G. R. Acuff on the use of lactic acid treatments for reducing bacteria of fecal origin on beef carcasses. This report from the Journal of Food Protection, Vol. 61, No. 7, 1998 evinces this treatment to reduce bacterial contamination on beef carcasses.

Our CCP’s in the beef harvesting process is the Lactic Acid Spray and the Zero Tolerance Inspection. 

BEEF HARVESTING PLAN

• CCP 1B – The parameters of the Lactic Acid is checked for PSI, lactic acid %, temperature and time duration. The lactic acid is applied to beef carcasses.
• CCP 2B - ZERO TOLERANCE for fecal, ingesta and milk matter is performed carcass sides including Head, Weasand, (when applicable) and Cheek meat. The ZERO TOLERANCE for carcasses is checked every hour by selecting three (3) carcass sides The Head, Weasand (when applicable) and Cheek meat applies ZERO TOLERANCE after twelve (12) hours three (3) separate thirty (30) pound samples.

_____________________________________________________________________ 

DOMESTIC ORIGIN

Description of Process

All cattle that are harvested by ABC originate from only U.S. produced domestic livestock suppliers. All cattle are considered to be thirty (30) months of age or older.

Plan: How ABC shall meet the production step?

ABC receives and harvests livestock that are only domesticated U.S. livestock. As a responsible and accountable harvester ABC shall;

Do: Actual production step?

ABC has on file documentation which verifies that ABC harvests only domesticated produced livestock. Livestock are from local dairies including surrounding areas in California and other bordering States. 

Check: How do you verify using Quality Assurance check?

All harvested ABC livestock are of domestic origin only. Compliance with this requirement will be verified through all receiving invoices and applicable documentation that pertains to the origin of the live cattle delivered to our Establishment.

Act: What action(s) will be taken based on the Quality Assurance check?

Sustained documentation and verifiable records are filed in chronological order and can be confirmed that only livestock that is of U.S. origin are harvested at ABC.

SSOP PROCEDURES FOR SRM – HARVESTING OPERATIONS

The following protocols concerning SRM’s from cattle harvested at our Establishment is listed below;

1. All previous SSOP’s will be followed by plant personnel.
2. All cattle harvested at our establishment are considered to be in the category of thirty (30) months of age or more.
3. SRM’s are defined as being the skull, brain, trigeminal ganglia, eyes, tonsils, vertebral column, neck bones, lumbar vertebrae, wings of the sacrum, distal ileum, spinal cord, and dorsal root ganglia. 
4. Removal of the Distal Ileum – See separate SSOP procedures regarding the removal of the distal ileum as per FSIS Notice 58-05.

Removal of Spinal Cord – The spinal cord is removed in its entirety on the slaughter floor just prior to post evisceration steam vacuuming. Lifting of the cord tissue out of the vertebral canal is achieved by the use of a Bettcher TrimVaccum System. If any spinal cord remnant is discovered, the carcass will be retained and re-worked.

1. Any carcass that is found to be harboring fragments of SRM’s will be retained and re-worked and subject to further inspection and documented as such.
2. SRM materials are separated at the earliest opportunity. SRM materials are placed into an inedible container and moved to the inedible area. GMPs entails proper ID of employee's handling SRM residuals.
3. Any head that is retained by the USDA shall be tagged and discarded. All beef heads are to be inspected by the USDA prior to condemning. The discarded head shall placed in inedible rendering and documented (assigned tags of USDA). 
4. Monitoring forms for proper SRM removal is performed. 
5. SRM’s are processed through Darling - Please Believe Me Rendering System. The SRM’s are exposed to 275°F temperature for a minimum of one (1) hour. An annual letter is on file stating that the SRM product will not be sold for ruminant feed. _______________________________________________________________________

Annual Cattle Letters of Guarantee are sent to cattle suppliers regarding FDA Title 21 Part 589.2000 of the Code of Federal Regulations (Effective August 4, 1997) that prohibits the feeding of ruminant meat and bone meal to ruminant animals. These documents are filed in sequential order for references. (To avoid possible mad cow disease).

_____________________________________________________

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

OVERVIEW

ABC 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 are offered for slaughter be condemned. 

All related records of the Final Rule shall 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 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;
• 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 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. ABC 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 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 with the brain sucked out of the skull and is washed with cold water to remove any possible contaminates. 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, and trigeminal ganglia intact) are 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 the 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 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.
• Removal of the spinal cord - Harvest. After the splitting of a carcass is accomplished, the spinal cord tissue is removed by using a Bettcher Trim Vacuum System. The spinal tissue is automatically discharged to an outside storage tank.                   
• Removal of the spinal cord - Deboning. 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. 
• 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) months of age of older: 

• Skull, eyes and trigeminal ganglia: Designated orange handled knives are dipped into a SRM dedicated knife sterilizer after each head is trimmed. Sterilizer for the knives is measured at 180°F or higher. Knives, hooks and steals are to be placed in the sterilizer a minimum of 4 to 5 seconds. The cutting table that the heads are placed and trimmed on are washed with water every five (5) heads. 

SSOP PROCEDURES FOR SPECIFIC RISK MATERIALS                              

• 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 by the means of a Bettcher Trim/Vacuum System. When applicable, orange colored 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 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 (4 to 6 seconds) after each head is processed. 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 Directive 6100.4, dated 9/13/2007. 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 by the receiving Establishment. 

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 5/7/2009.
• ABC shall be 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 are 30 months of age or older and states that the customer is the responsible party to remove and properly dispose any SRM’s that remain attached. 
• The certificate of analysis (COA) contains the Date, Vendor Name, Purchase Order, Seal Number, Slaughter Date 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 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 at our establishment.

 MONITORING OF SRM’S 

This Pre-requisite 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 Notice 56-07, dated 8/31/07.

Any deviations to this Pre-requisite Program shall be noted on the Operational Deficiency/ Corrective Action form with a documented reassessment being conducted. An annual reassessment of this SSOP shall be conducted at least once a year or earlier.

All germane documentation of these procedures shall be available to the USDA upon request.

_____________________________________________________________________

PART 2 PREVIEW FOR --- WEDNESDAY 03/30/2022

__________________________________________________________________________

FINAL NOTE TO CHAPTER 1

As you can tell, I myself prefer color coding each individual HACCP / SSOP stages of operations while listing / showing all germane USDA /FSIS Directives and science-based studies, and HACCP / SSOP monitoring forms that support your HACCP system to one's unique operations - all in one single program electronically or by paper (the old fashion way).

I like peppering the Best Business Practice Program with all the applicable USDA Directives and Notices - as you shall see next week Wednesday.

Why?

Because you want to evince to the auditor that this Best Business Practice Program is a "piece of cake" and that you have your establishment regulatory act "toooo-gether" by having everything written or scanned --- with pictures. Lot's of pictures as you'll see beginning next week.

I hated, early on, when I was being audited, to rush to this book or that manual during an audit. This has just about everything you'll need as you shall see as we march on.

BTW: Your objective is to get the GFSI auditor - or - USDA / FSIS out / gone - ASAP.

By having a crystal clear, razor sharp science-based program that is easy for a 12-year old to read and reference to - is keen.

It works.

One always wants to proffer the impression to the auditors, that you, as the HACCP Coordinator have your regulatory act together. Slam, bam, thank you ........... lad.

And you shall give off that type of impression - while remaining humble.

Don't forget to always date and sign your programs and germane documents including a John Hancock signature on thou HACCP flow chart.

Lastly, never ever volunteer anything during an audit.

Let her or him always, always ask, ask, ask.

________________________________________________________________________

.