ISO 9000 / GFSI / NSLP Foreign Material Controls In The Red Meat Industry

SAFETY | FOREIGN OBJECT CONTROL

August 20, 2014 • By Steve Sayer 

Currently, Steve Sayer is a workplace safety consultant to OSHA, EPA, GFSI, Humane Handling (feed livestock and birds), FSIS / AMS / USDA / FDA, and a technical writer for multiple industries, as well as a part-time maintenance worker for California State Beaches in San Clemente, California. You may contact him at sayersteve9@gmail.com

(Updated on 09 / 24 / 2022 - By Steve Sayer)

The USDA Food Safety and Inspection Service (FSIS) of the USDA is responsible for ensuring that U.S. meat and poultry products (including imports) offered to consumers are safe, wholesome, unadulterated, and properly labeled.

In fulfilling these responsibilities, the agency’s laboratories perform microbiological analysis of meat products, including investigations for foreign materials in the likes of metals, wood, plastic and glass.

The preclusion of this type of contamination begins on the farm / ranch where the livestock are raised. Producers of livestock have implemented their own safeguards to assure foreign materials do not enter the meat supply.

For beef, both national (USDA) and state regulatory programs work diligently to ensure domestic and imported beef, and beef by-product is the safest and highest quality beef possible.

Only wholesome, unadulterated products are eligible to bear the mark of USDA when they enter into the general commerce.

In the case of foreign material contamination, statistics evinces that the incidence at USDA inspected establishments - according to information released by the USDA - that foreign materials were the leading cause of food contamination during the first half of the calendar year 2019 - and growing ... .

Food Recalls Due to Foreign Materials are on the Rise

What’s more, the amount of food recalled due to foreign material contamination between January and June of 2019 added up to more than 13 million pounds. By comparison, for the entire calendar year of 2018, a total of just under 1.6 million pounds of food were recalled due to foreign material contamination.

Of the 125 total food recalls in 2018, 28 were prompted by physical contaminants.

This year, there have already been 93 food recalls, with 22 of them caused by the presence of foreign materials.

If USDA inspectors find products containing foreign materials because the establishment did not properly segregate and dispose of contaminated product, inspectors have the power to take regulatory control actions by issuing non-compliance records that require the establishment to develop a written corrective action and preventive measure(s), while contemporaneously ensuring no harmful product has entered into the general commerce.

In the event contaminated product does enter into commerce, establishments are advised to initiate a recall that would be announced by the USDA through the media and its website.

FSIS encourages, but does not require, meat processing establishments have detection technology available in the likes of metal detectors (ferrous, non-ferrous, and stainless steel) and/or X-ray machines (metals, glass, wood, plastics, etc.) in order to eschew physical contamination.

USDA-inspected establishments must have supportable justification from academia studies and/or in-house validation studies regarding how the procedures they employ will detect any possible foreign materials present. If foreign material contamination occurs, inspection program personnel must verify that an establishment follows their detection, segregation, and final product disposition procedures to ensure the contamination is removed.

This is all accomplished by having mandatory Hazard Analysis and Critical Control Points (HACCP) designed to preclude any chemical, physical, or biological hazard(s) from cross contaminating the otherwise wholesome meats.

QUICK TAKE - METAL / FOREIGN MATERIAL DETECTION WORTH KNOWING

From food grade / UL approved conveyor tunnels to -

a flow-through or a gravity fed,

or a pipeline.

Perhaps a double-double detector & check-weigher all in one?

Or, the throat style drop - thru step.

Go laser with induced breakdown spectroscopy (LIBS).

Even a pharmaceutical.

Choice is your$ to pick and choose that shall meet your products unique needs.

Certified test samples, of course, that can support compliance with the GFSI standards and external codes of practice including BRC v6, IFS v6, SQF 2000 Code 7.2, FSSC 22000 and Dutch HACCP (if germane) must be abided and certified by qualified contractors or - internally.

HACCP AND PREREQUISITE PROGRAMS

FSIS / USDA inspectors verify that the HACCP requirements associated with an establishments Prerequisite Program for foreign PHYSICAL materials are met on a continuing basis.

For example, inspectors verify the requirements associated with a Prerequisite Program for foreign material in a raw ground beef process by performing verification procedures on the detection devices themselves and by reviewing the establishment’s applicable HACCP recordkeeping that shall include - daily preventive maintenance documentation.

A USDA-regulated HACCP system requires that an establishment must conduct a hazard analysis to determine the food safety hazards reasonably likely to occur in the production process and identify the preventive measures that the establishment can apply to control those hazards. Historical data and customer complaints are also considered by the HACCP team when creating a hazard analysis.

If the establishment’s detection equipment is calibrated and finds product with foreign material contamination within the levels of detection, the Prerequisite Program would be considered as operating as designed, and detection is successful (e.g. a metal detector rejects boneless beef).

The HACCP team must evaluate the rejected product and, based on the findings of the product evaluation, determine the root cause of the contamination. Then the establishment should evaluate the incident to determine whether additional controls are needed to preclude the presence of foreign material in the future.

Plan, do, check and act ...

+ PDCA's inherent 'continuous improvements' tendencies ...

= The Marrow of GFSI - all in a well

documented package that's automatically posted up to earths lower orbit - always in chronological order and - relayed back - onto your hand-held smart phone's screen.

The study of foreign materials found in food is called - Microanalytical Entomology.

The FDA and the Association of Official Analytical Chemists (AOAC) have published reference articles, books, and methods on this subject that discuss methods of analyses, contaminant identification, and contaminant significance.

LIVESTOCK

In addition to the large dollar amounts that processors and manufacturers spend annually to ensure foreign objects are detected and removed from domestic meat products, livestock producers are also implementing their own safeguards to keep foreign objects, like buckshot, from entering the food supply.

Livestock producers are educating their employees and neighbors not to fire shotguns for herd control, and not to allow hunting of other wildlife in the vicinity of cattle herds.

Buckshot can inadvertently hit cattle from such practices, and the financial losses are magnified when the plant must detect and remove this foreign material later in the manufacturing process. As a result, livestock producers are increasing their efforts to reduce this potential source of contamination.

VOLUNTARY SAFEGUARDS

There presently exists a voluntary governmental program for beef establishments that produce fresh boneless beef and frozen ground beef for the nation’s schools and a variety of institutions that requires objectionable materials to be removed. This program is named the National School Lunch Program (NSLP) - of which I've proffered numerous times in these LinkedIn safety blogs.

The program requires a written technical proposal approved by governmental auditors from the Agricultural Market Service (AMS) that involves written procedures from the transportation of livestock (humane handling of livestock) thru the entire continuum of beef slaughter, fabrication, and ground beef.

The NSLP involves and promotes both food safety (HACCP program and FSIS inspection) and remarkably food quality requirements (i.e. fat percentage, net weights, and objectionable materials removal) that must meet AMS set parameters addressed within each USDA establishment’s technical proposal requirements.

The AMS’ technical proposal is based on the ISO 9000 series and requires the plan, do, check, and act format on every process step (from secured transportation of livestock to final secured delivery of finished beef products) to generate excellent conditioned boneless beef and frozen ground beef.

One key element of the program is the detection and elimination of objectionable materials (natural tissues of meats) as well as foreign physical materials (metals, plastics, stones, and glass).

A typical description involving objectionable materials in a plan, do, check, and act format of a NSLP technical proposal is partially cited below.

SUGGESTIVE CRITERION FOR MEAT TRIMMING OBJECTIONABLE MATERIALS - NSLP Requirements

4 defects > 0.5 inch in its greatest dimension = re-work the entire bin of raw beef trimmings

The definition of 0.5 inch in its greatest dimension is 0.5 inches in length, width, and/or diameter.

Description of Process—Objectionable materials

Major lymph glands (pre-femoral, popliteal, and pre-scapular) thymus gland, and the sciatic nerve (lies medial to the outside round).

All bone, cartilage, and the following heavy connective tissues; white fibrous—shoulder tendon, elbow tendon, silver skin (from the outside round), sacrociatic ligament, opaque periosteum, serous membrane (peritoneum), tendinous ends of shanks, gracilis membrane, patelleras ligament (associated with the stifle joint), Achilles tendon, and the yellow elastin, back strap, and abdominal tunic.

Trained quality assurance personnel ensure that the following objectionable materials are removed using a knife: the major lymph glands (pre-femoral, popliteal, and pre-scapular), thymus gland, bone cartilage, sciatic nerve, shoulder tendon, elbow tendon, sacrociatic ligament, opaque periosteum, tendinous ends of the shanks, patellar ligament (stifle joint), and internal fat, (kidney, pelvic, and heart fat.

Plan: How shall QA meet the production step?

All boneless beef products that are intended for the NSLP program shall be subject to visual inspection to ensure that the above objectionable materials are removed and placed into an inedible container. An approximate 30-pound sample shall randomly be taken from a combo bin (containing raw boneless beef) and re-inspected for any objectionable materials; approximately every thirty (30) minutes, plus or minus fifth-teen (15) minutes.

Do: The actual production step.

Beef carcasses are de-boned by skilled butchers.

Achilles tendons and external fibrous tissues are removed by the butchers prior to de-boning the hind shank.

The rump portion of each carcass is opened by knife cuts to separate muscle groups, exposing other tissues, such as silver skin, gracilis membranes, sacrociatic ligaments, popliteal lymph nodes, abdominal tunic, and pre-formal lymph nodes, which shall be removed. Back straps are removed by butterflying open the neck and back portion of the beef chuck, once the bone is removed.

The neck portion and the strap are trimmed off.

USDA-inspected establishments must have in place supportable justification from academia studies and/or in-house validation studies -

- regarding how the procedures they employ shall detect any possible foreign materials present.

The back portion are pulled out to expose the attaching membrane, which is cut by a knife and cleanly pulled away from the muscle tissue.

Boneless shoulder clods are then turned upside down exposing the interior side of the muscle and the pre-scapular lymph nodes.

At the two areas where the shoulder and elbow tendons protrude, the clod is checked on the butt end where the shoulder tendon protrudes approximately 1 to 2 inches, depending on the size of the shoulder clod, and at the point portion where the elbow tendon protrudes is also checked for defects.

Afterwards, the boneless beef travels down a conveyer belt and ends up accumulating directly into a combo bins.

At this juncture, personnel visually examine the boneless beef trimmings. The boneless beef that is destined for the NSLP program is placed into cardboard bins lined with a food grade plastic liner, fully and properly labeled at the end of pack-off.

At this point of the process, QA personnel perform the on-line inspection for objectionable materials.

Check: How do you verify using quality assurance check?

As the combo bins of boneless beef that are destined for the NSLP are in the filling process, an on-line Partial Quality Control program is performed and documented by trained QA personnel.

At approximate thirty (30) minute intervals (beginning from the start of each production shift if school lunch product is being processed), plus or minus fifth-teen (15) minutes, an approximate thirty (30) - pound grab sample of product is removed from a combo bin and placed inside an edible labeled tote and inspected by a trained QA.

An off-line organoleptic (visual) re-inspection is performed afterwards under enhanced lighting.

The boneless beef is then scored using a criterion for on-line inspection for boning defects. If the criterion is exceeded, all product produced from the last acceptable check will be tagged, re-worked, re-inspected, and documented.

IN SUMMARY

The NSLP like GFSI, is a demanding and unforgiving program that’s stricter (and arguably safer) than any other commercial or governmental program today.

The NSLP for frozen ground beef is indeed the unequivocal King Midas of the USA - thus far in the 21st century.

By reading through the plan, do, check, and act format, it’s imperative that constant employee training is required in order for the program to meet all of the AMS requirements and guidelines.

Failure to follow selected AMS guidelines can lead to a disqualification status. Plants can get reinstated by forwarding a cause and effect corrective action that is approved by selected officials at the AMS in Washington DC.

The Global Food Safety Initiative (GFSI) involving Safe Quality Food (SQF), British Retail Consortium (BRC), and the FSSC 22000 does not contain any such detailed requirements.

However, if USDA establishments have the ability to adopt both the NSLP and GFSI programs into their operations, such pro-active programs shall empower their operations several levels higher than that of their competitors.

Tru$t me.

I’ve always advised selected qualifying companies who are vertically integrated beef (harvesting (slaughter), fabrication, and grinding) that want to have the NSLP and GFSI programs integrated within their company operations - to successfully implement and - accomplish the myriad standards involving the NSLP first.

And all the while - inserting the very basics of GFSI codes (i.e. GAP analysis, note the myriad physical objects in each applicable room, pest control, histograms, control charts, etc.) in mind - in order to save valuable time and precious monies - with quicker re$ult$.

After all - both the NSLP and the multiple GFSI schemes are indeed P, D, C, and Acts - as well as - being International Organization for Standardization (ISO) 9000 based.

The trails of documentation, management commitment, and employee training that’s required to meet the many standards of the NSLP in of itself - shall naturally and seamlessly prepare a company’s operations upwards - to the demanding, but - - - oooh $o rewarding - ISO standards that is GFSI.

Steve Sayer, is a 41-year-veteran of the beef industry. He is presently a consultant ' auditor at Sayer Consulting / Auditing, LLC, in San Clemente, Calif. You may reach him at sayersteve9@gmail.com.

XTRA XTRA XTRA

WORD OF THE DAY

doughty

“The press likes to demonstrate its power by destroying lightweights, and pack journalism is never more doughty and complacent than when the pack has tacitly agreed that the candidate is but a joke.”