What does the OIG report mean?

Well, as the wheels of governance turn, the OIG has audited how FSIS tests beef trim for grinding.

BLUF: "The Office of Inspector General (OIG) found that the Food Safety 
Inspection Service (FSIS) needs to re-evaluate its E. coli testing 
methodology, as it relates to the downstream processing of boxed beef 
products. FSIS tests product designated as ground beef or likely to 
become ground beef, but they do not sample all boxed beef product. 
Some downstream processors grind such boxes of unsampled cuts of 
beef without sampling it for E. coli prior to grinding. Similarly, 
“retail exempt establishments”—grocery stores, butcher shops, etc.—
potentially grind their own ground beef; but unlike Federally 
inspected plants, FSIS does not sample and test bench trim at these 
establishments for E. coli. FSIS does have a program for periodically 
testing the final ground beef products at downstream processors and 
retail exempt establishments before it enters commerce. Also, FSIS is 
not testing tenderized meat products for E. coli despite several recent 
recalls."

So, there are a few gaps.  FSIS tests the beef trim that's obviously going for grinding, but it doesn't always test boxed beef that can end up being ground.

Raise your hand if you work at an establishment that grinds boxed beef.  Yep, that's a lot of you.

Directive 10010.1 sounds like it was a big target of this audit.

Which means, small USDA inspected producers, get ready for more testing.  Make sure your supplier program is pristine.  Are you keeping track of where that boxed beef is coming from?  Do you have a really good lotting system? If you get the boxed beef from a broker, it is going to behoove you to trace that beef trim back to the original source.

And for heavens sake, if you are tenderizing beef test your needles, test the tubing and keep really good records.  Because FSIS is probably going to be taking a really close look at what you are doing.  Nobody wants and OIG report out there, even on a Friday afternoon, that says you aren't fulfilling your primary mission.

PS- BLUF is Army speak for Bottom Line Up Front.

Validation- Are Your Systems Aimed at the Right Spot?

It is really easy to confuse verification and validation.  Validation is a subset of verification, so when you are validating, you are verifying, though the converse is not true. Confused yet?

Verification= are you doing what you say you are doing?
Validation= is what you are doing protecting the public health?

Validation requires collecting and evaluating scientific and technical information to determine if the HACCP plan, when implemented correctly will effectively control the identified hazards (paraphrasing from a NACMCF definition).

Validating your HACCP means that you are assuring the plan is adequate for controlling food safety hazards.  If that seems like a big task, it is because it is.  You can't find a scientific paper that validates an individual HACCP  plan as a whole.  But, you can break it up and validate the CCPs.  Every CCP needs to be validated.  Taken together validated CCPs validate your HACCP.

So, start googling.  But not just anywhere.  Read up on your regulatory agency and validation

• USDA 
• FDA- dairy
• FDA- juice look in section F
• FDA- seafood (lumped into verification)

Start with those resources and look for scientific papers that pertain to the process you are working on.  Then start looking at the known physical, chemical, and microbiological hazards in your process.

Then, ask around to see if you are on track.  Ask your extension agent for help.  Shoot me an email, I'm always up for a conversation about food safety!

Once you have scientific papers to back up your CCPs, look at your actual process to see if it is delivering those critical limits.  Is your bacon being smoked at 144F?  Every single slab?  In all parts of the smoker?  Every single time?  Got records to prove it?  How about your cooler?  Is it supposed to be below 41F?  Is it?  In all parts, even right next to the door?  How are you going to test it?  Do you have records to prove it?

Validation can be hard, make sure you are doing it right.

Charcuterie For the Small Processor

DQM spent the weekend at the New England Meat Conference.  It was a fantastic gathering of entrepreneurs, producers, processors, chefs, meat cutters and just about anyone else working to create the New England market for local meats.

And if there was one over riding interest after "isn't this cool?  All the people I know and like are in one place!!" it was charcuterie.

From a food safety perspective, charcuterie is challenging.  But hey!  Let's break it down!  Food safety challenges are what we do here at DQM!  The following is by no means an exhaustive list, but, it is a good start.

First- figure out what you want to make.  And don't just say sausage.  Do you want to make Spanish sausage?  Mexican?  Polish? The more specific you define your product the easier it is going to be.  You need a recipe.  Even if it is your grandmother's that you used to make in the basement, you need to know what and how much is going into the product

Second- Understand what process steps are.  When you write a HACCP plan, you need to have a process flow diagram.  And your commercial charcuterie production needs to have one full of excruciating detail.  You are going to get inspected on how well you adhere to this flow, and if you don't, there can be huge consequences.  Make sure your process flow diagram starts with Receiving Meat.

Third- Once you understand what you are making and how, then start thinking about the whole food safety plan including pre-req programs, the HACCP plan itself, training, and what avenue of inspections are available.

Putting a delicious and safe charcuterie product in the marketplace is absolutely possible.  However, it takes attention to detail, and frankly, is tough to do without some help.  When you are ready to take that step, give DQM a call, and we will be right there with you to put your wonderful product into the marketplace!

Verification of CCPs

So, are you telling the truth?

Is your production team doing what it says?  Are you sure?

Wanna know how to be sure?  It's through verification!

First, an easy way to remember the difference between verification and validation.  Verification comes from the latin root vera meaning truth.  Ergo (ha! more latin) verification is the HACCP step where you determine if you are telling the truth about your HACCP plan.  Validation asks if what you are doing is useful to control hazards.

Verification has 3 components:

• your CCPs are being followed
• the whole HACCP is in place and being followed
• regulatory verification

Verifying can be done many ways.  In meat production, a pre-shipment review is a regulated verification step.  In other types of production, any step where you review your logs and sign off that you have reviewed them, is a verification.  Audits are another good way of verifying work.  Finally, having the regulators pay you a visit and give you their findings is a way of verifying.

Some good ways to verify:

• Review your monitoring records.  You are spending ages recording everything, take a look at it, make sure you are recording correctly.  Review at a frequency that makes sense.  Don't review your cleaning step once a quarter only to find out that your concentrations of cleaner is WAY off.  Imagine THAT recall.
• Calibrate!  Got a thermometer?  Is it working?  You sure?  Fill a container with ice water, stick the thermometer in.  Make sure the thermometer is reading 32F.  If you don't remember why this works, consult your high school chemistry notes.
• Grab your accountant, promise you will take her out to lunch if she'll spend some time looking at your workers work.  Put her in a lab coat and have her watch one part of your production process.  Don't worry, the workers will do it right for about 3 minutes, and then, they'll do it how they always have done it.  Over lunch, talk to your accountant and figure out what's working and what isn't.
• Get some lab samples done.  Finished product testing is ok, but non-specific and expensive.  Test something specific, like your injector, or swab a food contact surface in your processing room.  If it turns up positive...

Call me, I'll help.  Dirigo Quality Meats can help with straightening out all sorts of processing problems.  908-907-7798

HACCP training coming to New England

I've been spending my week in Washington DC with the good folks of the GMA doing a HACCP "Train the Trainer" class.  In addition to covering every nook and cranny of HACCP plans for both USDA and FDA plants in exhaustive detail the course has gone into great detail about how to teach adult learners.

When my courses are approved, I am going to start teaching IHA accredited "Introduction to HACCP" courses.  I am also going to bring shorter 1 day courses into the market on Pre-Req programs, SOPs, and sSOPs among others.  Currently, these courses are simply not available to Norther New England producers without traveling out of the region.

But no more.  The highest quality, most rigorous HACCP training is come to New England.  Brought to you by Dirigo Quality Meats.

The first one day general class is going to be April 24 9-5 at the Androscoggin Chamber of Commerce.  Sign up on the webpage.

Pre Req Programs

HACCP plans can not exist without the proper pre requisite programs (PP).  PP are the basis of a comprehensive food safety program.  PP's do two things in food production:

1. They make hazards "Not Reasonably Likely to Occur" (NRLTO)
2. They control just about everything else in a plant that isn't hazard.

So, what's a hazard?  A physical, chemical, or microbiological adulterant of food.  Think metal shards, allergens, and E. coli.

PP don't control those hazards.  Critical Control Points (CCPs) do.

But what do PP do?  They use Standard Operating Procedures (SOPs) to bring control into the plant and impose the order necessary to reduce the likelihood of physical, chemical and microbiological contamination of food.

So what are some PP?

• Chemical hygiene plans
• Pest Control plans
• Receiving SOPs
• Approved supplier programs
• Personnel hygiene programs

The truth is that most of the food borne illness outbreaks occur because of improperly implemented and executed PP.  CCPS do.  CCPs are generally observed and controlled, that's the point.  They work. But, it takes a whole culture of food safety for everyone to make sure that PP are also observed and practiced.  Fail at them, and all the CCPs won't help.

Need help evaluating your Prerequisite Programs? Email Dr. P

Is it getting chilly in here? Cooling as a CCP in Meat

I talk a lot on this blog about broad food safety issues, but today, I am going to talk about a specific CCP point as it occurs in both Fully Cooked RTE foods, and Heat Treated, Not Fully Cooked, not RTE foods.

When writing a meat/poultry HACCP the CCPs we put in control for Physical, Chemical, or Microbial hazards.  Most of the time, we spend a lot of time worrying about what those microbes are doing on our meats.  Writing a heat treatment CCP makes us feel all good because we are killing a lot of those microbes.

But we don't kill the spore formers.  Those Clostridia and Bacillus can survive boiling water, freezing cold, and pretty much all the chemicals we might want to throw at them.  The spore itself is pretty fascinating.  However, what spore forming bacteria can do to us and our food can be problematic at one end of the spectrum, and deadly at the other end of the spectrum.

When spore forming bacteria are heated, they form their spore, lie dormant till the threat is passed, then return to their normal, active vegetative state where they are the greatest threat to health, because they are making toxins and multiplying.  Cooling food can spend a lot of time in the danger zone of these bacteria.  Ergo, we must cool them quickly so that the spore formers go dormant once again.  

Clostridia is especially active at 130F to 80F and thus cooling must be as rapid as possible within that range.  But keep in mind, that cooling (like heating) is a dynamic process that takes place at a different rate in different cuts of meat.  A uniformly ground and packed sausage will heat and cool uniformly.  A bone-in ham will not.  And a bone-in ham will cool at a different rate than a brisket.  The cooling of the product depends on the temperature differential between the hottest portion of the piece and the coldest portion of the piece (for you calculus types this is dT/T).  The greater the difference between the hottest part and the coldest the more rapid the cooling.  So what can a processor do to speed things up?

Use potable water to continually chill the outside of the meat.

Put the meat through a tunneling system.

Put the meat in the freezer

FSIS really likes it if the meat can drop from 130F to 80F in 1.5h and then to 40F in 5h (Option 1).  

Keep in mind though that cooling meat puts heat in the air, hot air rises, hits the cool ceiling of your establishment, cools and condenses.  And that my friends brings out the Listeria!  But that is a post for another day.

Many small processors don't have the myriad of expensive equipment to cool the meat and handle the moisture in a way that satisfies Option 1 of Appendix B which leaves cooling meats in the finished product cooler under Option 2, which brings the temp from 120F to 55F in no more than six hours.

Both options are valid.

But, you have to test that the cooling is occurring in all parts of the meat, in all the sizes you are using.  Thermometers and time temperature graphs are a great way to test this.  

Interested in learning how to make a validation test?  Send me an email for a validation testing procedure.

Hazards and FSMA

The regulations that are part of the FSMA, are becoming clear.  The FDA is clearly working hard on making sure the marketplace has adequate information.  They've re-organized the website and added a Small Business Page.

But here's the short and dirty version.  Processors that need to register:

• Dietary supplements and dietary ingredients
• Infant formula
• Beverages (including alcoholic beverages and bottled water)
• Fruits and vegetables
• Fish and seafood
• Dairy products and shell eggs
• Raw agricultural commodities for use as food or components of food
• Canned and frozen foods
• Bakery goods, snack food, and candy (including chewing gum)
• Live food animals
• Food for animals (e.g., pet food, pet treats and chews, animal feed)

Farms don't have to register IF all the food  "is grown, raised, or consumed on that farm or another farm under the same ownership, as well as facilities that manufacture/process food, provided that all food used in such activities is consumed on that farm or another farm under the same ownership."

FDA compliant businesses will need to address the following hazards:

•  Biological
• Chemical
• Physical
• Radiological hazards
• Natural toxins
• Pesticides
• Drug residues
• Decomposition
• Parasites
• Allergens
• Unapproved food and color additives
• Hazards that occur naturally
• Hazards that may be unintentionally introduced
• Identify and evaluate hazards that may be intentionally introduced, including by acts of terrorism

That is no short list!  

Fortunately, help is at hand  I will teaching a Risk Analysis/HACCP 101 course on April 24 at the Androscoggin Chamber of Commerce.  The Course wil cover the risk analysis and HACCP that the FDA requires.  Registration is on the website.  We look forward to seeing you!

Labeling out of RTE

Back in September, the USDA rolled out a new Listeria Compliance Guideline.  At first glance this Guideline seems to be only for RTE foods.  Fair enough, that's where Listeria is most problematic.

But, Attachment 1.2 updates how they consider products that receive a full lethality treatment that are not RTE, and are not defined as such by 9CFR 430.1.  Value added products that are not hot dogs or deli meat can now be "labeled out" of RTE status.  Producing those products under a Heat Treated, Not Fully Cooked, Not Ready To Eat, then labeling them as NRTE, and clearly marking them with cooking instructions, now seems to be an acceptable way to put cooked product into the marketplace, without having to comply with Listeria controls.

This means that plants that have hesitated to put smoked meats, pot pies, or frozen dinners into the marketplace, now have clear and concise guidelines on what to do and how to justify their decisions.  Thanks USDA!

Do you have a product that you are wondering about?  I offer free initial phone consultations on HACCP and other food safety plans.