Food Safety from Producer to Plate: Part 1- E. coli in Beef

We talk a lot around here about what processors can do to improve food safety.  That's where most of the inspection is and that's where it is possible to put in the controls to eliminate food borne illness (FBI).

However, one of the main reasons why the processors need to put in these controls is because their supply comes in contaminated.  Animals and plants grown on a farm harbor pathogens.  Nothing we can do about it.  Biological systems are complex and we are never going to eliminate pathogens from our food completely.  Nor do I think should it be a goal to eliminate them, because these microbes exist for a reason.  They work in the soil and they work on an animals gut to aid digestion.  We find trouble when microbes are in the wrong place, occur in much too high a concentration, or occur at the wrong time.

As our local food movement moves forward, producers needs to know about the various pathogens of FBI that occur in their livestock and what they can do about them on the farm.  A lot of times this stuff is obvious, but, putting in FBI controls at the farm can save a lot of headache down the road.

So with that said, today's post is the first in DQMs "Producers to Plate" series!  And we are going to start to tackle E.coli from the viewpoint of what a livestock rancher can do to control it.

First, what is  E. coli?  E. coli is a group of bacteria that live in the large intestine of warm blooded animals.  E. coli, like other bacteria, isn't a problem unless it is too high in number, or in the wrong place. E. coli can use the flagellum to migrate out of the gut of an animal and "walk" itself to an aberrant site like the urinary tract causing a UTI.  E. coli contamination of an udder can cause mastitis by the same mechanism.  The bacteria gets where it shouldn't be, has a lot of nutrients and no bacteria to compete against, and POW, infection.

In the food supply, we worry about E. coli because it can cause very serious FBI, like hemolytic uremic syndrome.  Though cases of E. coli are going down the CDC estimates that there are 26 cases not reported.  So we have a lot of people not being diagnosed.  Which means there's no traceback to where the illness might have come from.

However, livestock ranchers can help protect their product by taking some steps to decrease E. coli in their herds.  Also, implementing these can help to protect a rancher's family from E. coli, as it is also a zoonotic disease.

Vaccinate the herd against E. coli
Feed probiotics with Lactobacillus (like Bovamine)
Test for supershedders and cull them (and not into the food supply)
Make sure the cattle are clean before slaughter.  Work with your processor and find out what his/her plan is for killing clean animals.  Preventing hide contamination of meat can not be over estimated.  This should be one of the pre-req programs (or part of a pre-req program) the processor has.

This

Not this

As the CDC has indicated, E. coli contamination is a battle we are actually making headway against.  The local food movement has a great opportunity here to make sure that our consumers have access to meat that's as free of E. coli as possible.  It will drive confidence and sales.

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!

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!

Risk Analysis

As I have posted on the Dirigo Quality Meats FaceBook page, I am going to start offering Risk Analysis and HACCP training. As I go about the process of writing this one day course, I am learning a great deal.

1. I probably should have stuck math in college out through linear algebra
   
2. There is practically no one bridging the gap between rigorous mathematical approach to risk analysis and a more bottom up organic approach that is common in food safety discussions.
   
3. The preferred method of teaching about risk analysis starts with a definition.  I was taught in high school English class this was a pretty weak way to start an essay.  I think the same is true of a Power Point deck.
   
4. I am trying to come up with some interesting risk analysis activities and it is HARD.

Developing a HACCP

As America's food system becomes more professionalized and distribution channels widen, small producers and plants have an opportunity to move into new markets.  Consumers are looking for safe, wholesome food, and entrepreneurs are stepping up to provide new products, or put an new twist on established products.

Food however, exists in a regulatory framework.  If you want to make money selling food, someone is going to regulate you.  And whomever that someone is, you are going to have to satisfy them that your food safety plan is adequate to the task of keeping your product safe and wholesome.

Enter HACCP.  Back in the dawn of the food safety movement as it currently exists, some smart folks figured out that testing final product for pathogens was a really expensive, and not terribly effective way of keeping food safe.  So, they came up with a scheme called HACCP.  Hazard Analysis for Critical Control Points.  HACCP plans were first implemented in a regulated way at the FDA with seafood and juice.  Then the USDA adopted HACCP planning for its plants, and no one has ever looked back.

But HACCP is more than just a process diagram.  It is a way of thinking and planning on how to keep your product safe starting before it even comes to your loading dock.  HACCP allows your food safety team to manage your production process to keep the plant and people healthy.  And therein lies one of the keys to HACCP, and to food safety in general: teamwork.  From top to bottom in the company, people must be on board with creating safe food.  The executives must understand how safe food contributes to the bottom line (how expensive would a recall be??) and the line workers must know why the SOPs are there, why and how to follow them.  Food safety isn't just a checkoff list (though, those help a ton).  It is a thought process and corporate culture.

If you are interested in a piece on how to write a HACCP plan, drop me a line at michele<at>dirigoqualitymeats<dot>com.

So Just What Do We DO Here?

As a public health veterinarian and former Army officer, I was responsible for the food safety program in my area for suppliers to the Department of Defense.  Working closely with the managers of the on base grocery stores (the PX system), food manufacturers that supply the DoD, and soldiers under my command, I ensured safe wholesome food was available to those who relied on the DoD system.

Ensuring a safe and wholesome food program requires excellent communication skills, a deep understanding of regulations, and training everyone to create a culture of food safety.  As an independent contractor in food safety, I work with my clients to design systems and processes that will result in safe food.  Understanding HACCP and the method to arrive at the process flow is only one part of that.  Prerequisite programs are needed to ensure that all workers know and understand the safety system that they are implementing.  As GFSI standards are becoming more important, I work with clients to select a 3^rd party auditing system and work to implement it.  As the FSMA comes into fruition, I work with clients to understand the changes and work with them.  My work has brought me in direct contact with government agencies responsible for licensing and auditing.  I understand government regulations and how to work with the Health Department and the Agriculture Department. I immensely enjoy the opportunity to train.  I have worked with the Maine Beef Quality Assurance Program to train beef producers on food borne illness from beef as well as zoonotic diseases.  My training as a veterinarian has given me expertise and insight into all aspects of the food chain.