Meat + Poultry - December 2004 - 49

R.T.E. and ground beef

The new rules

Every company producing R.T.E. products is required to test food contact
surfaces for Listeria according to U.S. Dept. of Agriculture regulations issued
in October 2003. A comprehensive microbiological monitoring program should
go beyond the regulatory requirements. Environmental samples should be taken
to monitor for Listeria in drains, refrigeration units, and other non-food contact
surfaces. Samples for total aerobic plate count should be taken to measure the
cleanliness of the surface. Sampling should be conducted weekly to verify the effectiveness of the sanitation process and should be increased during periods of
construction activity.
Post lethality exposed environments must also be evaluated. Precautions need
to be taken when entering R.T.E. areas, like sanitizing hands and footwear while
wearing designated outer clothing for R.T.E. areas. Traffic flows need to be analyzed to prevent potential cross contamination between raw and cooked products.
This flow analysis should include potential contamination from product, people
or equipment. Maintenance employees and tools are often a potential source of
contamination between raw and cooked areas.
For companies processing ground beef, supplier qualification and slaughter
interventions are critical. Grinding companies should require "Certificates of
Analysis" on each load or on a frequent basis to verify control and antimicrobial interventions for E. coli O157:H7 are effective. Verification testing should
be completed on a regular schedule with the tested lot placed on hold until results are obtained.

Directive 8080.1 Revision 4 issued this past May
by F.S.I.S. and titled "Recall of meat and poultry
products" reflects the recent reorganization
structure at F.S.I.S. and provides updated
instructions regarding recall procedures. The
Directive contains four primary parts:
* The directive itself that includes
information on terminology, need for a
recall, classification, public notification,
effectiveness checks and closure.
* Attachment 1 includes Product Recall
Guidelines for Firms, and model press
releases.
* Attachment 2 details Factors that
are considered by the FSIS Recall
Committee
* Attachment 3 provides details on
Effectiveness Checks
All companies should be familiar with these
revised guidelines and follow them carefully in the
event of a recall.

Improper labeling
Lack of control in product formulation, work in process identification, rework procedures or finished product labeling can result in a recall due to improper labeling of allergenic ingredients. A number of top meat and poultry
companies have had recalls for this reason, indicating a lack of adequate
control throughout the industry. Allergens must be controlled with proper labeling, separation of allergenic and non-allergenic ingredients, scheduling
and wash downs, if needed.
Product formulations that include allergenic ingredients need to be identified
and managed in a specific manner to ensure proper labeling of finished products.
It is critical to ensure all work in process is labeled properly. Proper rework procedures must also allow product containing allergenic ingredients to be reworked
only into the same or similar formulations to prevent crossover of allergenic ingredients with non-allergenic products.
Even product components such as a sauce packet or dessert in a meal kit
must be identified with all ingredients to prevent recalls. There is a need for greater control of product label verification at the time of packaging to ensure all ingredients have been identified and all components are accurate when compared to
the product label.
Foreign material is always a recall threat. As Table 1 indicates, foreign material contamination was the cause of eight recalls in 2004, which involved a total
of nearly 335,000 pounds. This area is a growing concern when considering the
potential for intentional sabotage from a disgruntled employee or food security
threat. Visual inspection is an effective control when employees are trained to
look for foreign material as the product is handled.
Many companies effectively use metal detection or x-ray inspection. All firms
should have a preventive maintenance program that routinely inspects for loose
nuts or bolts on equipment. Policies should be in place to prevent loose metal in
production areas.
Last but not least, critical control points must be verified to minimize risk of

DECEMBER 2004

www.MEATPOULTRY.com

recalls. While most recalls are not due to HACCP failures, the risk of non-compliance with critical limits and
regulatory requirements must be minimized. Table 1
demonstrates there have been three recalls due to undercooked product.
Companies have had HACCP records that appeared to be in compliance with critical limits, only to
later discover under-processed product in the marketplace as a result of a cold spot in a batch smokehouse
or in a continuous cook system where monitoring was
not frequent enough to detect the undercooked product. Some companies with continuous cook systems
have had problems with overlapping pieces on a conveyor belt that resulted in undetected undercooked
product on occasion.
The fourth lesson learned is to work closely with
U.S.D.A. in a cooperative manner. A recall situation
will result in a review from a compliance officer and/
or enforcement investigation and Analysis Officer. The
company will need to be adequately prepared to work
with the on-site investigators and the Emergency Response Recall Committee in Washington.
Questions will have to be quickly answered to
determine the classification of the recall, amount

MEAT&POULTRY

http://www.MEATPOULTRY.com

Meat + Poultry - December 2004

Table of Contents for the Digital Edition of Meat + Poultry - December 2004