Meat + Poultry - December 2007 - 75

PROCESSORS ASK

Q: FSIS uses the term "robust testing" in many of its documents. What
exactly does that mean?
A: FSIS defined what they considered to be robust testing recently in
the E. coli O157:H7 checklist, and stated that a robust testing program must
include the following:
* For samples capable of excision testing, such as trim or subprimals, the
N-60 method should be followed.
The samples should represent 375
grams or more of thinly-sliced exterior surface tissue (60 slices derived
from trim in up to five combo bins/
boxes/other units - 12 very thin slices of exterior surface materials from
each combo bin//box/other unit):
each slice should be approximately
1/8" thick, 4.0 inches in length, and
2.0 inches wide. The composite sample should weigh at least 2 pounds
and consist of at least 60 slices places together in an aseptic package); a
375-gram sample is enriched and analyzed using a method at least as sensitive and specific as the FSIS method.
(For additional information on N-60
training, see FSIS Notice 18-07 and
its associated training).
* For samples not capable of excision
testing (e.g., comminuted product),
a composite sample is collected representing all units from a specified
time period (10-30 minutes for continuous testing; one sample from the
entire production lot; grab samples
from each combo bin/box/other
unit); at least a 325-gram sample is
enriched and analyzed using a method at least as sensitive and specific
as the FSIS method.
Q: We are increasing our microbiological testing program and are
considering building our own lab to
conduct testing in-house. Will FSIS
accept our results?
A: Yes, FSIS will recognize your
in-house results for your own testing
programs, as long as the tests you run
are the same or equivalent to the tests
that are run in FSIS labs. Your best bet
is to have an experienced microbiologist
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on staff if you are considering this.
FSIS has a reference guide, The
Microbiological Guidebook, which is
your best point of reference from FSIS
for testing protocols and procedures:
http://www.fsis.usda.gov/Science/
Microbiological_ Lab_Guidebook/
index.asp
Q: As a further processor of nonintact beef items, what options are
available to me to further enhance
the safety of my products?

"Technologies have
been developed in
recent years to provide
processors of nonintact items (ground
beef, tenderized
steaks, injected
products) options for
lowering the risk for
E. coli O157:H7."
A: Technologies have been developed in recent years to provide processors of non-intact items (ground beef,
tenderized steaks, injected products)
options for lowering the risk for E.
coli O157:H7. Before these technologies were developed, the only option
processors had was to rely on the interventions applied at slaughter establishments. These technologies can be
applied to trimmings or to the surface
of subprimals prior to tenderization of
enhancement.
Examples of technologies that can
be used without labeling requirements
include:
* Acidified sodium chlorite
* Lactic acid
* Peroxyacetic acid and hydrogen
peroxide
* Ultraviolet light and a Photohydroionization Cell
FSIS maintains a list of safe and
suitable ingredients on its Web site
www.MEATPOULTRY.com

along with the methods for use and
any labeling requirements at: http://
www.fsis.usda.gov/OPPDE/rdad/FSIS
Directives/7120.1Amend13.pdf
Q: Our beef raw materials (boneless trim, primals and sub primals)
are all required to have a letter of
guarantee indicating that the supplier uses acceptable interventions
to control E. coli O157:H7. Since we
have this letter of guarantee for all
beef products, does this apply to the
house trim that we produce in the
process of cutting steaks?
A: The letters from suppliers do
usually cover all products, however,
the difference is that with the trim
that comes in, there is usually a microbiological testing program associated
with it as well. Currently, the subprimals that you receive, particularly the
vacuum-packaged subprimals, have
most likely not been subject to any
kind of testing program, so FSIS considers your bench trim to more likely
be contaminated than the trim you
buy in that's been pre-tested.
Q: Is there a minimum requirement for the amount of lean that
must be present to call product
"trimmings"?
A: According to FSIS notice 15-07,
meat trimmings which may be labeled
as "boneless beef" must have visible lean
tissue, that is, contain at least 12 percent
lean tissue. Head meat and cheek meat
are considered "meat"; however, they
are restricted in certain products and,
therefore, must be declared as such as
a commodity.
They cannot be in a product that is
declared only as boneless beef. Trimmings containing less than 12 percent visible lean tissue are identified
as "(species) fat with visible lean" or
"(species) fat."
Send questions for "Processors Ask" to
www.meatpoultry.com and your question may appear in the next column.
We would like to hear from you - to comment on
this story or to request reprints, contact us by
e-mail at: meatpoultry@sosland.com.
http://http:// http://www.fsis.usda.gov/OPPDE/rdad/FSIS http://www.fsis.usda.gov/Science/ http://www.meatpoultry.com http://www.MEATPOULTRY.com
Meat + Poultry - December 2007

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