Food Safety Consortium

With the implementation of Pathogen Reduction and HACCP Rules by USDA in 1996, the meat and poultry industries have undergone the most pivotal changes experienced since the Meat Inspection Act of 1906. Hazard Analysis Critical Control Point (HACCP) is supported as a preventative, systematic approach to food safety assurance that can be applied to all segments of the meat industry including small and very small meat and poultry operations. However, many small and very small meat and poultry processors needed science based information and education to properly implement and manage their HACCP programs. A current challenge to these operations is providing USDA with in plant validation studies for practices used in beef slaughter and processing FSIS recognized early on in the HACCP implementation process that both small and very small plants would need guidance and assistance that the large plants implementing in 1998 did not require. In order to meet these needs a number of outreach programs have been implemented. These programs were tailored to meet the specific needs of both small and very small plants. In 1999,2373 federally inspected and 170 state inspected small plants implemented HACCP. In 2000 over 3400 federally inspected and 2300 state inspected plants implemented. FSIS and University Extension Specialists have worked with very small and small meat and poultry processors to provide training and research information for the implementation and management ofHACCP. As a result of this assistance, most operations have successfully implemented and managed HACCP plans since the required implementation dates in January 2000 and January 2001. However very small plants that slaughter and process beef are struggling with new requirements as a result of the E.coli 0157:H7 notice. Specifically, very small meat processors have implemented controls and antimicrobial interventions for beef slaughter and processing that have been validated in research and university laboratories. Published peer reviewed journal articles have been used as supporting documentation for the control or antimicrobial intervention. In addition to the published supporting documentation, very small plants are being asked to conduct "in plant" validation studies for further supporting documentation. The challenge is that very small plants do not have the science based knowledge or the financial resources to conduct these validation studies. The regulatory concern is that the controlled conditions of a laboratory study may not translate into similar results when the same procedure is conducted during operations in a very small or small meat processing facility. It is also true that the scientific community does not fully understand the possible variation that could occur in application of controls and antimicrobial interventions during the beef slaughter and processing and the possible impact on food safety and HACCP systems in small and very small processing plants. If minimal variation can be demonstrated from plant to plant and if the improvement of HACCP and food safety can be achieved across a variety of small meat processing operations, the use of standard interventions and controls could be very beneficial for all small and very small operations. In plant validation studies can be costly. Our experience is that validation of interventions and controls for a beef slaughter process can run from $7,000 to $15,000 per study to cover the costs of laboratory tests, worker travel and sample collection. If 3,500 very small meat processors (only a portion ofthe 3400 federally inspected and 2300 state inspected plants) conduct in plant validation studies the total cost to these small businesses could exceed five million dollars. This major cost to small business could be avoided by the development of standard control measures that are applicable to small business, the validation of antimicrobial interventions in small plant, the evaluation of the application of these control measures and the publication of pier reviewed articles and/or regulatory performance standards for beef processing in very small meat operations. The intent of this project is to utilize the expertise of a consortium of four universities that have established working relationships with small and very small meat processing operations to evaluate the use of standard beef slaughter interventions and controls, to evaluate the differences or similarities of application of a standard control across a variety of very small meat processing plants in the United States, and to establish a reference document and/or performance standard that can be utilized by small and very small processors. The first year of the project would address beef slaughter and processing and other processes could be addressed in following years. Goal: To determine if standard procedures for beef slaughter controls and antimicrobial interventions can be established to achieve food safety and avoid the added cost of numerous "in plant" studies by very small and small meat processors.