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USDA’s new take on the daily grind

Opinion

The new rule-79 FR 42464 will be in full effect starting on June 21 2016. This new rule will alter the way both inspected (official) and exempt facilities grinding beef control the beef grinding process. Overall, the new requirements will impact an estimated 71,000 companies employing about 100,000 persons.

2ndbeefgrinder_406x250Retail-exempt facilities regularly mix cuts of beef from various sources to make ground beef products. This FSIS rule will require such facilities to maintain clear records identifying the source, supplier, and names of all materials used in the preparation of raw ground beef products. All pre-operation, mid and post sanitation work will also be recorded on a lot-by-lot basis.

The Agency is seeking to broaden its regulation of retail-exempt facilities, which have traditionally come under the purview of state and local regulatory authorities. This rule will very well set a precedent for FSIS to expand its regulatory activities with regard to retail and grocery facilities that are not currently subject to ongoing federal inspection.

HACCP in a grinding operation

The Food Marketing Institute (FMI) advises that facilities should also ensure their employees are qualified to perform their assigned duties and are properly trained in the principles of food hygiene, food safety, and employee health and hygiene. One method of achieving this would be training and certification of at least one management level person in charge of the grinding operation in Hazard Analysis Critical Control Point (HACCP) principles, specific to the beef grinding process.

HACCP is a process control system designed to prevent, eliminate or reduce food safety hazards to an acceptable level. The establishment in its hazard analysis must consider biological, physical, and chemical food safety hazards. Raw product, like ground beef, has no kill step in a grinding operation for reducing to an acceptable level microbial food safety hazards, such as E. coli O157:H7 or Salmonella.

GRINDINGLOG_406X250Therefore, grinders must focus on what can realistically be applied during the process to minimize the potential for growth of pathogens, if present on the raw material. These steps often involve time and temperature controls (i.e., raw material and finished product temperature during processing, cold storage or other steps) to minimize the potential for growth of harmful bacteria, and good sanitation pre-requisite programs to minimize environmental pathogens.

While the control of microbial multiplication and surface sanitation do not truly meet the definition of a CCP, because one microorganism in the raw material may be too many, they are a best practice that can and must be applied in a grinding operation.

Therefore, because this rule represents a new record-keeping requirement, particularly at the retail and grocery level, such businesses should carefully review the details of this proposal.

Consumer demand for transparency

Decision makers might also want to invest in technology that captures on-farm systems in electronic form at the point in the supply chain where the hardware, software and human resources exist to efficiently effect that transition, and provide a high level of transparency.

There is not currently a commonly accepted definition for the word “local,” in regards the origin of food, so when something is labeled and marketed as “local,” one can’t be sure what that means. It could mean a certain number of miles from a given store or could indicate it originated elsewhere in the state or even in a multi-state region. What consumers want is proof it is not from another country or a processing facility thousands of miles away.

Unless the consumer purchased ground beef from the farmer down the road- which is a rarity this day and age , it can be hard for them to tell exactly where it came from, even if the label on the package says “local”. One solution for consumers is a quick barcode scan enabled by a smart-phone that could disclose  the exact location  where the product came from.

Just tracking a single animal from birth to harvest can be a challenge,  with up to 500 packages of meat can be produced by a single beef carcass, with a large percentage usually becoming  ground beef.   So trying to track that mixed volume has a whole different set of issues including trim from anywhere, and the sanitation practices of the grinding machine and it’s operators.

The consumer today is interested in not only locally sourced beef, but also the potential for full traceability of beef from the farm to the plate or put it another way, consumers want to be able to trace individual animals from the farm to the hamburger in the bun on their plate. By translating RFID or metal/plastic ear tags to a barcode, the trim pieces or packages of beef after grinding can be labeled with that code, tracing it back to the firm or machine, and finally to where the meat came from, even in a retail setting.

 

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(Environ Health Associates, Inc. and its partner ScoringAg are developing a streamlined computer based system to effectively track both the supply chain and food safety requirements associated with the new rules, and a HACCP Alliance accredited program of instruction specifically for the small to medium-sized exempt grinding facilities.  Contact rcosta1@cfl.rr.com for further information)

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