HACCP DECISION-MAKING DOCUMENTATION

For
BEEF SLAUGHTER
Rosenthal Meat Science and Technology Center
Establishment Number 1
April 7, 2003
The following definitions from USDAs Pathogen Reduction/HACCP regulation were reviewed
before the team started reviewing the hazard analysis and documenting the thought process for each
response.
Food safety hazard: Any biological, chemical, or physical property that may cause a food to
be unsafe for human consumption (USDA, 417.1).
Hazard analysis Reasonably likely to occur A food safety hazard that is reasonably
likely to occur is one for which a prudent establishment would establish controls because it
historically has occurred, or because there is a reasonable possibility that it will occur in the
particular type of product being processed, in the absence of those controls (USDA, 417.2(a)(1)).
HAZARD ANALYSIS:
The following summarizes the discussions and thought process that impacted the decisions for each
step of the flow chart for the three food safety hazard categories biological, chemical, and
physical.
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Cattle Receiving and Holding:
Process Step Overview:
We obtain cattle from various sources to use at our university. For most teaching and extension
activities, cattle sources include those raised and fed at Texas A&M University, purchased from
commercial feedyards, and obtained from various livestock shows across the state. For research
animals, the source will vary depending on the project and may include animals that are prohibited
from entering the food chain and processed only for data collection. On occasion, we may receive
animals for custom slaughter.
We transport some of the livestock to our facility and we receive some of the livestock from
commercial transporters. Although it is not directly related to food safety, procedures are in place
to ensure humane handling of livestock during unloading and during holding as required by 9 CFR
313. [Livestock Handling Standard Operating Procedures (SOPs), AUP 2002-227: Animal
Science 307 (Meat Science), and other AUPs, as required]
Hazard Analysis Logic:
Chemical: Antibiotic Residue Cattle that are identified by the inspector as high risk are tested
for antibiotic residue using a STOP test. To the best of the teams knowledge, there have
been no positive antibiotic residues from Jan. 1, 1998 to December 15, 2002, as a result of
high risk testing. High risk cattle, such as show steers, are identified in the pens, and the
inspector samples liver and kidney for analysis. Any violation will be noted on an NR so
the team will reassess this issue if future violations are noted. Based on this information the
team does not think that antibiotic residue is a food safety hazard that is reasonably likely to
occur in this slaughter process.
Illegal Drug Residue On Feb. 4, 2002, a steer from the Southwestern Livestock Show in
Fort Worth, Texas, was slaughtered, passed postmortem inspection and a STOP test, and the
carcass was subsequently released for commerce. We were contacted by the livestock show
to inform us that a urine sample from the steer tested positive for Phenylbutazone, a
compound not approved for use in cattle. At the time of slaughter, show officials had not
informed us of the pending drug tests. Corrective actions for the unforeseen hazard were
conducted on Feb. 15, 2002. Animal and product release forms have been developed and all
animals from livestock shows must be released prior to the carcass and variety meats being
used. At this time, we conclude that illegal drug residue is not a reasonably likely to occur
food safety hazard for our establishment.
Animals used for research involving non-approved chemical substances will be identified
and segregated to ensure that products from them do not enter the food chain.
We considered lead contamination as a potential chemical food safety hazard. According to
Dr. James W. Barnett, Jr., Ph.D., Diplomate, American Board of Toxicology, If there was
ingestion of one or a few lead shot or as subdivided by grinding, the estimated increase in
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blood lead levels (approximately 0.12 0.36 g/dl/pellet) are well below levels that pose
health hazards to children or adults. [See supporting documentation.]
Physical: We acknowledge that some cattle may occasionally have buckshot, bullets, needles,
etc. However, these cannot be identified at the time of receiving and may not be found as
the product moves throughout the process. There have been no reported incidences of these
physical hazards from Jan. 1, 1998 to Oct. 15, 2002. We also considered that size and shape
of metal will impact whether or not an object is a food safety hazard according to Olsen
(1998), classifies hard or sharp objects over 7mm in length as potentially hazardous
while objects that measure between 2 and 7 mm are normally considered a nonhazardous
defect. [See supporting documentation.] Therefore, physical hazards are not identified as a
reasonably likely to occur food safety hazards for this process step.
We are addressing lead shot as a potential chemical hazard.
Biological: Pathogens. It is an accepted fact that raw meat is a potential source of pathogens
(i.e., Salmonella and E. coli O157:H7). The USDA/FSIS Nationwide Beef Microbiological
Baseline Data Collection Program: Steers and Heifers October 1992 September 1993
documents previous incidence levels. Also, based on the Smith and Elder data provided by
USDAs FSIS these microorganisms are reasonably likely to occur. [See supporting
documentation.] Therefore, we acknowledge that steps must be taken to try to prevent,
eliminate or reduce to an acceptable level any pathogen contamination. At this step, there
are no known interventions that can be used to eliminate these pathogens. We have
identified subsequent steps of organic acid spraying to reduce pathogen contamination and
chilling to reduce pathogen growth.
The following discussion outlines the use of the CCP Decision Tree for this identified
hazard:
1. Do control measure(s) exist for the identified hazard (pathogens)? YES
2. Does this step (receiving and holding) eliminate or reduce the likely occurrence of a
hazard (pathogens) to an acceptable level? NO
3. Could contamination with the identified hazard(s) (pathogens) occur in excess of
acceptable level(s) or could it increase to an unacceptable level? YES
4. Will a subsequent step eliminate the identified hazard(s) or reduce its likely occurrence
to an acceptable level? YES, organic acid has been scientifically shown to reduce the
likely occurrence of pathogens, and proper chilling will reduce the potential for pathogen
growth.
This step is not a CCP in our process.
###
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Stunning:
Process Step Overview:
Proper stunning is used to comply with 9 CFR 313. Animals are driven into a knocking box, one
head at a time, to be stunned. Stunning is accomplished using a non-penetrating mechanical stunner
(Cash Knocker). After stunning, the animal is released from the knocking box into the dry landing
area for shackling and hoisting before the bleeding process.
Hazard Analysis Logic:
Physical: Stunning is accomplished using a non-penetrating mechanical stunner; however, there
are some bone fragments that may enter the brain cavity. Brains are not kept for
consumption. The brain cavity is flushed with water to remove the brains and any bone
fragments that may occur due to fracturing the skull during stunning. We determined there
are no physical food safety hazards associated with stunning cattle.
Chemical and Biological: The team could not think of any chemical or biological hazards that
would be associated with this step of the process.
###
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Bleeding:
Process Step Overview:
We bleed the animal by first making a longitudinal opening through the hide in the center of the
underside of the neck from the sternum to the throatlatch, and after knife sanitizing, insert the knife
immediately below the point of the sternum and sever the carotid artery and jugular vein. No edible
blood is collected.
Hazard Analysis Logic:
Chemical and Physical: None identified at this time. The act of sticking an animal for bleeding
does not introduce chemical or physical food safety hazards into the system. The fact that
the knife has been sanitized is addressed in the Sanitation Standard Operating Procedures.
Therefore, no chemical or physical food safety hazards were identified for this step.
Biological: Pathogens. We know that the hide is a potential reservoir for pathogens. The act of
sticking is the first step that involves opening the hide, so pathogens from the outside of the
hide may contaminate the carcass. Therefore, the team acknowledges that subsequent steps
must be taken to try to prevent, eliminate or reduce pathogens to an acceptable level. We
have identified subsequent steps of organic acid spraying to reduce pathogen contamination
and chilling to reduce pathogen growth.
The following discussion outlines the use of the CCP Decision Tree for this identified
hazard:
1. Do control measure(s) exist for the identified hazard (pathogens)? YES
2. Does this step (bleeding) eliminate or reduce the likely occurrence of a hazard
(pathogens) to an acceptable level? NO
3. Could contamination with the identified hazard(s) (pathogens) occur in excess of
acceptable level(s) or could it increase to an unacceptable level? YES
4. Will a subsequent step eliminate the identified hazard(s) or reduce its likely occurrence
to an acceptable level? YES, organic acid has been scientifically shown to reduce the
likely occurrence of pathogens, and proper chilling will reduce the potential for pathogen
growth.
This is not a CCP in our process.
###
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Foreshanking and Heading:
Process Step Overview:
Steps in this process include removing the forefeet between the metacarpals and carpals (must be
accomplished before head removal), remove horns (if present) and ears across the top of the poll,
splitting the hide down the middle of the face, and continuing to completely skin the head.
The weasand (esophagus) is separated from the trachea and lungs by finding it near the knife
opening in the throat area and by using the weasand rod to detach it from a point on the throat to the
base of the reticulum. This frees the esophagus from its attachments to the trachea and lungs so that
during evisceration it may be pulled through the chest without tearing. We tie the weasand with
string to prevent spillage of rumen contents. The esophagus is cut between the tied area and the
head before head removal.
The head is removed by cutting through the muscles behind the poll and through the muscles at the
underside of the throatlatch before making the final cut through the occipito-atlantal space. The
head is carried to the head wash cabinet and further activities will be addressed during head
processing.
Hazard Analysis Logic:
Chemical: The act of head removal and foreshanking is not conducive to introducing chemical
hazards.
Physical: The weasand is tied with string to prevent spillage during evisceration. The tying
device is removed with the viscera, so it is not likely to contaminate the product. We could
not identify any physical food safety hazards that would be introduced during the
foreshanking and heading process.
Biological: Pathogens. We acknowledge that the head removal process and foreshanking may
introduce pathogens to the exposed areas of the head and carcass, which is virtually sterile
before the hide is opened during this process step. As above, the team acknowledges that
subsequent steps must be taken to try to prevent, eliminate or reduce pathogens to an
acceptable level. We have identified subsequent steps of organic acid spraying to reduce
pathogen contamination and chilling to reduce pathogen growth.
The following discussion outlines the use of the CCP Decision Tree for this identified
hazard:
1. Do control measure(s) exist for the identified hazard (pathogens)? YES
2. Does this step (foreshanking and heading) eliminate or reduce the likely occurrence of a
hazard (pathogens) to an acceptable level? NO
3. Could contamination with the identified hazard(s) (pathogens) occur in excess of
acceptable level(s) or could it increase to an unacceptable level? YES
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4. Will a subsequent step eliminate the identified hazard(s) or reduce its likely occurrence
to an acceptable level? YES, organic acid has been scientifically shown to reduce the
likely occurrence of pathogens, and proper chilling will reduce the potential for pathogen
growth.
This step is not a CCP in our process.
###
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Hindshanking and Rimming:
Process Step Overview:
We loosen the bung by making a circular cut around the anus (including vulva in females) and
pulling outward cutting its attachments to the pelvic cavity. A plastic bag is placed around the bung
and is secured with a tying device. The bagged bung is pushed back into the body cavity.
We perform initial hide opening by making a cut immediately above the dew claws on the free hind
leg up to the Achilles tendon and continuing to the bung area. We sanitize the knife after initial
hide opening and before proceeding with hide removal. Additional hide removal steps include
initial opening of the midline and skinning to remove the hide in the belly area, loosening of hide
from foreshanks and brisket area, and skinning to remove the hide over the shoulders in preparation
for the hide puller. Wet udders are removed before proceeding to the hide puller.
We remove hindshanks between the tarsals and metatarsals using a mechanical device that is
sanitized after each use.
Hazard Analysis Logic:
Chemical: The act of hindshanking and rimming does not introduce chemical hazards.
Physical: Bung is covered with a plastic bag to prevent leakage during evisceration. The bag
and tying device are removed with the viscera, so it is not likely to contaminate the product.
Biological: Pathogens. We acknowledge that the hindshanking and rimming may introduce
pathogens to the carcass, which is virtually sterile before the hide is opened. The team
acknowledges that subsequent steps must be taken to try to prevent, eliminate or reduce
pathogens to an acceptable level. We have identified subsequent steps of organic acid
spraying to reduce pathogen contamination and chilling to reduce pathogen growth.
The following discussion outlines the use of the CCP Decision Tree for this identified
hazard:
1. Do control measure(s) exist for the identified hazard (pathogens)? YES
2. Does this step (hindshanking and rimming) eliminate or reduce the likely occurrence of a
hazard (pathogens) to an acceptable level? NO
3. Could contamination with the identified hazard(s) (pathogens) occur in excess of
acceptable level(s) or could it increase to an unacceptable level? YES
4. Will a subsequent step eliminate the identified hazard(s) or reduce its likely occurrence
to an acceptable level? YES, organic acid has been scientifically shown to reduce the
likely occurrence of pathogens, and proper chilling will reduce the potential for pathogen
growth.
This step is not a CCP in our process.
###
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Dehiding with Hide Puller:
Process Step Overview:
We use a hide puller that pulls the hide upward and away at a 45 angle. Workers assist in the hide
pulling process by using air dehiders, especially in the side, shoulder, and back regions. The
foreshanks are secured with chains that are sanitized between animals to prevent pulling the animal
off of the rail during hide pulling. The hide is removed from the slaughter floor and placed in a
refrigerated hide storage room adjacent to the slaughter floor.
Hazard Analysis Logic:
Chemical and Physical: The act of hide removal is not conducive to introducing chemical or
physical hazards.
Biological: Pathogens. We acknowledge that the hide removal process may introduce
pathogens to the carcass that is virtually sterile before the hide is removed. The carcass is
now exposed and may become contaminated with pathogens. As above, the team
acknowledges that subsequent steps must be taken to try to prevent, eliminate or reduce
pathogens to an acceptable level. We have identified subsequent steps of organic acid
spraying to reduce pathogen contamination and chilling to reduce pathogen growth. We
note that air-dehiders are used as processing tools during the hide removal step. These aid
with the hide removal and the proper sanitation of these tools are addressed in the Sanitation
Standard Operating Procedure.
The following discussion outlines the use of the CCP Decision Tree for this identified
hazard:
1. Do control measure(s) exist for the identified hazard (pathogens)? YES
2. Does this step (dehiding and hide puller) eliminate or reduce the likely occurrence of a
hazard (pathogens) to an acceptable level? NO
3. Could contamination with the identified hazard(s) (pathogens) occur in excess of
acceptable level(s) or could it increase to an unacceptable level? YES
4. Will a subsequent step eliminate the identified hazard(s) or reduce its likely occurrence
to an acceptable level? YES, organic acid has been scientifically shown to reduce the
likely occurrence of pathogens, and proper chilling will reduce the potential for pathogen
growth.
This step is not a CCP in our process.
###
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Evisceration:
Process Step Overview:
We remove the oxtail, open the sternum with a brisket saw (sanitized between animals), make a
knife cut from a point in the abdominal region, near the aitch bone, down to the point of the
sternum, and remove the viscera and pluck. The inedible viscera and pluck are placed in a paunch
truck and the edible items are placed on a stainless steel table for preparation for inspection.
The inedible viscera is removed from the slaughter floor and placed in plastic barrels in a
refrigerated storage room adjacent to the slaughter floor. Edible products are either boxed or hung
on trees before being chilled.
Hazard Analysis Logic:
Chemical: The written Sanitation Standard Operating Procedures address the proper procedures
for cleaning and sanitizing equipment used during evisceration. We could not identify any
chemical food safety hazards for this step in the process.
Physical: The plastic bag and tying devices used to prevent spillage from the weasand and
leaking from the bung are removed with the viscera. The viscera are not kept for further
processing at this facility and are rendered inedible. Therefore, we could not identify any
physical food safety hazards as reasonably likely to occur for this step of the process.
Biological: Pathogens. We acknowledge that the evisceration process may introduce pathogens
to the carcass, which is virtually sterile. The exposed carcass may become contaminated
with pathogens from the gastrointestinal tract during evisceration. As above, we
acknowledge that subsequent steps must be taken to try to prevent, eliminate or reduce
pathogens to an acceptable level. We have identified subsequent steps of organic acid
spraying to reduce pathogen contamination and chilling to reduce pathogen growth.
The following discussion outlines the use of the CCP Decision Tree for this identified
hazard:
1. Do control measure(s) exist for the identified hazard (pathogens)? YES
2. Does this step (evisceration) eliminate or reduce the likely occurrence of a hazard
(pathogens) to an acceptable level? NO
3. Could contamination with the identified hazard(s) (pathogens) occur in excess of
acceptable level(s) or could it increase to an unacceptable level? YES
4. Will a subsequent step eliminate the identified hazard(s) or reduce its likely occurrence
to an acceptable level? YES, organic acid has been scientifically shown to reduce the
likely occurrence of pathogens, and proper chilling will reduce the potential for pathogen
growth.
This step is not a CCP in our process.
###
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Electrical Stimulation:
Process Step Overview:
We use a portable electrical stimulation unit that operates by placing a stainless steel probe
(sanitized between carcasses) into the crest area of the carcass to administer the electrical current.
The stimulator uses electrical currents to enhance the conversion of muscle to meat.
The stimulator is operated by authorized personnel only, a safety horn alerts workers that the unit is
about to be operated and has finished its cycle, and the controls must be in the operators hand to
apply current.
Hazard Analysis Logic:
Chemical, Physical and Biological: None identified at this time. Electrical stimulation is used
to enhance the quality of the carcass and does not have an impact on food safety hazards.
The voltage is not high enough to cause breakage of bones. Therefore, it was determined
that electrically stimulating the carcass does not enhance or introduce chemical, physical or
biological hazards to the carcass.
###
Splitting:
Process Step Overview:
Splitting is accomplished using a band saw splitter (sanitized between carcasses) operated from an
elevating platform. The carcass is split into two halves by sawing through the center of the chine
bones and their dorsal spinous processes. Visual contamination, when found, along with blood
clots, fatty or glandular tissue from the throat region, are removed from the carcass. Spinal cord is
removed from each side using a handheld scraper.
Hazard Analysis Logic:
Chemical, Physical and Biological: None identified at this time. Splitting is accomplished by
using a split saw. If a blade breaks on a split saw, it is not likely that contamination of
edible tissue would occur because the blade is usually lodged in the vertebral column.
Therefore, it was determined that splitting does not enhance or introduce any chemical,
physical or biological hazards to the carcass.
###
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Trim Zero Tolerance:
Process Step Overview:
We roll the carcass into the wash bay and all visible feces, milk, and ingesta is trimmed starting
with the foreshank, working up to the round, and then working back down to the foreshank. Once
trimming is complete, the carcass is inspected for effectiveness of trimming.
Hazard Analysis Logic:
Chemical and Physical: None identified at this time. The process of visually inspecting the
carcass for visible feces, milk, and ingesta does not impact chemical or physical food safety
hazards. Therefore, none was identified for this step.
Biological: Visible feces, milk and ingesta. USDAs Food Safety and Inspection Service
requires the trimming of all visible feces, milk and ingesta from the carcass prior to washing
as part of zero tolerance control. According to 62 Federal Register (FR) 63254, November
28, 1997; the plant must address zero tolerance in the HACCP plan. Therefore, this step is
identified as a CCP to control visible feces, milk, and ingesta by knife trimming any visible
contamination. [See supporting documentation.]
###
Final Wash:
Process Step Overview:
We wash the carcass with warm water under high pressure beginning at the hind shank and working
downward, paying special attention to the regions of the hock, crotch, throat, and beneath the
foreshank to remove bone dust and other foreign materials.
Hazard Analysis Logic:
Chemical, Physical, and Biological. None identified at this time. Since the water is potable, we
could not identify any chemical, physical, or biological food safety hazards that would be
associated with this step. Final wash is used to remove bone dust, hair, and other foreign
materials that are not food safety hazards.
###
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Organic Acid Spray:
Process Step Overview:
After the final wash, a lactic acid solution is applied to all exposed areas of the carcass from the
hind shank working downward using a hand-held spraying wand that mixes the lactic acid with
water to achieve the appropriate concentration. Special care is given to ensure that both external
and internal surfaces receive the spray.
Hazard Analysis Logic:
Chemical: The lactic acid used is a food grade substance that was approved by USDAs FSIS
for use on carcasses at a 2.5% maximum level. We have letters of guarantee on file from
our suppliers stating that food grade lactic acid is considered Generally Recognized as
Safe under 21 CFR 184.1061. Therefore, no chemical food safety hazards were identified
as reasonably likely to occur by the act of spraying the carcass with lactic acid.
Physical: The step of mixing and applying lactic acid does not impact physical hazards;
therefore, the team could not think of any physical hazard that were associated with this step
of the process.
Biological: Pathogens. Lactic acid has been shown to be an effective organic acid at reducing
pathogen loads. FSIS Notice 49-94 (12-21-94) states that up to 2.5% of a food grade acid
can be used. Therefore, we consider the use of lactic acid as a CCP for reducing pathogens,
including E. coli O157:H7, on the slaughter floor. Scientific literature is also available to
support the use of lactic acid as a microbial intervention that will reduce E. coli O157:H7
and Salmonella. This intervention has been scientifically validated to reduce levels of E.
coli O157:H7 (inoculated samples were reduced by at least 3 logs) that are higher than
would be anticipated on carcasses during normal processing. [See supporting
documentation.]
The following discussion outlines the use of the CCP Decision Tree for this identified
hazard:
1. Do control measure(s) exist for the identified hazard (pathogens)? YES
2. Does this step (spraying with organic acid) eliminate or reduce the likely occurrence of a
hazard (pathogens) to an acceptable level? YES, spraying the carcass with organic acid
will reduce pathogens.
This step is a CCP in this process to reduce pathogens (i.e., E. coli O157:H7 and
Salmonella).
###
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Chilling:
Process Step Overview:
The carcasses are placed into the hot box to initiate the chilling process. The hot box is designed to
optimize the initial chill because it has high air movement at refrigeration temperatures to help
reduce the surface and internal temperatures of the carcasses. The refrigeration system is a closed
ammonia system and the cooling capacity is capable of chilling the number of carcasses that we
produce on a routine basis.
Hazard Analysis Logic:
Chemical. The refrigeration system operates with ammonia in a closed system; therefore, it was
not considered as a reasonably likely to occur food safety hazard. We know that ammonia
leaks could be a worker safety issue, but any contamination onto the product may cause
some quality defects but would not be a food safety hazard because it will dissipate. In
addition, ammonia is present in raw meat as a byproduct of the conversion of muscle to
meat. We could not think of any other potential chemical hazards that should be considered
as part of the chilling process.
Physical: None identified at this time. The team could not think of any physical food safety
hazards that were associated with the chilling process.
Biological: The process of chilling does not introduce biological hazards. Pathogens that are
present when entering the chilling step cannot be eliminated either. Although microbial
interventions are in place to reduce pathogens on the slaughter floor, the team recognizes
that pathogens may be present on the carcass as it passes from the slaughter floor to the
cooler. Proper chilling of the carcass can help reduce the potential for pathogen growth.
Therefore, the team considers chilling to be a CCP.
The following discussion outlines the use of the CCP Decision Tree for this identified
hazard:
1. Do control measure(s) exist for the identified hazard (pathogens)? YES
2. Does this step (chilling) eliminate or reduce the likely occurrence of a hazard (pathogen
growth) to an acceptable level? YES, proper chilling of the carcass will reduce the
potential for pathogen growth.
This step is a CCP in our process.
###
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Head Processing:
Process Step Overview:
The head is prepared for inspection by trimming and washing the outer surface and by flushing the
head cavity in the head cabinet. The brain is removed by the flushing. This process involves
loosening the tongue and removing the tonsils.
Hazard Analysis Logic:
Physical: Stunning is accomplished using a non-penetrating mechanical stunner; however, there
are some bone fragments that may enter the brain cavity. Brains are not kept for
consumption. The brain cavity is flushed with water to remove the brains and any bone
fragments that may occur due to fracturing the skull during stunning.
Chemical: None identified at this time. The process of trimming and washing the head does not
introduce any chemical hazards.
Biological: Pathogens. It is an accepted fact that raw meat is a potential source of pathogens
(i.e., Salmonella and E. coli O157:H7). The USDA/FSIS Nationwide Beef Microbiological
Baseline Data Collection Program: Steers and Heifers October 1992 September 1993
documents previous incidence levels. Also, based on the Smith and Elder data provided by
USDAs FSIS these microorganisms are reasonably likely to occur. [See supporting
documentation.] Therefore, we acknowledge that steps must be taken to try to prevent,
eliminate or reduce to an acceptable level any pathogen contamination. At this step, there
are no known interventions that can be used to eliminate these pathogens. We have
identified subsequent steps of organic acid spraying to reduce pathogen contamination and
chilling to reduce pathogen growth.
The following discussion outlines the use of the CCP Decision Tree for this identified
hazard:
1. Do control measure(s) exist for the identified hazard (pathogens)? YES
2. Does this step (head processing) eliminate or reduce the likely occurrence of a hazard
(pathogens) to an acceptable level? NO
3. Could contamination with the identified hazard(s) (pathogens) occur in excess of
acceptable level(s) or could it increase to an unacceptable level? YES
4. Will a subsequent step eliminate the identified hazard(s) or reduce its likely occurrence
to an acceptable level? YES, organic acid has been scientifically shown to reduce the
likely occurrence of pathogens, and proper chilling will reduce the potential for pathogen
growth.
This step is not a CCP in our process.
###
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Trim Zero Tolerance -- Heads:
Process Step Overview:
We place the head in the head cabinet and all visible feces, milk, and ingesta are trimmed. Once
trimming is complete, the head is inspected for effectiveness of trimming.
Hazard Analysis Logic:
Chemical and Physical: None identified at this time. The process of visually inspecting the
head for visible feces, milk, and ingesta does not impact chemical or physical food safety
hazards. Therefore, none were identified for this step.
Biological: Visible feces, milk, and ingesta. USDAs Food Safety and Inspection Service
requires the trimming of all visible feces, milk, and ingesta from the carcass prior to washing
as part of zero tolerance control. According to 62 Federal Register (FR) 63254, November
28, 1997, the plant must address zero tolerance in the HACCP plan. Therefore, this step is
identified as a CCP to control visible feces, milk, and ingesta by knife trimming any visible
contamination. [See supporting documentation.]
###
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Organic Acid Spray -- Heads:
Process Step Overview:
A lactic acid solution is mixed and applied to all exposed areas of the head using a hand-held
spraying wand that mixes the lactic acid with water to achieve the appropriate concentration.
Special care is given to ensure that both external and internal surfaces receive the spray.
Hazard Analysis Logic:
Chemical: The lactic acid used is a food grade substance that is approved for use on heads at a
2.5 % maximum level. Therefore, no chemical food safety hazards were identified as
reasonably likely to occur by the act of spraying the carcass with the lactic acid.
Physical: The step of applying lactic acid does not impact physical hazards; therefore, the team
could not think of any physical hazard that was associated with this step of the process.
Biological: Pathogens. Lactic acid has been shown to be an effective organic acid at reducing
pathogen loads. FSIS Notice 49-94 (12-21-94) states that up to 2.5% of a food grade acid
can be used. Therefore, we consider the use of lactic acid as a CCP for reducing pathogens,
including E. coli O157:H7, on the slaughter floor. Scientific literature is also available to
support the use of lactic acid as a microbial intervention that will reduce E. coli O157:H7
and Salmonella. This intervention has been scientifically validated to reduce levels of E.
coli O157:H7 (inoculated samples were reduced by at least 3 logs) that are higher than
would be anticipated on heads during normal processing. [See supporting documentation.]
The following discussion outlines the use of the CCP Decision Tree for this identified
hazard:
1. Do control measure(s) exist for the identified hazard (pathogens)? YES
2. Does this step (spraying with organic acid) eliminate or reduce the likely occurrence of a
hazard (pathogens) to an acceptable level? YES, spraying heads with organic acid will
reduce pathogens.
This step is a CCP in this process to reduce pathogens (i.e., E. coli O157:H7 and
Salmonella).
###
Rosenthal Meat Science and Technology Center
Beef Slaughter Decision-Making Documentation
April 7, 2003
18
Chilling -- Heads:
Process Step Overview:
The heads are placed on a tree and put in the hot box to initiate the chilling process. The hot box is
designed to optimize the initial chill because it has high air movement at refrigeration temperatures
to help reduce the surface and internal temperatures of the heads. The refrigeration system is a
closed ammonia system and the cooling capacity is capable of chilling the number of heads that we
produce on a routine basis.
Hazard Analysis Logic:
Chemical. The refrigeration system operates with ammonia in a closed system; therefore, it was
not considered as a reasonably likely to occur food safety hazard. The team could not think
of any other potential chemical hazards that should be considered as part of the chilling
process.
Physical: None identified at this time. The team could not think of any physical food safety
hazards that were associated with the chilling process.
Biological: The process of chilling does not introduce biological hazards. Pathogens that are
present when entering the chilling step cannot be eliminated either. Although microbial
interventions are in place to reduce pathogens on the slaughter floor, the team recognizes
that pathogens may be present on the head as it passes from the slaughter floor to the cooler.
Proper chilling of heads can help reduce the potential for pathogen growth. Therefore, the
team considers chilling to be a CCP.
The following discussion outlines the use of the CCP Decision Tree for this identified
hazard:
1. Do control measure(s) exist for the identified hazard (pathogens)? YES
2. Does this step (chilling) eliminate or reduce the likely occurrence of a hazard (pathogen
growth) to an acceptable level? YES, proper chilling of heads will reduce the potential
for pathogen growth.
This step is a CCP in our process.
###
Rosenthal Meat Science and Technology Center
Beef Slaughter Decision-Making Documentation
April 7, 2003
19
Variety Meat Processing:
Process Step Overview:
After removal during evisceration, the variety meats are prepared for chilling by trimming or other
procedures.
Hazard Analysis Logic:
Physical: The team could not identify any physical hazards associated with the processing of
variety meats. The meats are processed whole and are not altered in any way.
Chemical: None identified at this time. Variety meat processing does not introduce any
chemical hazards.
Biological: Pathogens. It is an accepted fact that raw meat is a potential source of pathogens
(i.e., Salmonella and E. coli O157:H7). The USDA baseline studies document previous
incidence levels. Therefore, we acknowledge that steps must be taken to try to eliminate,
prevent or reduce to an acceptable level any pathogen contamination. The steps that are
identified for this process will be discussed later in the subsequent steps organic acid
spraying and chilling.
The following discussion outlines the use of the CCP Decision Tree for this identified
hazard:
1. Do control measure(s) exist for the identified hazard (pathogens)? YES
2. Does this step (variety meat processing) eliminate or reduce the likely occurrence of a
hazard (pathogens) to an acceptable level? NO
3. Could contamination with the identified hazard(s) (pathogens) occur in excess of
acceptable level(s) or could it increase to an unacceptable level? YES
4. Will a subsequent step eliminate the identified hazard(s) or reduce its likely occurrence
to an acceptable level? YES, organic acid has been scientifically shown to reduce the
likely occurrence of pathogens, and proper chilling will reduce the potential for pathogen
growth.
This is not a CCP in our process.
###
Rosenthal Meat Science and Technology Center
Beef Slaughter Decision-Making Documentation
April 7, 2003
20
Trim Zero Tolerance Variety Meats:
Process Step Overview:
The variety meats are inspected for compliance with zero tolerance requirements.
Hazard Analysis Logic:
Chemical and Physical: None identified at this time. The process of visually inspecting the
variety meats for visible feces, milk and ingesta does not impact chemical or physical food
safety hazards. Therefore, none were identified for this step.
Biological: Visible feces, milk, and ingesta. USDAs Food Safety and Inspection Service
requires the trimming of all visible feces, milk, and ingesta from the variety meats prior to
washing as part of zero tolerance control. According to 62 Federal Register (FR) 63254,
November 28, 1997, the plant must address zero tolerance in the HACCP plan. Therefore,
this step is identified as a CCP to control visible feces, milk, and ingesta by knife trimming
any visible contamination.
###
Rosenthal Meat Science and Technology Center
Beef Slaughter Decision-Making Documentation
April 7, 2003
21
Organic Acid Spray Variety Meats:
Process Step Overview:
A lactic acid solution is mixed and applied to all exposed areas of the variety meats using a hand-
held spraying wand that mixes the lactic acid with water to achieve the appropriate concentration.
Special care is given to ensure that both external and internal surfaces receive the spray.
Hazard Analysis Logic:
Chemical: The lactic acid used is a food grade substance that is approved for use on variety
meats at a 2.5 % maximum level. Therefore, no chemical food safety hazards were
identified as reasonably likely to occur by the act of spraying variety meats with the lactic
acid.
Physical: The step of applying lactic acid does not impact physical hazards; therefore, the team
could not think of any physical hazard that was associated with this step of the process.
Biological: Pathogens. Lactic acid has been shown to be an effective organic acid at reducing
pathogen loads. Therefore, the team considers the use of lactic acid as a CCP for reducing
pathogens on the slaughter floor. Scientific literature is available to support the use of lactic
acid as a microbial intervention.
The following discussion outlines the use of the CCP Decision Tree for this identified
hazard:
1. Do control measure(s) exist for the identified hazard (pathogens)? YES
2. Does this step (spraying with organic acid) eliminate or reduce the likely occurrence of a
hazard (pathogens) to an acceptable level? YES, spraying variety meats with organic
acid will reduce pathogens.
This step is a CCP in this process to reduce pathogens (i.e., E. coli O157:H7 and
Salmonella).
###
Rosenthal Meat Science and Technology Center
Beef Slaughter Decision-Making Documentation
April 7, 2003
22
Chilling Variety Meats:
Process Step Overview:
The variety meats are placed on a tree and put in the hot box to initiate the chilling process. The hot
box is designed to optimize the initial chill because it has high air movement at refrigeration
temperatures to help reduce the surface and internal temperatures of the variety meats. The
refrigeration system is a closed ammonia system and the cooling capacity is capable of chilling the
number of variety meats that we produce on a routine basis.
Hazard Analysis Logic:
Chemical. The refrigeration system operates with ammonia in a closed system; therefore, it was
not considered as a reasonably likely to occur food safety hazard. The team could not think
of any other potential chemical hazards that should be considered as part of the chilling
process.
Physical: None identified at this time. The team could not think of any physical food safety
hazards that were associated with the chilling process.
Biological: The process of chilling does not introduce biological hazards. Pathogens that are
present when entering the chilling step cannot be eliminated either. Although microbial
interventions are in place to reduce pathogens on the slaughter floor, the team recognizes
that pathogens may be present on variety meats as it passes from the slaughter floor to the
cooler. Proper chilling of variety meats can help reduce the potential for pathogen growth.
Therefore, the team considers chilling to be a CCP.
The following discussion outlines the use of the CCP Decision Tree for this identified
hazard:
1. Do control measure(s) exist for the identified hazard (pathogens)? YES
2. Does this step (chilling) eliminate or reduce the likely occurrence of a hazard (pathogen
growth) to an acceptable level? YES, proper chilling of variety meats will reduce the
potential for pathogen growth.
This step is a CCP in our process.
###
Rosenthal Meat Science and Technology Center
Beef Slaughter Decision-Making Documentation
April 7, 2003
23
Receiving Organic Acid:
Process Step Overview:
This is where the lactic acid we use in our organic acid rinses is received.
Hazard Analysis Logic:
Chemical: The lactic acid used is a food grade substance that is approved. We have letters of
guarantee on file from our supplier stating that food grade lactic acid is considered
Generally Recognized as Safe under 21 CFR 184.1061.
Physical: The step of receiving the lactic acid does not impact physical hazards; therefore, the
team could not think of any physical hazard that was associated with this step of the process.
Biological: The team could not identify any biological food safety hazards that can be identified
with receiving the lactic acid.
###
Dry Storage:
Process Step Overview:
This is where the lactic acid we use in our organic acid spray is stored.
Hazard Analysis Logic:
Chemical: The team could not identify any chemical hazards associated with storing of the
lactic acid.
Physical: The step of storing the lactic acid does not impact physical hazards; therefore, the
team could not think of any physical hazard that was associated with this step of the process.
Biological: The team could not identify any biological food safety hazards that can be identified
with storing the lactic acid.
###