By Laurel Maloy, contributing writer, Food Online
The way the Food Safety and Inspection Service deals with positive E. coli tests at ground beef trim facilities is undergoing some marked changes
Ground beef trim utilized by the grinder processor has long been at the center of controversy over its lack of traceability and the fact the trim provider is often not held accountable. For years the grinder has taken the heat, while a slap-on-the-wrist email notification was sent to the supplier.
White Paper: Improving QA In The Meat Cold Chain
Rarely, usually only in instances of repeated positive E. coli tests, was additional follow-up performed at the beef trim provider’s facility by the Food Safety and Inspection Service (FSIS). When further investigation was warranted, FSIS would perform a Comprehensive Food Safety Assessment (CFSA), typically scheduled up to a month from the date of the positive test. Basically, the CFSA is verification of a facility’s Hazard Analysis and Critical Control Points (HACCP) plan and its Sanitation Standard Operating Procedures (Sanitation SOPs), and/or its pre-requisite programs. FSIS’s Enforcement, Investigations, and Analysis Officer (EIAO) is required to complete the CFSA, once started, prior to departing the facility.
New policies, however, are being implemented and enforced by FSIS with many consumers and advocacy groups are saying, “It’s about time!” Rather than its past, somewhat lackadaisical attitude toward raw beef trim suppliers, FSIS will start actively investigate all positive E. coli tests. FSIS will immediately send one or more EIAOs to the establishment(s) in question. The purpose is to identify any potential cause of contamination by examining a facility’s operational, as well as testing, records. A thorough inspection will be done in order to ascertain any insanitary conditions that may exist and to identify potential sources for contamination and/or cross-contamination. This will be a CFSA, on steroids, so to speak. As such, raw beef trim suppliers may want to be reassessing their HACCP plans and procedures.
Proactively, in keeping with FSMA’s focus, FSIS will be instructing its on-site inspection personnel to more closely examine a facility’s pathogen test results. Inspectors will compare past test results with current test results, in 30-day increments, in order to determine if an emerging pattern of adverse trends exists. If a facility experiences a High-Event Period — a period of time with high incidents of contaminated product — FSIS may require the establishment take further action. Further action may entail a raw beef trim recall, and in some cases could trigger a recall of intact beef primals.
Preventative Controls & Record Keeping: Complying With FSMA
In regard to “high-event periods,” there may have to be some clarification from FSIS. Plants do not seem to have a clear and concise measurement upon which to determine a high-event period and, so far, FSIS has not provided detailed guidance on how to respond to the same. Section 1: Industry’s E. coli Testing of the USDA’s Application of FSIS Sampling Protocol for Testing Beef Trim for E. coli O157:H7, addresses the issues confronting FSIS and raw beef trim processors.
FSIS is predicting this new and more-stringent recall policy may result in as many as 12 additional recalls each year. Being forewarned is being forearmed.