USDA’s Food Safety and Inspection Service (FSIS) just updated and released its generic Hazard Analysis and Critical Control Point (HACCP) model for beef slaughter. This update replaces the 1996 version of the model. The model may be used as a starting point for developing a slaughter HACCP plan for other classes of livestock.
At the same time, the agency has also developed a new Sanitation Standard Operating Procedures (SSOP) guide.
As part of its ongoing updates to HACCP guidance, FSIS two months ago released four revised HACCP guidance models to help the meat and poultry industry stay up to date.
Guides and generic models – the newest ones being for beef jerky, raw ground beef, bacon and pork slaughter – are designed to help processors in meeting regulatory requirements to produce safe and wholesome food products. This year is the 25th anniversary of USDA’s mandatory HACCP regulations to improve the safety of meat and poultry and other food products. The Food and Drug Administration required HACCP plans for seafood. Recently, HACCP was added as a requirement for making egg products, also under USDA jurisdiction. And along the way, other HACCP requirements have been added by states for a variety of food products.
These models and guidance for poultry and meat include updated scientific references, a product description, ingredients list, production flow diagram, hazard analysis and HACCP plans.
Mandatory HACCP food safety plans in meat plants as part of government regulations came about as the result of an outbreak of E. coli O157:H7, after the dangerous pathogen contaminated undercooked hamburger patties sold at Jack in the Box restaurants in Washington state in 1993. The outbreak eventually resulted in severe sicknesses, causing four deaths, 170 hospitalizations and 700 foodborne illnesses in four states.
The tragedy resulted in a massive revamping of how meat and poultry inspection is carried out in the United States, Canada, and other countries.
Requirements for a HACCP food safety plan including conducting an analysis for hazards in a food processing plant, identifying critical control points where steps can be taken to prevent food safety problems, establishing critical limits during slaughter and processing, monitoring those critical control points plants have set up, applying corrective actions if food safety problems do arise, documenting the entire food safety system, and carrying out validation and verification procedures that make sure the a plant’s HACCP system is working.
“HACCP actually began being used by seafood before meat and poultry,” said Kerri Gehring, PhD, professor of animal science at Texas A&M University, and president and chief executive officer of the International HACCP Alliance.
Before HACCP became mandatory in poultry and meat inspection, inspectors relied on their senses – sight, smell, and touch, or “poke and sniff,” to detect potential hazards. Such methods didn’t do much to find today’s major food safety threats, which are mostly microbiological and pose the most significant threats to consumers. Before HACCP changed the inspection system, meat and poultry inspection was also termed “command and control” because of the absolute power inspectors had over plants.
And while inspectors still have a great deal to say about what goes on in plants, HACCP made two major changes: (1) It altered the way food safety inspections are done. (2) It gave plants the responsibility for formulating a HACCP food safety plan. Before HACCP, plant operators relied on inspectors to tell them if what they were doing was “right” or “wrong.” Now the responsibility for producing safe food was being thrown more into the industry’s corner.
Al Almanza, global head of food safety at JBS, who formerly served as Administrator of USDA’s Food Safety and Inspection Service, said experts initially thought HACCP would not be a good safety system to use in the food industry.
“Critics said it was designed for NASA (the space industry) and the auto industry, not for food safety,” Almanza commented. “They didn’t see the relevance of HACCP in regulating meat and poultry, which as you know, is a heavily-regulated industry. Or that HACCP could help meat and poultry plants to produce food products more safely.
“But was there anything better to improve poultry and meat slaughter and product safety? No,” Almanza said. On the contrary, he believes it has been the best option for food safety. “It has streamlined the whole approach to inspection for FSIS and industry – how they communicate with each other, the expectations of meat and poultry plants and inspectors -- and HACCP set up a prescribed way of doing things.”
“Before HACCP, in the days of ‘command and control’, there was no real playbook for food safety,” Almanza said. “There were so many variables, and no real consistency at all. HACCP brought consistency to our meat and poultry inspection system – and to the way processors themselves make sure their products are safe. Food safety and how it is measured is much more precise now. There are expectations of what HACCP plans and systems are, both to establishment operators and inspectors.
“Inspectors devote their time to finding food safety problems, whether they are microbiological or from other issues. And it has allowed JBS and other companies to set up sophisticated and consistent food safety systems that are able to catch food safety problems before they develop into bigger issues,” he said.
Sizing up safety
But that’s not to say that everything with HACCP has always been perfect – or easy. Chris Young, executive director of the American Association of Meat Processors (AAMP), a trade association representing small, very small and medium-sized meat and poultry processors, said HACCP was a burden to small meat processors, especially in the beginning, when the industry had to learn what it was and how to implement it.
AAMP played and continues to play a major role in helping the small processors with HACCP.
“In the beginning, some plants didn’t want to take on such a major change, so they closed or changed their operations to custom-exempt,” Young said.
Changing to a new food safety system, with a massive revamping of the meat and poultry inspection culture that existed for so long, has been a challenge to small operations where, unlike large companies, there are not microbiologists and scientists on staff. But the small processors got plenty of help, from organizations like AAMP and land grant universities across the country, who set up HACCP training courses, and who still run them.
That said, Young pointed out that HACCP has played a major role in improving food safety in the meat and poultry industry, including the small industry.
“HACCP has been a great improvement for the industry,” he noted. “It forced everyone to understand the food safety side of processing. It made people look at their processes and find the areas where they can control the food safety aspects. It made the industry, the small and very small processors, aware of and understand the hazards that exist and controls they could use in making safe products.”
But that doesn’t mean it’s not difficult or a challenge at times. Young thinks the HACCP models coming out from USDA these days have been more useful to small and very small plants. “A lot of models USDA put out in the past, in the beginning, were really more suited to the operations of large plants. I’m encouraged to see under the current FSIS leadership assistance and help geared to small plants,” he said.
A challenge underway now, in which AAMP is playing a leadership role, is HACCP validation requirements, which have become important. Of particular concern are Appendix A and B, which set up thermal processing and stabilization (cooling down) requirements.
“The small industry has always been more dependent on being able to follow spelled-out requirements like this,” Young explained. “One reason is the very small and small processors still make big hams, for example, so it’s important they can meet these requirements.”
Young has been meeting with USDA-FSIS for several years to make sure the agency can come up with requirements that processors in the small and very small industry can meet.
Educating processors, both small and large, about HACCP and how to meet its requirements goes back to the very beginning of the HACCP regulation, Gehring said. The HACCP Alliance has played a major role in training plant operators to set up and run HACCP plans and systems in their plants. The organization began in 1994, when the industry knew mandatory HACCP was only a few years down the road.
“We trained and continue to train people to teach HACCP to plant operators and show them how to set up HACCP plans and systems – we call it ‘train the trainers’,” she said. HACCP or HACCP-like requirements have expanded to virtually all food products.
The HACCP Alliance went on to sponsor large numbers of HACCP courses for the industry, including large and small plants. “Some meat and poultry plants, large actually, had HACCP in place before it was required – they did it voluntarily,” Gehring explained.
She got involved when she was finishing graduate school. “Dr. Russell Cross, who worked for USDA, was leaving there to come to Texas A&M to teach. He and Rosemary Mucklow, who was then the director of the National Meat Association, met with me, and we set up the HACCP Alliance, with the idea that it would sponsor HACCP courses for everyone.” Gehring helped develop the Alliance and continues to run the organization, and admits it has been a major factor in bolstering HACCP education since its beginning.
Change is always difficult, Gehring said, especially when it’s a massive change and a great change in culture in a system that’s been around for a long time, where everything was always done a certain way.
“I think HACCP’s greatest accomplishment in the food industry is that it changed government inspection and food safety efforts and accomplishments by industry to a science-based system to minimize food safety risks for consumers,” Gehring said.