IKE Scenario 05-03 Performing 03J01 and 03J02 Procedures for the Determination Compliance with the Food Safety Standard for Fecal Material, Ingesta and Milk on Livestock Carcasses During Slaughter Operations.

IKE scenario is the first of three that are designed to illustrate the procedures used in accordance with FSIS Directive 6420.1, Livestock Post-Mortem Inspection Activities – Enforcing the Zero Tolerances for Fecal material, Ingesta and Milk, dated 12/17/98. This directive provides instructions to inspection personnel that are similar to FSIS Directive 6150.1, Rev. 1, Poultry Post-Mortem Inspection and Reinspection – Enforcement of Zero Tolerance for Visible Fecal Material, dated 6/19/98

You are an off-line GS-8 slaughter inspector in a young, fat cattle slaughter facility. Your duties include the verification of the food safety standard for contamination of carcasses with feces, milk, and/or ingesta, under the 03J01/03J02 HACCP categories. This verification is to ensure that the establishment’s controls are effective and that their HACCP plan is being adequately implemented to either prevent the contamination of or remove feces, ingesta, or milk from carcasses.  Verification of this food safety standard by FSIS personnel is performed after the final carcass inspection station or area and before the final wash regardless of where the firm’s Critical Control Point (CCP) is located in accordance with FSIS Directive FSIS Directive 6420.1, Part 2, II,(b)(2). This particular establishment’s CCP is in the cooler. 

While performing the 03J01 procedure for zero tolerance, you select 11 non-split beef carcasses of the 1,000 beef carcasses being slaughtered on the shift for verification examination in accordance with FSIS Directive 6420.1, Livestock Post-Mortem Inspection Activities – Enforcing the Zero Tolerances for Fecal material, Ingesta and Milk, dated 12/17/98. In this particular establishment the verification is performed on-line at a location just past the on-line GS-07 inspector. (Note: According to the Directive, the verification of establishment procedures is, under normal circumstances, to be performed on-line by off-line inspection personnel.) While performing the verification procedure you observe readily identifiable fecal material, i.e. yellow, green, or brown material containing fibrous or plant-like textures, on two of eleven beef carcasses in your sample.

You immediately notify establishment management verbally of the failure to meet the food safety standard due to the fecal contamination findings. It is the Agency’s position that not meeting this food safety standard on livestock carcasses presented for post-mortem inspection, i.e. at the final rail, is an indication that the establishment’s controls have failed. Consequently, they are expected to take corrective actions in accordance with 9 CFR 417.3(a). As a part of the establishment’s corrective action, the slaughter floor foreman has the contaminated carcasses identified for off-line trimming and re-inspection. The preventive measure is identified by the establishment as retraining the new establishment employees assigned to the hiding operation. The plant also plans to initiate a program in which the live cattle are inspected for excessive contamination before entering the plant for slaughter. 

As a critical thinker, what are your next actions?

·         Verify the effectiveness of the establishment's immediate corrective action by checking the adequacy of trimming by establishment personnel in accordance with FSIS Directive 5400.5, 9 CFR 310.18(a), 417.3(a) and 417.8. 

·         Document the food safety standard noncompliance on FSIS Form 5400-4, Noncompliance Record. Notify the Veterinary Medical Officer so that he or she is apprised of the situation in the event that reoccurring noncompliance’s occur and further regulatory control action must be taken. 

·         The off-line GS-8 will verify the immediate corrective action of removal of the visible fecal material found on the affected lot of beef carcasses defined by the establishment. 

·         The off-line GS-8 will perform the 03J02 procedure in response to the failure to meet the food safety standard found during the performance of the 03J01 procedure for zero tolerance verification in accordance with FSIS Directive 5,000.1, Rev. 1, dated 5/21/03 . 

NOTE: Identification of corrective and preventive measures in response to any failure to meet the food safety standard as illustrated in the above IKE scenario are solely the responsibility of federally inspected establishments. This would include, but is not limited to, the decision to slow line speeds, define specific lots or numbers of carcasses affected, as well as determining lot size and/or reworking product back to the last acceptable check.

FSIS only verifies that the HACCP plan and any corrective actions taken by the establishment meets the regulatory requirements found in 9 CFR 417 et al. Agency personnel must not suggest or direct the corrective actions or preventive measures to be taken by the establishment. FSIS personnel will only accept the establishment’s actions as either meeting the regulatory requirements or not, as specified.  

In this scenario the establishment’s CCP is located in the cooler. As such, no deviation from a critical limit has occurred. In this instance, there is a non-compliance with the establishment meeting the Agency’s food safety standard that FSIS verifies at or after the final rail, which is an indication that their controls have failed. Consequently, as outlined in the Federal Register Notice, Vol. 62, Number 229, the establishment must meet the requirements of 9 CFR 417.3(a), even though there technically was no deviation from an established critical limit.

For IKE related questions, send mail to ike@fsis.usda.gov. For all other general questions, send to Tech Center address listed below.