IKE Scenario 10-02: 9 CFR 416.15 - Slaughter-SSOP/Poultry -
You are an IIC at a large three-line NELS poultry plant with TSP on-line
Shortly after start-up an inspector on line two requests that you look at a
couple of birds he/she had the helper take off of the line. You notice a couple
of small black specks on the legs of the carcasses. After you question this
inspector, and all of the other inspectors, you perform some verification of
your own and determine that this is a very infrequent occurrence, isolated to
line two, and that the bird washers further down the line seem to be removing
the specks. You determine this to be potential economic adulteration but that
the product is meeting Finished Product Standards (FPS).
Several hours later, one of the GS-08 floor inspector informs you that he/she
found "several small smearable black specks" on four of the ten birds
while performing a pre-chill FPS test on line two. He/she determined that this
substance appeared to be falling off of the rails and onto the carcasses. He/she
also informs you that the FPS test passed and therefore the plant did not seem
to be worried about it.
Moments later, the other GS-08 floor inspector informs you that the line
inspectors on line two had notified her/him that "the birds were covered
with a powdery black substance" and that they wanted to see you.
As a critical thinker, what would you do at this juncture to ensure that all
regulatory requirements are being met and that the plant is not producing and/or
shipping adulterated product?
You go out into the plant to investigate the line inspectorsí concern. You
determine that approximately 45% of the birds have varying degrees of a powdery,
smearable black substance on them. You look up at the rails and notice a
build-up of this same substance on the rails and the chainís trolley wheels.
- At this point you invoke the "Rules of Practice"
according to [9 CFR 500.2(a)(1)&(2)] (This is a "Regulatory
Control Action" due to insanitary conditions/practices and /or
product adulteration). You stop the line and place a US Reject Tag on the
- You immediately inform a member of plant management of their failure to
meet [9 CFR 416.4(d)], which states that product must be protected
from adulteration during processing and handling. You also inform them that
due to the insanitary condition you are taking a regulatory control action
and stopping the line until sanitary conditions have been restored.
- You do not accept the plantís arguments that pre-chill tests are passing
and the "birds are passing through TSP, anyway."
At this point you review the plantís FPS and SSOP records:
- The plantís pre- and post-chill FPS records show higher than normal
levels of extraneous material.
- The plantís pre-operational SSOP records show, that in an effort to
reduce some minor rust build-up on the line two rail the sanitation crew had
performed "an extra heavy foaming of the rail with an approved cleaner,
followed by a thorough rinsing with water." This in turn had led the
maintenance department to "oil the line with an approved
- The operational SSOP records show that the past three hourly operational
sanitation checks indicated that there was a problem with a black powdery
build-up on the rails and trolley wheels and that "this same substance
was falling onto the chickens." The plant had responded with short
skips in production in order to "wipe the rails with rags soaked in an
approved lubricant." The last entry indicated that the plant planned to
perform a more thorough wiping at lunch (which was still approximately two
hours away at that point). The records also indicated that any affected
product was appropriately reconditioned.
After completing your records review, you inspect some product in the cut-up
- You observe this same black substance on product being placed into
packages going to the cooler, labeled and ready to ship. You place a US
Retained tag on the affected product and inform the appropriate supervisor
that the product is on hold.
Finally, you inform plant management of the following:
- That they had seemingly performed all operational SSOP checks according to
their procedures, but they had failed to take proper corrective actions
according to [9 CFR 416.15(a)], when it was determined that the
implementation of the sanitation SOPís had failed to prevent direct
product contamination or adulteration of product.
- That conditions were such that adulterated product was repeatedly being
produced and this same product was being packaged and ready to ship.
- That they would have to meet the "Corrective Actions"
requirements of [9 CFR 416.15(b)], to include:
- Procedures to ensure appropriate disposition of product(s) that may be
- Restore sanitary conditions.
- Prevent the recurrence of direct contamination or adulteration of
- Appropriately reevaluate and modify the SSOPís specified procedures
and/or make improvements in the implementation of the execution of the
procedures specified therein.
You go to your office to document the non-compliance on an NR and to await
the establishmentís response.
- The original findings were infrequent and isolated. As such, they fell
under the heading of potential economic adulteration. An NR would only be
documented it there was an FPS failure. The NR would be under the 04C04
code. Only later, after several hours of the trolley wheelsí friction
causing this black substance (blackened, flaking lubricant) to build up, did
the problem become bad enough to warrant calling it an SSOP failure and
taking the actions outlined.
- This would not be considered a food safety non-compliance under HACCP
("03J" code) and [9 CFR 417]. The lubricant the plant used was
classified as safe for incidental contact and the plant has the appropriate
documentation to guarantee the substanceís safety.
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