IKE Scenario 06-04 Illustration of FSIS Notice 50-04 Concerning Tonsils

    FSIS Notice 50-04 describes one possible method that establishments may incorporate into their written SRM procedures for the removal of visible tonsils. 9 CFR 310.22 states that the tonsils of all cattle are specified risk material (SRM) and that establishments that slaughter cattle and establishments that process the carcasses or parts of cattle shall develop, implement, and maintain written procedures for the removal, segregation, and disposal of specified risk materials in their HACCP, SSOP, or other prerequisite programs. The Notice also describes Inspection Program Personnel’s (IPP) ongoing responsibilities in the verification of the establishment’s written procedures. This IKE Scenario is an illustration of the establishment and IPP responsibilities.   

    You are the Public Health Veterinarian (PHV) at establishment 38 M, a large cattle slaughter facility who has their written SRM removal procedures incorporated into their HACCP plan.  This facility harvests beef tongues and tongue trimmings for edible purposes.  You are in the process of correlating with a newly promoted consumer safety inspector (CSI, GS-8) in the verification procedures for SRM removal, segregation, and disposal in accordance with 9 CFR 310.22 as part of the scheduled 03J01 procedure for the day. You instruct the GS-8 that verification of SRM removal should begin with a review of the establishment's written plan.  Correlation on this day will focus specifically on verification of tonsil removal, for which you have also discussed FSIS Notice 50-04 and reviewed 9 CFR 310.22. Your review of the establishment's written procedure reveals that their procedures meet the regulatory requirements of 9 CFR 310.22.  At this time, the establishment has opted to follow the guidance regarding the transverse cut provided in FSIS Notice 50-04 to remove visible tonsils from the tongue and its associated tissues.    

    After reviewing the plant's written procedure, you and the CSI decide to verify the plant's actual execution of this program.  While touring the kill floor you observe plant personnel making the cuts in accordance with their written procedure, and disposing of the SRMs (palatine and lingual tonsils) in a manner consistent with 9 CFR 310.22.  You also examine several pieces portions of tongue and tongue trimmings to see if the plant is effectively removing visible portions of the tonsil, and you conclude that this is being performed satisfactorily.  Finally, it is determined that the records documenting the removal of these SRMS meet regulatory requirements. You mark the PBIS 03J01 procedure as “performed”. Note: Tongue trimmings are not SRM as long as they do not contain visible tonsil material   

    After returning to the USDA office, the plant manager comes to discuss a new procedure for the removal of tonsils from tongues currently being performed at a neighboring facility.  As a critical thinker, you inform plant management that what is required is the removal of visible tonsils.  You go on to state that there may be ways to accomplish this other than the method explained in Notice 50-04, and explain that the continued focus of FSIS verification will be the successful implementation of the establishment's written protocol designed to remove, segregate, and dispose of visible tonsils.   

    The above scenario outlines several of the key elements of FSIS verification of an establishment's system designed to remove, segregate, and dispose of SRMs.  These elements involve written procedures in their HACCP, SSOP, or other prerequisite programs, adequate execution of the procedures, as well as a recordkeeping component.  It also demonstrates that, when applied specifically to the removal of tonsils in cattle, establishments are required to remove the visible portion of the lingual and palatine tonsils; FSIS Notice 50-04 describes only one possible method that accomplishes this.