Teaching Workshop: Bovine Spongiform Encephalopathy (BSE)
Advanced Meat Recovery (AMR)

New Requirements for AMR-Beef

• On January 12, 2004, FSIS published:
  • 3 interim final rules with requests for comments and one notice.
  • In response to the December 25, 2003 confirmed positive of BSE in a cow in the U.S.
• One rule added new requirements for AMR.

Advanced Meat Recovery (AMR)

• AMR systems:
  • Enable processors to remove attached skeletal muscle tissue from livestock bones without incorporating significant amounts of bone and bone product into the final meat product.
  • When used properly, the product from AMR systems is comparable to meat derived by hand deboning.
  • Use hydraulic pressure to emulate the physical action of hand-held high-speed knives to remove skeletal muscle tissue from bone.
  • Application of pressure detaches meat from the bones in a "hard separation" process.

Harvard Risk Assessment for BSE

• USDA commissioned the Harvard Center for Risk Analysis to conduct a risk assessment for BSE:
  • Indicated that the most important means by which low-risk tissue can become contaminated is through the use of AMR systems that can leave spinal cord and dorsal root ganglia (DRG) in the recovered meat product.

FSIS 2002 Survey of AMR Products

• For seven months, FSIS collected samples from AMR systems that used beef vertebrae as source material.
  • Tested for the presence of spinal cord and DRG.
  • Only 12% of plants were able to produce final AMR product with no spinal cord or DRG on a consistent basis.

Prohibited from Use in AMR

• As of January 12, 2004, meat derived from AMR systems cannot contain the following parts from any livestock:
  • Brain
  • Spinal cord
  • Dorsal root ganglia (DRG)
  • Trigeminal ganglia
  • Significant amounts of bone solids or marrow
• In addition, for cattle 30 months of age and older:
  • Skulls and vertebral column bones are prohibited from use in AMR systems.

New AMR Requirements

• To ensure that AMR systems are not a means of introducing central nervous system (CNS)-type tissue into product labeled as "meat".
• In addition, FSIS has determined MS(Beef) to be inedible and prohibits it from use as human food.

Plant Responsibilities - AMR Beef

• In addition to meeting all existing regulatory requirements, plants which produce AMR beef must:
  • Reassess their hazard analysis to determine if there is a hazard reasonably likely to occur.
    • AMR regulatory changes are likely to affect the hazard analysis.
  • Ensure that the AMR production process is in control in order to prevent the introduction of central nervous system (CNS)-type tissue into product labeled as "meat".
  • Have these control procedures and recordkeeping included in the HACCP plan, Sanitation SOP, or other prerequisite program.
  • Maintain records on the entire AMR process control system on a daily basis.
    • Previously, recordkeeping requirements applied only to the calcium criteria.
  • Make those records available to FSIS inspection program personnel upon request.
  • Observe bones entering the AMR system.
  • Test product exiting the AMR system.
  • Determine how and when the plant will test AMR product for calcium, iron, spinal cord, and DRG.
    • May use testing methods which are not as sensitive as the method FSIS uses, but are less expensive.

AMR from All Livestock

• AMR from livestock other than cattle must also meet the new requirements.
• Only differences:
  • There are no Specified Risk Materials (SRMs) for other livestock.
  • HACCP plan does not have to be reassessed, but the program must be documented in writing.

FSIS Responsibilities

• In addition to present inspection procedures, inspection program personnel will:
  • Take samples from plants which produce AMR products, to ensure that prohibited tissues are not in the product.
  • Verify plant testing, using validated histological procedures.
  • FSIS is developing inspection procedures, and methodology, including those for sampling and testing.

Enforcement

• If a plant's AMR system repeatedly fails to produce product free of prohibited materials, it will not be allowed to produce AMR meat from vertebrae.