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03B Raw Ground Meat Industry FSA Methodology Walk-through December 18, 2008 Washington, DC Janet L. McGinn, DVM Staff Officer Office of Policy and Program Development FSIS, USDA Overview What information will be collected by the EIAO for the 03B Raw Ground Meat FSA Tool?

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03B Raw Ground Meat

Industry FSA Methodology Walk-through

December 18, 2008

Washington, DC

Janet L. McGinn, DVM

Staff Officer

Office of Policy and Program Development

FSIS, USDA


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Overview

  • What information will be collected by the EIAO for the 03B Raw Ground Meat FSA Tool?

  • Review of validation

  • How will this information be used?


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Overview

  • Product types will determine which categories of questions the EIAO will seek answers to.

    • Species other than Beef (general, custom exempt, and miscellaneous questions)

    • Beef (all questions)


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Overview of the 03B Raw Ground Meat FSA Tool

  • Interventions and Validation for E. coli O157:H7

  • Sampling and Testing

  • Miscellaneous


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Interventions and Validation for E. coli O157:H7

  • EIAO will directly observe the plant’s interventions

  • Purchase specifications

    • Present? What are they? Verified?

      Interventions on raw ground beef components and ground beef? CCP? Validated?

    • Validation questions walk the EIAO through the thought process to determine whether validation documents are adequate


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Validation

  • Validation includes the HACCP system

  • Initial validation = first 90 days

  • Validation has 2 parts:

    • Scientific or technical support for the HACCP system

    • Initial practical in-plant demonstration proving the HACCP system can perform as expected


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Sampling and Testing

  • Raw Ground Beef Components and Ground Beef

  • Sampling

    • Is it done? Method?

    • Testing

    • Method?

    • EIAO will evaluate for weaknesses in program, i.e. fit for use, adequate frequency, test portion, method validated, method being followed as written

    • Compare to FSIS method

      • Adequate to detect low levels of E. coli O157:H7


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Sampling and Testing

  • EIAO will report on results from in-plant testing and review FSIS results

  • Corrective actions

  • Hold lot pending results?

  • Recall?


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Miscellaneous

  • Definition of “lot”

  • # of suppliers of raw ground beef components

  • Product temperature

  • Cleaning and sanitizing

  • Third party audits

  • Retail exemption


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Miscellaneous

  • Analysis and Summary

    The point where the EIAO will discuss all findings and analyze the impact of these findings on the plant’s food safety system and its ability to produce safe, wholesome and unadulterated product as it relates to raw ground operations.


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Information Use

  • All data, both regulatory and non-regulatory, becomes relevant to inform risk

  • Data used to establish a food safety system’s risk relative to other establishments

    • prioritizing the scheduling of food safety assessments

    • Scheduling verification procedures

    • Scheduling sampling


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