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A Comprehensive Feed Safety Approach for Rendered Products FDA Public Meeting Discussion of Animal Feed Safety System S PowerPoint Presentation
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A Comprehensive Feed Safety Approach for Rendered Products FDA Public Meeting Discussion of Animal Feed Safety System September 23, 2003. David Harlan Taylor Packing Co., Inc An Excel Food Solutions Company. Animal Feed Manufacture. Pet Foods. Food Animal Production. Consumer Foods.

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A Comprehensive Feed SafetyApproach for Rendered Products FDA Public MeetingDiscussion of Animal Feed Safety SystemSeptember 23, 2003

David Harlan

Taylor Packing Co., Inc

An Excel Food Solutions Company

slide2

Animal Feed

Manufacture

Pet

Foods

Food Animal

Production

Consumer

Foods

Rendered

Co-Products

Meat

Processing

Feed Ingredients

Rendering Cycle Plays a Critical Role

beef processing typical fed cattle plant
Beef ProcessingTypical Fed-Cattle Plant

USDA Ante mortem

Dressing Floor

Blood Drying

Inedible

Rendering

Fabrication

Edible

Rendering

Further Process

Edible Beef Products

Feed & Technical

beef processing taylor packing
Beef ProcessingTaylor Packing

USDA Ante mortem

Dressing Floor

Blood Drying

Inedible

Rendering

Fabrication

Further Process

Edible Beef Products

Feed & Technical

taylor rendering process
Taylor Rendering Process

Dressing Offal

Fab Bone & Fat

MIX &

GRIND

LOADOUT/

BLENDING

BEEF TALLOW

TANKS

C

O

O

K

E

R

STORAGE

FILTER

GRIND/SCREEN

TANK

COOLER

Liquid

Solid

SCREEN

CENTRIFUGE

PRESS (3)

comprehensive program
Comprehensive Program
  • Philosophy & Commitment
  • Raw Material Source, Specifications & Assurances
  • Hazard Analysis & Critical Control Point program
  • Good Manufacturing Practices
  • Employee Training Programs
  • Transportation Policy
  • Third Party Audits
philosophy commitment
Philosophy & Commitment
  • Preventative Mindset
  • Proactive vs. Reactive
  • Continuous Improvement
  • Commitment from Entire Team
    • Leadership
    • Management
    • Production
raw material specifications
Raw Material Specifications
  • In-House Packer Source – 100% Bovine with mixed supply from 70% mature cows and 30% fed-cattle
  • 100% from Cattle Passing Ante Mortem Inspection Conducted by USDA:FSIS Veterinarian
  • Packinghouse Training & Awareness Relative to Potential Physical & Chemical Contaminants
  • CNS Tissue Removed in Packinghouse
hazard analysis and critical control point haccp 7 principles
Hazard Analysis and Critical Control Point (HACCP) 7 Principles
  • Assess Hazards
  • Determine Critical Control Points – CCP
  • Establish Critical Limits for CCP’s – CCPCL
  • Procedures to Monitor CCP’s
  • Develop Corrective Action Plans
  • Recordkeeping
  • Verification
potential hazards 3 classes
Biological

Microbiological

Insect Infestation

TSE’s

Chemical

Pesticides & PCB’s

Lubricants, oils, etc.

Physical

Metal

Plastic

Potential Hazards3 Classes
haccp example microbiological pasteurization
HACCP Example Microbiological - Pasteurization
  • Assess Hazard
    • Raw material contains potential pathogens
  • Determine Critical Control Points – CCP
    • Cooker discharge temperature - TEMP
    • Raw material grind - GRIND
    • Processing rate - RATE
  • Establish Critical Limits for CCP’s – CCPCL
    • TEMP - Minimum 270o F based on validation study
    • GRIND - Maximum 30 mm anvil gap on pre-breaker
    • RATE - Maximum 36,000 pounds/hour feed rate
haccp microbiological continued
HACCP – MicrobiologicalContinued
  • Procedures to Monitor CCP’s
    • TEMP - Continuous monitoring by certified thermocouple
    • GRIND - Inspection, Weekly measurement of anvil gap
    • RATE - Computer tracking of cooker feed auger
  • Develop Corrective Action Plans
    • TEMP - Alarm notification, automated discharge shutoff
    • GRIND - Repair, Rebuild when gap reaches 30 mm
    • RATE - Reduce feed rate if over 36,000 pounds/hour
haccp microbiological continued1
HACCP – MicrobiologicalContinued
  • Recordkeeping
    • TEMP - Computer tracking of CCP and alarm log
    • GRIND - Operations & maintenance logs
    • RATE - Computer tracking of CCP and alarm log
  • Verification
    • Clostridium perfringens testing – indicator organism
    • 15 day intervals
    • Rotate shift and time within shift
slide15

Recordkeeping

Cooker

Temperature

Trending and

Statistical Analysis

good manufacturing practices gmp
Good Manufacturing Practices (GMP)
  • Housekeeping Issues
  • Recordkeeping
  • Pest Control Program
  • Facility Design & Repair
  • Sanitation Program
  • Startup & Shutdown Procedures
gmp example prevent salmonella recontamination
GMP ExamplePrevent Salmonella Recontamination
  • APPI model adopted by +99% of industry
  • Process zones in facility
  • Work habits & policies
  • Startup procedures
  • Reprocessing of product spills
  • Dry cleaning of finished product areas
  • Sanitation practices that target “hot spots”
  • Facility design & equipment maintenance
  • Effectiveness verified by finished product testing

No CCP available except formaldehyde addition

employee training
Employee Training
  • Specific Modules on HACCP, GMP’s and SOP’s
  • New Hires
    • Entry at Trainee position
    • Individualized training over several months
  • Career Advancement
    • Training program for each position
    • Certified by written & verbal testing
  • All Employee’s
    • Quarterly quality training
    • Immediate team review of feed safety issues
transportation policy
Transportation Policy
  • Certification of regulatory compliance by carriers
  • Trucks are only to haul agricultural commodities
  • Trucks are to be clean prior to arrival
  • Visual inspection of empty trucks upon arrival
    • No visible carryover regardless of past ingredient hauled
    • Will the integrity of our product be maintained?
  • Assurance of cleanout after delivery
    • Included in policy signed by carriers & drivers
    • Prominent reminder to driver attached to Bill of Lading

Clean Conveyances and Inspection Prior to Loading

Is the Responsibility of Every Ingredient Supplier!!

third party audits 21 cfr 589 2000
Third Party Audits21 CFR 589.2000
  • APPI Certification via Cook & Thurber
    • Found high compliance in Rendering Industry
    • Confirmed by FDA Inspections
    • Discontinued because of high compliance
  • Facility Certification Institute - FCI
    • Requirements are based upon FDA rule
    • Must prove compliance with FCI program
    • Ingredient supplier and transport certifications
    • Must demonstrate adequacy of flushing when co-mingling restricted use products
    • Annual audits to maintain status in program