ADVANCEMENT OF THE SCIENCE
SPECIAL REPORT
Federal Meat and Poultry Inspection Duties and Requirements—Part 4: Food Defense, Product Sampling, Rules of Practice, and Summary
Roger W. Amery, CP-FS
findings. These meetings are documented on memoranda of interview and not on non- compliance records because there are no reg- ulations regarding food defense. Mandatory Zero Tolerance Due to contamination from pathogens in feces, ingesta (i.e., material such as food and drink taken into the body by way of the digestive tract), and milk, FSIS has mandated that companies inspect red meat carcasses from the carcass rail inspection to the final wash with zero tolerance for those contami- nants. This requirement applies also to head meat, cheek meat, and weasands (i.e., eso- phogi) that are inspected separately from car- casses. Companies should have e ective con- trols in place, which are monitored by FSIS to ensure that zero tolerance is maintained (U.S. Department of Agriculture [USDA], 2019).
b45r#%5 This 4-part series aims to inform environmental health specialists of the duties and requirements for federal meat and poultry inspectors and the companies they regulate. Part 1 provided general attributes of U.S. Department of Agriculture Food Safety and Inspection Service inspection personnel and regulated companies (Amery, 2023a). Part 2 covered the computer-based system used to communicate results of inspection tasks, the marks of inspection, and slaughter inspection duties and company responsibilities (Amery, 2023b). Part 3 covered the duties performed by consumer safety inspectors who monitor food safety systems. These duties include monitoring of Sanitation Standard Operating Procedures, hazard analysis critical control point (HACCP) procedures, reinspection, labeling issues, and company allergen controls (Amery, 2023c). Part 4 will discuss the verification of company food defenses, laboratory sampling of products, and the Rules of Practice. A summary of the 4-part series is also provided.
Microbiological Sampling
Introduction and Overview At prescribed frequencies, consumer safety inspectors (CSIs) collect product samples, medium washes, and swabs, then send them to U.S. Department of Agriculture (USDA) Food Safety and Inspection Service (FSIS) laboratories for analysis of pathogens related to the product types. At slaughter compa- nies, samples are taken by FSIS inspectors to test for antimicrobials and residual chemi- cal abuse by livestock suppliers. The Rules of Practice are used to address numerous noncompliances. This 4-part series has provided a treatise for environmental health specialists on the duties and policies of FSIS inspectors for the protec- tion of public health. To round out the series, part 4 discusses verification of company food
defenses, laboratory sampling, and the Rules of Practice. Furthermore, a summary and con- clusions from the series are provided. Food Defense Verification Food defense is the voluntary action that companies can take to ensure that intentional contamination does not take place. Threats of intentional contamination could be from outside or inside companies. Companies are encouraged but not required to have written and tested procedures for food defense. FSIS inspectors complete a computerized survey 4 times a year regarding the written food defense procedures of companies. If FSIS inspectors find vulnerabilities that could result in intentional contamination, they meet with the companies and explain the
Generic E. coli Sampling FSIS requires companies that slaughter live- stock to test for E. coli biotype 1 to verify that the slaughter process is under control (Contamination With Microorganisms, 2023; Subpart K—Post Mortem Inspection, 2023a). Carcasses are to be totally free of all fecal material; E. coli is a good indicator of undetectable fecal material. CSIs are to check the slaughter company activities and records regarding E. coli testing. The establishments are to have written procedures showing that the chilled carcasses are selected randomly and from what sites on the carcasses the sam- ples are taken. Testing frequencies (i.e., tests per carcasses produced) are determined according to spe-
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Volume 86 • Number 2
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