Hazard Analysis Revisited

By Lynn Knipe

As very small meat plants are preparing their HACCP plans, they need to be aware of an FSIS letter that was to be sent this past spring to selected small and large meat plants that had already implemented HACCP. FSIS was concerned that some plants have not addressed all of the food safety hazards that are reasonably likely to occur during meat processing. The two biggest concerns were: 1) the reference to GMP’s as providing necessary controls or justification that a hazard is not likely to occur and 2) HACCP plans that contain only one Critical Control Point (CCP), and that one CCP is associated with a hazard at the raw material receiving step. FSIS’ concern is that this suggests that there are no food safety hazards that are reasonably likely to occur during that actual processing of the product. And as you have heard before, FSIS is "unaware of any meat or poultry production process that does not present a food safety hazard."

This has been a more common problem with raw ground and raw, not ground processes, in which some establishments do not feel that they have a CCP that prevents, reduces or eliminates food safety hazards, in the absence of these controls. FSIS has suggested that temperature control, during processing, that would prevent growth of pathogenic microorganisms, or antimicrobial intervention methods, which would prevent, reduce or eliminate pathogens, should be evaluated in order to identify microbiological hazards that must be addressed in your HACCP plan. Some people have argued that temperature control does not meet the requirements of a Critical Control Point for raw meat products, but temperature control is important in preventing further growth of pathogens, such as Salmonella, Staphylococcus, E. coli, etc. Temperature control is included on the Safe Handling label, and is one of the four food safety concepts promoted in the Fight Bac! Campaign.

What this all translates to is that if doing your hazard analysis for raw, ground or not-ground product, you really don’t think that you have a hazard that is likely to occur, seriously consider temperature control during processing (grinding, packaging, etc.) as a critical control point.

Consider the temperature of raw meat in your operation as it is being cut, ground twice, and as it sits waiting to be packaged. For a variety of reasons, many establishments process in unrefrigerated rooms. While it may be intended that the meat be out of the cooler for only a short time, during processing, the temperature of this product is critical. And in the chaos of a normal work day, the time that meat is allowed to sit out in an unrefrigerated may be longer than realized.

For those who agree with me so far, your next concern may be how to monitor temperatures and what to use for a critical limit. It is recommended that you use the product temperatures, not air temperatures, to monitor this critical control point. Air temperatures fluctuate much more quickly than meat temperatures, and you could have a refrigeration problem that could quickly allow cooler room temperatures to rise, while the meat temperatures were still well below a point of safety concern.

With raw beef and pork, we have no temperature regulations to help us determine a critical limit. However, there are regulations for raw poultry, which might give us some ideas on how to proceed. The raw poultry temperature regulations include a maximum of 55° F, for the internal product temperature, with the stipulation that once reaching that temperature, the product needs to be chilled to 40° F within 2 hours. Using a maximum of 55° F, for the internal product temperature critical limit, it would be wise to set 45° F or 50° F for your company target, to avoid exceeding your critical limit.

Another concern, particularly with ground product is with the microbial quality of reworked product. If you generate rework which is held from one day and included in the next day’s product, temperature control over that period of time is critical. Also, is there any chance that this reworked product could be mixed into product, for which another generation of rework is generated and held another day? Remember that reworked product was at the root of Hudson Foods problems a couple of years ago.


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