FSIS Notice 20-13 - Food Safety and Inspection Service

UNITED STATES DEPARTMENT OF AGRICULTURE
FOOD SAFETY AND INSPECTION SERVICE
WASHINGTON, DC
FSIS NOTICE 20-13
3/12/13
INCREASED VERIFICATION BY INSPECTION PROGRAM PERSONNEL OF SANITARY
DRESSING AT VEAL SLAUGHTER ESTABLISHMENTS
I. PURPOSE
This notice provides inspection program personnel (IPP) assigned to veal slaughter
establishments additional information to use when verifying that sanitary dressing and process
control procedures are preventing contamination of carcasses and the creation of insanitary
conditions. For purposes of this notice, veal slaughter establishments include all
establishments that slaughter bob veal, formula-fed veal, non-formula fed veal, and heavy
calves.
II. BACKGROUND
A. FSIS test results show that the percent positive rate for Shiga toxin-producing Escherichia
coli (STEC) from trimmings produced from veal appears to be higher than that for trimmings
produced from other cattle slaughter classes. Following up on these results, FSIS conducted a
review of Food Safety Assessments (FSAs) and onsite visits to veal slaughter establishments to
identify concerns unique to veal slaughter.
The results of the review showed that:
1. Many veal slaughter establishments may not have implemented sanitary dressing
and process control procedures sufficient to prevent contamination of carcasses and
the creation of insanitary conditions.
2. The amount of contamination from deficient sanitary dressing procedures likely
overwhelmed the decontamination and antimicrobial intervention treatments. These
sanitary dressing deficiencies contributed to the production of products contaminated
with STEC.
B. Based on results of the analyses, IPP need to verify that veal slaughter establishments are
consistently focusing on their sanitary dressing and process control procedures, and that these
establishments are preventing carcass contamination (9 CFR 310.18(a)) and the creation of
insanitary conditions in their operations (9
CFR 416.1). 9 CFR 416.1 through 416.5 require that establishments maintain sanitary
conditions.
C. FSIS issuances related to beef also apply to veal. FSIS inspection program personnel
assigned to veal establishments are to follow the directions in the following issuances:
DISTRIBUTION: Electronic NOTICE EXPIRES: 4/1/14 OPI: OPPD

1. FSIS Directive 10,010.1 Rev. 3, Verification Activities for Escherichia coli O157:H7 in
Raw Beef Products, and
2. FSIS PHIS Directive 6410.1 Rev. 1, Verifying Sanitary Dressing and Process Control
Procedures by Off-line Inspection Program Personnel (IPP) in Slaughter Operations of
Cattle of Any Age.
III. INITIAL INSPECTION PROGRAM PERSONNEL RESPONSIBILITIES
A. After receipt of this notice, at the next weekly meeting, IPP assigned to veal slaughter
establishments are to meet with establishment management. IPP are to inform establishment
management that:
1. IPP will be performing the Beef Sanitary Dressing task at an increased frequency. IPP
will perform the sanitary dressing task at least twice a week for the next 90 days. IPP will
follow the methodology in FSIS PHIS Directive 6410.1 Rev. 1, Verifying Sanitary
Dressing and Process Control Procedures by Off-line Inspection Program Personnel
(IPP) in Slaughter Operations of Any Age.
2. The purpose of this activity is to verify that veal slaughter establishments have
implemented sanitary dressing and process control procedures to prevent contamination
of carcasses (9 CFR 310.18(a)) and to ensure that insanitary conditions are not created
(9 CFR 416.1 and 416.2-416.5, as applicable).
B. IPP are to document this meeting in a Memorandum of Interview (MOI) according to FSIS
PHIS Directive 5000.1, Verifying an Establishment’s Food Safety System and to provide a copy
of the MOI to establishment management.
IV. SANITARY DRESSING VERIFICATION
A. Routinely, IPP perform the Beef Sanitary Dressing task once every other week. However,
IPP assigned to veal slaughter establishments are to perform the Beef Sanitary Dressing task at
an increased frequency for the next 90 days.
1. IPP assigned to veal slaughter establishments are to perform the Beef Sanitary
Dressing task at least twice a week for the next 90 days by adding directed tasks.
2. IPP are to follow the methodology FSIS PHIS Directive 6410.1 Rev. 1, Verifying Sanitary
Dressing and Process Control Procedures by Off-line Inspection Program Personnel (IPP)
in Slaughter Operations of Any Age.
B. IPP are to follow the instructions in FSIS PHIS Directive 13,000.1 Rev. 1, Scheduling In-plant
Inspection Tasks in the Public Health Information System (PHIS) when scheduling their
inspection tasks. IPP are to designate any unscheduled tasks that they did not complete as “not
performed” as a result of the increased frequency of the Beef Sanitary Dressing task. IPP are to
select “Higher priority task took precedent” as the reason code.
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C. IPP are to record any non-compliances identified on a noncompliance record (NR) according
to FSIS PHIS Directive 6410.1 and FSIS PHIS Directive 5000.1, Verifying an Establishment’s
Food Safety System including associating noncompliance records (NRs), where appropriate.
D. Examples of situations when it is appropriate for IPP to associate NRs include:
1. Two or more NRs documented while performing the Beef Sanitary Dressing task;
2. One NR indicates that the establishment’s corrective actions for a previous sanitary
dressing NR were not implemented or did not prevent recurrence; and
3. One or more NRs in response to a positive FSIS STEC result in trimmings.
E. When the information gathered suggests that the establishment has lost process control, IPP
are to determine whether the establishment has taken corrective actions to bring the process
back under control. IPP are to verify that the establishment’s corrective actions are effective
and prevent recurrence. IPP are to consult with their immediate supervisor for assistance in
making this determination, if needed. IPP are to request a for-cause FSA through supervisory
channels if the establishment repeatedly fails to take corrective action, or if the corrective actions
the establishment takes are ineffective. Examples of the types of findings that can indicate a loss
of control are provided in Section VIII of FSIS PHIS Directive 6410.1. Specific findings in FSAs
that have evidenced that veal slaughter establishments were losing process control include:
1. Multiple positive STEC results in raw beef manufacturing trimmings from FSIS routine
and follow-up samples;
2. Generic E. coli results from establishment testing that indicate increasing microbial
contamination on carcasses; and
3. An establishment not evaluating testing results, including generic E. coli on carcasses
and STEC on beef manufacturing trimmings, to help determine how the results impact
veal slaughter operations.
F. Attachment 1 provides information on and examples of sanitary dressing deficiencies and
ineffective application of interventions that have been observed at veal slaughter
establishments. IPP are to use the information in Attachment 1 to assist them in verifying
sanitary dressing in veal slaughter establishments.
G. If the establishment’s slaughter and sanitary dressing procedures are out of control, the level
of contamination may affect IPP’s ability to perform proper post-mortem inspection procedures.
The Public Health Veterinarian (PHV) or Inspector-in-Charge (IIC) is to determine whether this
is the case. If it is, the PHV or IIC is to reduce the line speed in accordance with 9 CFR
310.1(b)(1). (See Section XI. E. of FSIS PHIS Directive 6410.1 Verifying Sanitary Dressing and
Process Control Procedures by Off-line Inspection Program Personnel (IPP) in Slaughter
Operations of Cattle of Any Age)
V. SUPERVISORY PERSONNEL RESPONSIBILITIES
A. “Supervisory personnel” refers to any Office of Field Operations (OFO) personnel that
supervise IPP who conduct off-line verification activities in cattle (including veal) slaughter
operations.
B. Supervisory personnel with one or more veal slaughter establishments within their circuit are
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to conduct a work unit meeting with IPP assigned to veal slaughter establishments. Supervisory
personnel are to review the inspection methodology in FSIS PHIS Directive 6410.1 and the
information in this Notice.
C. Supervisory personnel are to conduct an on-site visit to veal slaughter establishments in
their circuit within 90 days of this issuance.
D. Supervisory personnel are to ensure that IPP are correctly prioritizing inspection tasks, are
correctly applying the inspection methodology, are making informed decisions, are properly
documenting findings, and are taking the appropriate enforcement actions as instructed in this
notice and FSIS PHIS Directive 6410.1.
E. Supervisory personnel are to refer to the current version of the FSIS Guide for Conducting
In-Plant Performance System (IPPS) Assessments for additional guidance and instructions.
VI. DATA ANALYSIS
Members of the Risk, Innovations, and Management Division (RIMD), Office of Policy and
Program Development, will analyze data from Shiga toxin-producing Escherichia coli (STEC)
sampling programs and Food Safety Assessments (FSA) performed at veal slaughter
establishments to determine whether veal slaughter establishments have adequately
addressed hazards. RIMD will analyze data to determine whether the frequency of sanitary
dressing verification for veal should be different than other cattle slaughter classes.
Members of the Data Analysis and Integration Group (DAIG), Office of Data Integration and
Food Protection, will analyze PHIS data to determine whether IPP at veal slaughter
establishments performed the beef sanitary dressing task at the increased frequency.
VII. QUESTIONS
Refer questions regarding this notice to the Risk, Innovations, and Management Division
through askFSIS or by telephone at 1-800-233-3935. When submitting a question, use the
Submit a Question tab, and enter the following information in the fields provided:
Subject Field: Enter FSIS Notice 20-13
Question Field: Enter question with as much detail as possible.
Product Field: Select General Inspection from the drop-down menu.
Category Field: Select Sampling E. coli O157:H7 from the drop-down menu.
Policy Arena: Select Domestic (U.S.) Only from the drop-down menu.
When all fields are complete, press the Submit button.
Assistant Administrator
Office of Policy and Program Development
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Attachment 1 Observed Sanitary Dressing Deficiencies and Ineffective Application of
Interventions at Veal Slaughter Establishments
FSIS conducted a review of Food Safety Assessments (FSAs) and onsite visits to identify
concerns unique to veal slaughter. The results of the review indicated that many veal slaughter
establishments have not implemented sanitary dressing and process control procedures
sufficient to prevent carcass contamination and the creation of insanitary conditions.
This attachment includes examples of sanitary dressing deficiencies and ineffective application
of interventions that FSIS observed repeatedly during on-site visits. IPP are to use this
information in conjunction with the inspection methodology in FSIS PHIS Directive 6410.1 to
assist them while verifying sanitary dressing in veal slaughter establishments. The attachment
includes the relevant section (slaughter process step) in FSIS PHIS Directive 6410.1 to
facilitate this process.
Sticking
In this photo, we see that the establishment uses a large cut to bleed the calf, and that ingesta is
leaking from the esophagus during bleeding (yellow arrow). FSIS observed employees cutting
through the weasand (esophagus) during sticking. This practice resulted in ingesta
contaminating the carcass and head. FSIS also observed employees removing the head
without closing the weasand. FSIS recommends that the establishment use the smallest cut
possible to accomplish bleeding and not to cut the weasand during sticking and bleeding. FSIS
recommends that establishments close the weasand after rodding prior to head removal.
Photo 1 Cutting through the weasand (esophagus) during sticking
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Hide removal
Onsite visits to veal slaughter establishments and reviews of FSAs showed that
establishments were cutting through the hide and further dressing the carcass without sanitizing
knives, gloves, and equipment adequately to prevent the creation of insanitary conditions. An
example would be an employee making a “dirty cut” (one through the hide, left photo) and
continuing to cut through aitchbone (yellow arrow) without sanitizing the knife after making the
dirty cut. Another example (not pictured) of this would be a veal slaughter establishment further
processing veal carcasses with the hide-on. Proper hide removal is a critical step in preventing
carcass contamination and the creation of insanitary conditions. While opening the hide (except
for the original incisions for sticking and starting the skinning operations at the poll and shanks),
FSIS recommends that the employee direct the knife blade toward the hair side of the skin to
prevent contaminating the flesh with cut hair (not shown). After making the “dirty cut” and
exiting the hide, FSIS recommends that the employee sanitize his knife and glove before
making another cut (in this case, cutting through to the aitchbone, right photo).
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Bunging
This concept of sanitizing after the “dirty cut” can also be seen with bunging. The employee
makes the “dirty cut,” in this case cutting around the tissue surrounding the anus (yellow arrow,
top left photo). The employee then sanitizes his knife and gloves before further cutting the
exposed tissue ( top right photo). FSIS recommends that establishments remove the hide prior
to cutting into the carcass. Tying and bagging the bung (not shown) is also an important step to
preventing carcass contamination.
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Bunging
These photos show the impact of the establishment failing to bag and tie the bung. The
contaminated bung is contacting the exposed carcass (yellow arrows). When establishments
apply hot water or antimicrobial interventions to an exposed bung, it further spreads
contamination. FSIS recommends that establishments tie and bag the bung in a sanitary
manner.
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Hide removal
Legging
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These photos show the “legging” process, a part of the hide removal process during which the
establishment personnel remove the hide from the hindlimbs. Establishment personnel may
introduce contamination at the pattern lines (along the incision lines through the hide, as the
arrows show in the two bottom pictures). It is important that establishments prevent
contamination throughout the slaughter process and remove contamination promptly when it
occurs. The establishment can do this through knife trimming or steam vacuuming.
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Hide Removal
Sanitize and Remove Debris from
Steam Vacuum
Steam vacuuming is a useful intervention for establishments to apply along the pattern lines and
for removing incidental contamination. FSIS observed (not shown) employees applying heavily
contaminated steam vacuums to carcasses. The purpose of these photos is to remind IPP of
the importance of cleaning and sanitizing equipment as often as necessary to prevent the
creation of insanitary conditions and cross contamination.
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Hide Removal
These photos show hide and hair touching the carcass when being removed, potentially allowing
the dirty exterior side to touch the carcass. In the bottom left photo, the leg hide flaps are
contacting the carcass. The bottom right photo shows hide flaps that have curled under after
hide removal (as seen inside the yellow oval) and are contacting the carcass. FSIS
recommends that establishments prevent the hide from contacting the carcass during hide
removal. The photo below shows the use of hide clips as one method of preventing hide from
contacting the carcass.
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Evisceration
These photos show the establishment puncturing the paunch and intestines during evisceration
(top photo, at blue arrow) causing carcass contamination with ingesta (bottom photo, inside
yellow oval). FSIS recommends that establishments perform proper sanitary dressing
procedures during evisceration to prevent puncturing the paunch and intestines.
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Hide removal (wash cabinets)
This photo shows cross contamination of heads from a spray applied to the carcass (water
sprayed onto carcass in the direction of the arrows, water spray seen within the yellow oval).
The establishment failed to take measures (e.g., adequate distance or shields) to prevent cross
contamination of adjacent heads. Cross contamination (not shown) can also occur while
employees spray equipment, the floor, and other surfaces if the establishment does not take
appropriate precautions to prevent overspray from contacting carcasses. Also, it is important
that carcasses are free of visible contamination prior to entering wash cabinets or the manual
application of water or antimicrobial sprays. Otherwise, the intervention could further spread the
contamination.
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Establishment Interventions
Failure to Implement Interventions
Effectively
These photos show the practice of suspending a carcass from a single hook, which prevents
antimicrobial and hot water interventions from achieving carcass/product coverage. Carcass
coverage –ensuring that the entire carcass surface is treated -- is necessary for the intervention
to operate effectively and as intended. Additional information is included in FSIS Notice 17-12
Verification of Antimicrobial Intervention Coverage of Carcass or Product at Veal Slaughter and
Beef Fabrication Establishments. IPP verify that establishments are implementing their
interventions effectively (i.e., according to the establishment’s scientific support) during the
observation component of the appropriate Hazard Analysis and Critical Control Point (HACCP)
verification task.
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Establishment Interventions
These photos show the establishment’s failure to implement its trim antimicrobial intervention
spray effectively. The intervention did not achieve full product coverage. Product coverage is
essential for the intervention to be effective. Both pictures show that the establishment only
applies the intervention to the top side of the trim. These pictures also show product that is
folded on top of itself so that not all product surfaces received the intervention (in the left picture
each piece has a single fold, and in the right picture the trim is piled up). The picture on the
right shows clearly that the arc of the spray nozzles (inside each yellow line) is not sufficient to
reach product on the sides of the conveyor belt (yellow arrows).
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Results of Sanitary Dressing
Deficiencies and Ineffective
Application of Interventions
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In these photos, we see contamination in the bung area (top left photo), boneless veal legs (top
right photo under arrow), breast and shank areas (middle photos under arrow and within ovals),
and along the thigh (bottom photo). This contamination resulted from the establishment’s failure
to implement sanitary dressing procedures to prevent the creation of insanitary conditions and
contamination of carcasses, and its failure to implement antimicrobial interventions effectively.
Positive STEC test results are a reflection of an establishment’s slaughter controls and provide
evidence that the establishment is not implementing its slaughter controls effectively to produce
safe, unadulterated products.
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