Source:  Rita Jane Gabbett, MEATINGPLACE.COM, 4/2/10

Meat processors and the organizations that represent them have been scrambling in recent weeks to understand and respond to new Food Safety and Inspection Service proposals that would mandate more in-plant validation of both critical control points in HACCP plans and prerequisite programs.

Kansas State University's Regent's Distinguished Professor of Meat Science James Marsden is a food safety expert who also works with meat processors on food safety interventions. Meatingplace asked him to weigh in on the debate about the new rules.

What are your thoughts on USDA's proposals on in-plant CCP validation and validation of prerequisite programs?

For a long time USDA has focused on just determining whether or not plants had HACCP plans that meet the minimum regulatory requirements. Now they are evaluating those HACCP plans to see if they really are controlling hazards and assuring the food produced under those plans is safe. So, from USDA's point of view, it is a logical progression.

The whole point of having a HACCP plan is to ensure you are producing safe food. In order to do that, you have to have critical control points that are valid and proven.

Retailers and others also are recognizing the importance of this, and I think you will see a lot of movement in this area over the next several months or even weeks. We may see retailers asking their suppliers to show that their critical control points are providing safe products.

Are you saying that regardless of what USDA does, processors may see their customers asking for more proof that their CCPs are working?

Yes. In fact, I know they are going to do that. I'm certain of it.

For the last 10 or 12 years further processors have had this problem. They are buying raw materials from (slaughter) plants that operate under HACCP plans that are USDA inspected, and yet they are contaminated. So it seems to me that they should really welcome (these USDA proposals) in terms of how they would be implemented in slaughter plants. The bigger problem is in slaughter plants where you've got product that is contaminated getting into commerce and (further processors) pay the price for that. They are not putting salmonella or E. coli on their product; it's coming in that way.

One concern for medium-sized further processors is how they implement in-plant validation testing when they might be making 100 different ready-to-eat products?

They have to categorize their products. Say they are producing 100 products and 90 of those products are cooked. Their critical control point is thermal processing. They need to validate that their thermal process is sufficient, which may be done very easily by a combination of evaluating the scientific literature then just going through their process and making sure they are always reaching that temperature and providing historical data to support that. Then, 90 of their products will be validated.

So, is it your understanding they can use historical data rather than doing an in-plant validation?

It comes down to how you define in-plant validation. When Dr. (Dan) Engeljohn spoke at NAMP in Chicago in March, he said plants often have the data; they just are not putting it together in the correct manner. It could be taking historical data from a file and turning it into a report, a validation study. They need to put their existing data together in a way that gives it some scientific validity.

Say a processor has a smokehouse and they probe it at 10 different spots over a 30-day period and show that every day, every time, they are reaching 160 degrees. That's historical data, but it is also a validation study. I honestly think in most cases it's going to be more rethinking what they are already doing and putting it into the right format to show their process is valid.

Another concern is how to achieve a one- log reduction of microbial counts, particularly if the raw product is already clean. What's your advice on that?

In some cases there won't be a one- log reduction. If the product comes in at less than one log contamination or aerobic plate count, there isn't even one log to remove. They will have to look at a percentage reduction, look at real numbers instead. I think that is sort of an academic question, especially if you are using an aerobic plate count. There should usually be enough there to show a reasonable reduction.

Processors are also concerned about the proposed rules around validating prerequisite programs. How does a plant go about doing that?

I don't think USDA is saying you have to validate all of them, only programs that are tied to HACCP plans. Say, for example, a plant is using nitrite, which is a potential chemical hazard. Nitrite control may not be included as a CCP because it is addressed in a prerequisite program. If a plant inadvertently mixed up nitrite and salt and used too much nitrite, a significant hazard would be created. Under USDA's validation initiative, the plant will have to show this cannot occur because their prerequisite programs make it impossible.

For example, receiving nitrite in pre-measured packets, rather than coming in a drum that might look like salt could be the prerequisite. That, along with employee training and other measures, could prove the efficacy of that prerequisite program.

If you are not going to have a critical control point to address a hazard because you have a prerequisite program identified, it's reasonable for USDA to ask you to show that program is effective.

Let me give you another example. A company I work with uses UV to treat their primals before they tenderize them. To validate that process, on three different days we took 10 subprimals and cut them in half. We put half through the UV system and half we did not. We then measured the plate count before and after the treatment and measured the reduction. It was simple. It cost less than $1,000 to do the entire study. And USDA accepted their validation.

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