HACCP In The Meat And Poultry Industry

HACCP in the meat and poultry industry: R.B. TompkinBrtifngC RouingTranxportingStunning] .- 1]G holdingC KillingC dohairingScaldingISingoingC polfxhing’--b?Ramovxl ofintwtfnw?0Excisionof tongueC tonxilxbpEEzycutting/Daboaingmvxlof head moat?1ChillLagIIvmodprocommiag/preparation?Figure2 Flow diagram for production and processing of pork products. ?, Sites where major contaminationexpected to occur. Lnn. mandibulares, mandibular lymph nodesapplied to control T.spiralis in porkproducts in Europe and North America do not apply inAustralia where T.spiralis does not exist.The primary goal of farmers is to achieve efficientfeed conversion and sufficient disease control tomaintain a favourable health status and maximize thegrowth rate of the animals. Human pathogens (e.g.salmonellae, C. jejuni) can be introduced into theanimal population from a variety of sources. Thepotential for higher carrier rates of these pathogens canincrease due to stress and crowding as the animals arecollected in pens and transported to the slaughteringplant. Other factors (e.g. age of animals) also canaffect the carrier rates of human enteric pathogens.Chemicals (e.g. pesticides, antibiotics) used by farmersmust be properly applied to avoid unacceptable residuelevels in meat. The risk of chemical residues is bestcontrolled through continuing education of farmers andan appropriate level of testing to verify compliance.Two fundamentalconcepts must be consideredduring the slaughtering process. First and foremost isthe use of procedures which will minimize the degree ofcontaminationon carcasses during the slaughteringprocess.This may involve training workers inthe proper use of knives and equipment, providingadequate work space and time to perform each functionrestrictions156Food Control 1994 Volume 5 Number 3with Y. enferocoliticu 0:3 iscorrectly, providing a plant layout that favours microbial control, and selecting equipment which is readilycleanableand which minimizescontamination.Research may be necessary to reduce contaminationbelow current levels. For example, more improved,cost-effectivetechnology is needed to hygienicallyremove feathers from poultry and hair from hogs. Thesecond concept has been gaining increasing acceptancein recent years by industry and regulatory officials.That is to include procedures (e.g. spraying withorganic acids) which can remove and/or destroy pathogens which inadvertentlycontaminatethe carcassduring slaughtering (Dickson and Anderson, 1992).When properly designed and implemented these decontamination procedures can enhance the safety offresh meat beyond that which can be accomplishedby relying solely upon preventing contamination. Additional research to develop more effective methods fordecontamination should be encouraged by Codex andnational regulatory agencies.After eviscerating and chilling, the carcasses oftenare cut into various sections of meat. In the example ofFigure I, deboned meat is selected for processing into acooked meat or poultry product. The species of meat(i.e. beef, pork, chicken) must agree with the ingredient statement on the package because some indi-

HACCP in the meat and poultry industry: R.B. Tompkinviduals are sensitive to certain types of meat. For thisreason species control is a CCP. A curing solution isprepared and injected into the meat to achieve thedesired level of ingredients. The quantity of nitriteadded is a CCP because excessive quantities can betoxic to consumers. The level of nitrite can be controlled through the use of a preblended nitrite-curingsalt. Other measures also can be effective. Both thetype of meat and the nitrite content can be effectivelycontrolled (CCPl).In this example, the meat is tumbled under vacuumin a chamber and then filled into a can, casing, mouldor other container for cooking. The meat is heatedsufficiently to destroy non-spore-formingpathogensand then chilled at a rate that will prevent theoutgrowth of surviving spores. After chilling, theproduct is removed from the container, sliced, vacuumpackaged and placed into shipping cartons for storingand distributing. The packages and cartons are labelledwith appropriate statements (e.g. ‘keep refrigerated’)to inform distributors, retailers and food handlers ofthe necessity for keeping the product cold. The conditions of holding, slicing and packaging the ham aftercooking is critical to minimize the risk of contaminationwith pathogens such as salmonellae and Listeria monocytogenes. Experience indicates that post-process contamination with salmonellae can be prevented (CCPl)(Tompkin and Borchert, 1992) whereas contaminationwith Listeria monocyfogenes can be minimized (CCP2)(Tompkin et al. 1992). The latter psychrotrophicpathogen is more difficult to control in the cookedproduct environment. HACCP has been recommendedto control L. monocytogenes and assure the safety ofprocessed meat and poultry products (WHO, 1988;NACMCF, 1991; ICMSF, 1994).Figure I contains four CCPs which can provideeffective control (CCPl). One involves formulating theproduct correctly to control the species of meat and thequantity of nitrite. Another is for cooking because iteffectively destroys non-spore-forming pathogens. Theremaining two are for chilling. When properly controlled the chilling of carcasses is effective for preventing the multiplication of pathogens. The other involveschilling the cooked meat or poultry product. In thiscase, the rate of chilling can be controlled to preventthe outgrowth and multiplication of spore-formingpathogens which survive cooking.Physical hazards (e.g. metal, bone, plastic, wood,glass) must be controlled by applying preventivemeasures which minimize their introduction into theproduct via the raw materials and during the processingsteps prior to cooking. Possible product contaminationwith metal can be monitored by passing the packagedproduct through a metal detector.AREAS WHEREFURTHERINFORMATIONOR STANDARDIZATIONMAY BEHELPFULPrinciple 4 of the current Codex document on HACCP(Codex, 1993 ) should be modified to incorporate animportant aspect of HACCP. As currently stated, theemphasis of Principle 4 is on monitoring (i.e. checking)whether CCPs are under control. Instead, the results ofmonitoring should be used to make adjustments inprocesses to ‘prevent loss of control’, not ‘regaincontrol’. If control has been lost, then a deviation willhave occurred and specific corrective ‘action will benecessary (Principle 5). It is in Principle 4 thatdetection and prevention are combined ‘to prevent lossof control and deviations from occurring.It is necessary that educational materials begin to bebased upon one common understanding #ofthe HACCPprinciples and definitions; otherwise, continued confusion will be detrimental to the acceptance of HACCP.With recent agreement on the principles of HACCPstandardized teaching materials, such as the WHOdocument on training (WHO, 1993), can provide auniform basis for educational programs on an international level.The question of education raises the issue of certification. Is it necessary or desirable to certify individualsor processing facilities for having met certain basicrequirements? Should educational courses on HACCPbe certified if they meet certain standards? Should thegraduates of such courses be certified? Should foodestablishments be required to employ or have availablefor consultation a person who is certified in HACCP?These issues must be resolved at a national rather thanan international level.Verification (Principle 6) is an important aspect ofHACCP. In fact, the major role of regulatory agenciesin facilities with HACCP plans should be to verifywhether HACCP plans are complete, accurate andbeing correctly followed (NACMCF, 1994a, 1994b).Periodic verification also is a responsibility of theHACCP team. Some companies have representativeswho visit facilities for periodic reviews. With so manygroups involved in verification activities a standardizedchecklist could be helpful. 7’uble I contains a generalquestionaire which can be used to facilitate thesereviews. The questionaire also can be helpful to theHACCP team as it develops its HACCP plan(s) oras it prepared for verification activities by outsideinspectors.POTENTIALHACCPPROBLEMSIN THEUSE OFA number of issues must be resolved during thetransition from traditional inspection to inspection ofmeat and poultry facilities which have HACCP plans(Tompkin, 1990). One significant factor affecting theacceptance of HACCP by industry and governmentinspectors is job security. As HACCP plans becomeimplemented there is less emphasis on end-product’inspection and testing. The responsibility for assuringproduct safety, and other product attributes, shouldshift to production personnel who actually monitor andFood Control 1994 Volume 5 Number 3157

HACCP in the meat and poultry industry: R.B. TompkinTable 1 General questionaire for use in HACCP verificationName of plant:Date of review:Who is on the HACCP team?Who is the HACCP team leader?Is there a HACCP plan for each process?Is there a flow diagram for each process?Is a simple plant layout available?Review the layout. Does the flow of product and people minimizethe possibility of cross-contamination?Who was responsible for identifying hazards and critical controlpoints (CCPs)?Does that person qualify as an expert in hazard analysis for thetype of foods and food processes in the facility?Have critical limits been established for each CCP in eachHACCP plan?Who established the limits?What rationale was used for the critical limits?Who approves a change in a CCP? Is the change documented?Select a HACCP plan and review the current process flow. Doesit agree with the HACCP plan?Who monitors the CCPs?Do they understand their role in the HACCP plan?Is the monitoring done according to the plan?Are the results recorded?Who verifies that the CCPS are being monitored correctly?Do the operators know the critical limits and when a deviationoccurs?Do the operators know how to adjust the process to prevent adeviation or does this occur automatically?What happens when a deviation occurs?Is a plan in place to address deviations at each CCP?How is management notified of a deviation?Are corrective actions for deviations recorded?Is a deviation log book or similar central record being maintained?Who is responsible for making decisions on corrective actions?Where are the HACCP plan records maintained?Are the records available for verification (can they be seen andreviewed)?Are all records pertaining to CCPs available?Where and how long are they kept?Who is responsible for maintaining the records?Is the effectiveness of the HACCP plan verified by any physical,chemical or microbiological testing?Who collects and interprets the data from tests which areperformed for verification?Who receives the test results?Do the plant manager and his/her staff understand the HACCPconcept and support the plant’s HACCP system?Are those who are directly involved with CCPs adequatelytrained?Who is responsible for training?Does the plant have someone on staff who has attended a coursein HACCP?On the basis of your review is the HACCP plan complete,accurate and being correctly followed?Do you have any recommendations for correction or improvement?control the process. The role of traditional inspectorsshould shift toward verification activities. This canresult in fewer inspectors being required in plants thathave effective HACCP plans. This could result insignificant changes in the meat and poultry industrywhich, in many countries, traditionally has receivedmore intensive regulatory inspection than other foodindustries.A second significant issue in the meat and poultryindustry concerns expectations. As the potential valueof HACCP becomes more widely recognized, there is atendency to oversell the benefits of HACCP, particularly to consumers and legislators. This stems from158Food Control 1994 Volume 5 Number 3failure to acknowledge the existence and distinctionbetween CCPl and CCP2 (ICMSF, 1988). A CCPl is aCCP that will assure control of a hazard. A CCP2 is aCCP that will minimize but cannot assure the control ofa hazard. Thus, certain hazards can be minimized butnot prevented.The new draft revised code of hygienic practice forfresh meat (Codex, 1993a) clearly states throughout thedocument that some level of contamination will occurduring the slaughtering process but conditions shouldbe such that the contamination is held to a minimum.Thus, the Codex document fully recognizes the existence of CCP2 at many steps in the process of convertinglive animals into fresh meat. The adoption of HACCPwill not eliminate all hazards because current technology is inadequate to reach this desirable goal. Theabsence of an effective kill step (e.g. pasteurization,cooking) during slaughtering means that raw meat andpoultry may harbour some level of pathogens. Theadoption of HACCP can lead to a reduction, but notthe elimination of enteric pathogens (i.e. salmonellae,C. jejuni, Y. enterocolitica, E. coli 0157:H7), sporeforming pathogens (e.g. C. botulinum, C. perfringens,B. cereu.s) and certain parasites. Thus, proper handlingand preparation of meat and poultry products by thefood preparer is essential for food safety.Recognition that carcasses may harbour microbialpathogens has led some to believe that rapid tests areneeded to detect pathogens on carcasses. Such testscould qualify as monitoring procedures if the resultsbecome available before the carcasses are shipped fromthe plant. This presumably would permit the processorto subject carcasses which test positive to some additional process to eliminate the pathogens or, perhaps,divert the meat to a processor who would use the meatin a cooked product. This approach, however, overlooks the weakness that no feasible sampling plan canguarantee the absence of a pathogen. Also, in the eventthat an enteric pathogen is found, then how manycarcasses must be diverted? Which carcasses areunacceptable - those that were tested, all carcassesfrom the same farm or all the carcasses processed thathour, shift or day? The long-term solution to entericpathogens lies not in testing carcasses but in controllingthe pathogens at the farm plus impoved technologyduring slaughtering.Other problems must be resolved as HACCPbecomes more widely adopted. As HACCP becomesincorporated into the regulatory inspection processthere will be disagreementsover whether certainhazards of potential significance are likely to occur in aprocess and whether certain steps in the process areCCPs. These debates will be influenced by existingknowledge and the conservative nature of the partiesinvolved.Decisions over the risk of a hazard and whether aprocessing step is a CCP are best made by an ‘expert inhazard analysis’. These experts are individuals with theknowledge and experience to correctly: (a) identifypotential hazards; (b) assign levels of severity and risk;

HACCP in the meat and poultry industry: R.B. Tompkin(c) recommend controls, criteria and procedures formonitoring and verification; (d) recommend appropriate corrective actions when a deviation occurs;(e) recommend research related to the HACCP plan ifimportant information is not known; and (f) predict thesuccess of the HACCP plan (NACMCF, 1992). Unfortunately, at this time there is an insufficient number ofexperts in hazard analysis available to assist in thedevelopment and assessment of HACCP plans.Wider use of HACCP will result from supplierbuyer relationships. Some buyers of meat and poultryproducts now require the use of HACCP plans bysuppliers; perhaps, even requesting that supplierssubmit a copy of their HACCP plan. Such a request isunacceptable for two reasons. First, HACCP plans areunique to each operating facility and are of value onlywhen reviewed for accuracy and completeness during avisit to the plant. Second, HACCP plans containimportantproprietaryinformationconcerning theplant’s operating procedure.Careless or unethicalsharing of the HACCP plan with other potentialsuppliers could occur. HACCP plans should be available for buyer review only at the plant.The generic HACCP plan as described above and inFigure I shows eviscerating as a CCP. In reality thereare many steps involved between when the hide, hair orfeathers are removed and when the carcass is chilled.Thus, decisions should be made whether any of thesesteps are CCPs. The Codex HACCP decision treewhich was developed to help decide whether the stepsin a process (e.g. slaughtering) are CCPs can lead todebatable results. The first question the decision treeasks is whether preventativemeasures exist. Theresponse should be, yes, measures do exist to minimizecontamination(Ql yes).The second question ispivotal with the answer depending upon one’s view ofan ‘acceptable level’. It is possible to specifically designand control certain steps in the slaughtering process tominimize carcass contaminationwith enteric pathogens. The acceptable level should be the minimum levelthat can be consistently achieved for a facility when theprocess is under control. The acceptable level in onefacility may differ from another facility. Failure tocontrol a specific step could result in a higher level ofcarcass contamination.In agreement with the Codexcode of hygienic practice for fresh meat (Codex 1993a)the conditions should be such that the level of contamination is held to a minimum. Thus, it must beconcluded that certain steps in the slaughtering processcan be CCPs (Q2 yes). This conclusion should be theone favoured by most proponents of HACCP, including those who are redrafting the code of hygienicpractice for fresh meats.If, on the other hand, an unrealistic position is takenthat no contamination is acceptable, then the answer toquestion 2 becomes no (Q2 no). Under a zerotolerance, any contamination at a step would be inexcess of the acceptable level (Q3 yes). Since asubsequent step (i.e. cooking) can eliminate the hazardof enteric pathogens (Q4 yes), this could lead to theconclusion that under a zero tolerance for carcasscontamination none of the steps in the slaughteringprocess are CCPs.The answer to question 2 of the decision tree also canlead to another conclusion depending on one’s view of‘specifically designed’. Many of the steps in theslaughtering process can be controlled to minimizecontamination even though they may not be ‘specifically designed’ to do so. Since these steps are not‘specifically designed’ to eliminate or reduce contamination with enteric pathogens, the answer to question 2is no (Q2 no). The response to question 3 is yes(Q3 yes). The decision tree would suggest that thecontamination which may occur at these steps is oflittle, or no, concern because a subsequent step (i.e.cooking) will eliminate the hazard of exaessive levels ofenteric pathogens on carcass meat. Thus, the steps inslaughtering which are not ‘specifically designed’ toeliminate or reduce contamination with enteric pathogens are not CCPs. Perhaps this was the intended resultof those who designed the decision tree. On the otherhand, since these steps are not CCPs they may receiveless attention and, thus, less effort to control the levelof contamination.Two variations of question 4 of the Codex decisiontree have been proposed which place even greateremphasis on the role (i.e. responsibility)of theconsumer for eliminating the hazards associated withcontamination that may occur during slaughtering. Oneasks, ‘will subsequent processing inaluding correctconsumer use, guarantee removal of the hazard orreduction to a level regarded as safe?‘, (Mayes, 1992).The other asks ‘will subsequent processing stagesincluding expected consumer use, guaradtee removal ofthe hazard or reduction to an acceptable level?’ (ILSIEurope, 1993). This is unfortunate because controlshould be exercised wherever possible during varioussteps in the slaughtering process to minimize contamination, even though cooking by the consumer will killenteric pathogens. The potential for cross contamination from raw meat and poultry to ready to eat foods inthe kitchen must be considered. The higher the level ofcontamination during slaughtering, the #greater the riskof

plan and see that it is correctly implemented. When developing a HACCP plan, a generic HACCP plan can be used for guidance. The plant must customize the plan to its own specific conditions, however, because each HACCP plan must addre