Final Report for SW09-601
Alterations in food safety requirements challenge the ability of small processors to remain sustainable. New requirements from USDA require small and very small meat processors to validate food safety processes. Small processors do not have the technical skills to conduct validation studies to meet the new requirements.
Six processors had E. coli O157:H7 interventions currently being used in plant validated and four plants had generic validation of Fully Cooked Not Shelf-stable HACCP plans. There is a reduction in all plants when the intervention is applied or cooking is done.
This grant is a post-subregional conference grant and not the standard education grant. The proposal requirements did not have an objectives/performance category.
Goals of the Project
A growing number of consumers desire to buy locally grown and processed. Changes in inspection rules challenge the abilities of small processors to remain competitive and sustainable. These small processors are crucial to increased production of locally grown and processed foods. Working hand-in-hand with ranchers, this local movement strengthens the competitiveness of the local producers. This project will help strengthen the infrastructure of the small local processors and help local ranchers fill the consumer demand for local products.
The production of products for sale locally helps to improve the local economy by allowing the producer and the processor to capture part of money normally sent out of state when calves and lambs are sent to the Midwest to finish and harvest. It has been estimated that every job added to the agricultural sector results in almost 100 jobs in allied fields. Improvement in job opportunities for local ranchers and meat processors would result in increased local job opportunities in other sectors, thus increasing the sustainability of rural communities.
Demand for locally produced product is increasing, but it is essential that these producers and processors put food safety first. Companies that cannot produce safe product will not survive in the new market place. Consumers are starting to vote with their food dollars; in 2006 less than 10% of the consumers stopped buying products because of food safety scares. In contrast, over 30% of consumers stopped buying a product because there were questions about its safety in 2007. For ranchers and small meat processors to succeed in the local market they must produce a safe food product. This project will give the processors the tools to monitor microbiology on meat products to help insure the safety of products produced. The processors will also have the documentation and written processes to satisfy requirements of inspection.
Alterations in food safety requirements are challenging the ability of small processors to remain sustainable. New requirements from USDA will require small and very small meat processors to conduct some microbial testing or utilize scientific papers to confirm the processes that they use are effective in reducing the number of E. coli O157:H7 on carcasses and processing procedures used are effective in reducing pathogens such as E. coli O157:H7 and Salmonella in fully cooked products. Small processors do not have the technical skills to conduct their own validation studies and often need help interpreting scientific papers for use to validate their processes. They also do not have the technical skills to develop statistical sampling plans to meet any new requirements USDA may choose to add to the requirements. Also, introduction of an outside professional entity in the documentation, development of procedures and testing helps to strengthen the information in regulatory eyes. For processors to remain sustainable, it is imperative that the plants validate the processes they currently are using, develop written procedures they can include in their food safety plans to ensure continued safety of products for the consumer and provide some statistical justification to their sampling plans.
Current regulations have taken a one size fits all approach, not recognizing that very small processors are not producing the volume of product that larger processors manufacture. These large plants also have technical people that have been trained in microbiology or meat science to conduct the validation studies and find scientific documentation required by USDA. Small processors need help from University personnel who have been trained in the science of data collection to develop a process to prove that their procedure is acceptable or make sure they are following published scientific research to produce safe products.
Increased concentration of supermarkets has led to an increased desire for locally grown and processed products. With the concentration of meat processing facilities, there are more producers who desire to capitalize on the locally grown market. Small local processing facilities are an integral part of the new move toward local production. Many of the small processors are working with local ranchers to produce products for regional and local markets.
However, consumer concerns for food safety and small plant compliance with new federal guidelines requires a level of testing and monitoring common and easily accomplished in large plants but a major obstacle to the viability of small local processing facilities. This project partners the expertise at the Montana State University Meat Lab with the needs of local Montana processors and the State Inspection program in a manner that educates and helps processors comply with new federal regulations assuring a safe locally processed meat product.
The processors supplied the information of what processes were currently used in the plant. They allowed the researcher to come into the plant, sample carcasses and sample raw and cooked of a fully cooked not shelf stable product to help validate the individual process in the plant. Once the data was analyzed, the information was given back to the processors, and they should integrate the information into their current food safety system to validate or improve the processes they are already doing.
All carcasses harvested within a plant in a day were sampled on three or four occasions. Carcass surface sampling was done using sponge-sampling kits obtained from commercial suppliers (3 M Microbiology, St. Paul, MN). The sampling procedure involved swabbing 10 cm2 areas at three carcass sites (flank, brisket and rump) as described by the USDA/FSIS for conducting generic E. coli testing as part of the final rule (Food Safety and Inspection Service, U.S. Dept. of Agriculture 1996). The 3.5 x 7.5cm sponge was moistened with supplied buffered peptone water (BPW). The sponge was then used to swab 10 times back-and forth horizontally and 10 times up-and-down vertically over a 10 x 10 cm area on each of the three designated surfaces of the carcass. The same side of the sponge was used for sequential swabbing of the flank and brisket. The other side of the sponge was then used for swabbing the rump. Following swabbing, the sponge was returned to the sampling bag. Samples were transported in coolers containing ice packs to the laboratory and immediately refrigerated for analysis within 24 hours. At the laboratory, the sample bag containing the sponge was stomached for two minutes at 230 rpm using a Stomacher 400 (Seward, Fisher Scientific, Itasca, IL, U.S.A.) and as much diluent as possible was expressed from the sponge by manually squeezing the bag. From the expressed diluent, serial dilutions were prepared using Butterfield’s phosphate diluent (3M Microbiology, St. Paul, MN, U.S.A.). Using the expressed diluent and serial dilutions, 3M Petrifilm E. coli/ Coliform Count plates (PF-EC; 3M Microbiology Products, St. Paul, MN, U.S.A.),3MPetrifilm Enterobacteriaceae Count plates (PF-EB; 3M Microbiology Products, St. Paul, MN, U.S.A.), and 3M Petrifilm Aerobic Count Plates (PF-AC; 3M Microbiology Products, St. Paul, MN, U.S.A.) were used for enumeration of indicator bacteria, with one plate prepared per dilution for each analysis. The PF-EC and PF-EB plates were incubated at 35?C for 24 hours and the PF-AC plates were incubated at 35?C for 48 hours.
Counted E. coli colonies on PF-EC plates are blue and associated with entrapped gas, within approximately one colony diameter. Coliforms enumerated on PF-EC plates included E. coli colonies as well as red colonies, which are associated with entrapped gas, within approximately one colony diameter. Counted Enterobacteriaceae colonies on PF-EB plates are red and fall into one of three categories: colonies associated with gas bubbles and no yellow zones of clearing, colonies with yellow zones of clearing (indicative of acid production) but no gas production, or colonies producing both gas and acid. All red colonies are counted on PF-AC plates, regardless of their size or the intensity of their color, to determine the aerobic plate count (APC). The log CFU/cm2 was calculated from the colony totals. When no cells were detected on the lowest dilution plate, a log value of ?1.38, which is equivalent to 0.5 colony-forming units, is used. This value is used because a value of zero colony-forming units cannot be converted to a log value.
Carcass and Cooler Temperatures
Deep muscle temperature decline, surface temperature decline and cooler temperature were monitored with either a Dickson or ThermoWorks data logger. Dickson SM320 (Addison, IL, U.S.A.) or ThermoWorks Model TB1F (Lindon, UT, U.S.A.) data logger probes were inserted into the center of the round. The body of the data logger which has an internal temperature device was hung on the round in close proximity to the surface, and this temperature was used as the surface temperature decline. Dickson SX100 (Addison, IL, U.S.A.) or ThermoWorks Model TD (Lindon, UT, U.S.A.) data loggers were hung in coolers to monitor the temperature fluctuation during harvest and carcass chilling. Temperature decline graphs were generated from data collected and time for carcass deep muscle and surface temperature to be less than 45F was determined.
Fully cooked shelf stable sampling
Individual plants were contacted to determine if they manufactured a fully cooked shelf stable product and if they were interested in validating the process. Plants that participated shared the Hazard Analysis Critical Control Point (HACCP) plan with the researcher. Random samples were taken after mixing, before stuffing or if the processor had a grinder mixer, directly from the grinder head for raw samples and then samples were obtained after cooking. Twenty-five grams of sample was stomached with 225 mL of buffered peptone water for two minutes at 230 rpm using a Stomacher 400 (Seward, Fisher Scientific, Itasca, IL, U.S.A.). Serial dilutions were prepared using Butterfield’s phosphate diluent (3M Microbiology, St. Paul, MN, U.S.A.). Samples and serial dilutions were plated on 3M Petrifilm E. coli/ Coliform Count plates (PF-EC; 3M Microbiology Products, St. Paul, MN, U.S.A.), 3M Petrifilm Enterobacteriaceae Count plates (PF-EB; 3M Microbiology Products, St. Paul, MN, U.S.A.), and 3M Petrifilm Aerobic Count Plates (PF-AC; 3M Microbiology Products, St. Paul, MN, U.S.A.). The PF-EC and PF-EB plates were incubated at 35C for 24 hours, and the PF-AC plates were incubated at 35C for 48 hours. Plates were enumerated as described above.
Fully cooked shelf stable temperature monitoring
Internal temperature and post cooking temperature decline were monitored with ThermoWorks Model TB1F (Lindon, UT, U.S.A.) data loggers. Probes were inserted into the center of the product prior to entering the smokehouse and removed prior to packaging or casing pealing and packaging.
Small meat processors (18) that harvest beef in Montana were contacted to determine how many wanted to participate in the validation studies. These 18 plants include the five plants that had agreed to participate upon submission of the proposal. The contact included obtaining information about slaughter days, inspector names, pounds or number of animals harvested and intervention used.
Ten plants expressed interest in participating in the validation study. One of the challenges for the extremely small plants is that they only kill one or two beef a week. Because of this, there were some plants that did not continue in the study because of low beef kill numbers. There were six plants that had three or four sampling days, and they received reports on the effectiveness of their E. coli O157:H7 intervention.
Of the plants that were sampled, the E. coli O157:H7 interventions were ambient lactic acid, hot lactic acid, hot water wash and dry aging (seven days).In all cases there were carcasses where the indicator organisms were below detectable limits prior to the intervention. However, there were also times when the number of indicator organisms increased after intervention. This shows that the small processors do a good job of dressing beef carcasses with low levels transferred to the carcass; however, consistency can be a problem of both the dressing process and application of the intervention. In general the different interventions resulted in 0.57 to 1.2 log reduction of indicator organisms. Indicator organisms do not say specifically determine that E. coli O157:H7 and Salmonella are not present on the carcass, but when no indicator organisms are found in the sampling area, the likelihood that the specific pathogens are not in the sampling area is high. One reason for the low log reduction is the low level of contamination found on most carcasses. The combination of lower contamination loads along with interventions resulted in 47 – 100% of the carcasses having below detectable limits of the indicator organism in the carcass samples. There is a variation between plants which can be associated with different dressing procedures as well as different interventions.
Carcass cooling rates were different between plants. The time to chill the deep muscle to less than 45 degrees was extremely variable within plants as well as between plants. Cooler temperatures are important to the chilling rates. Cooler settings explain most of the differences between plants, and problems with coolers explain part of the in plant variation. Some of the variation could be reduced if processors installed temperature monitoring equipment or instituted a daily cooler check to track changes in the cooler temperatures. This would allow the plant personnel to identify when coolers are starting to increase in temperature, indicating problems with a compressor. The plants with the least amount of variation in the cooler temperatures were ones that had some form of monitoring procedure.
Four plants participated in the validation of the fully cooked not shelf-stable HACCP plans. Each plant shared the current HACCP plan. Individual suggestions were made on ways to improve the process and the process flow was verified. Two samples from one plant and a single sample from three other plants were evaluated before and after cooking to determine effectiveness of individual processes. All plants involved utilized USDA’s Appendix A, Compliance Guidelines For Meeting Lethality Performance Standards For Certain Meat And Poultry Products and Appendix B, Compliance Guidelines for Cooling Heat-Treated Meat and Poultry Products (Stabilization) as the scientific documentation for the critical limits in the HACCP plan. All products sampled had below detectable limits of indicator organisms after cooking. The cooking process also resulted in a 2.0 to 5.0 log reduction in generic bacteria (Aerobic Plate Count). This suggests the process in place in the plant is effective at lowering contamination load to below detectable limits for indicator organisms and drastically reduced the total microbial load. Cooking and chilling temperatures recorded indicated the plants were meeting the requirements of the HACCP plans.
After the completion of this project, processors have written information they can include in their food safety plans that are made for their processes that will help them comply with the ever changing inspection requirements. USDA recently released the final information on the requirements for validation of HACCP plans. This requires plants to make sure they are doing exactly what their supporting scientific documentation says or test for bacteria. Processors who participated in this project now have data on the effectiveness of the E. coli O157:H7 intervention they are currently using. The microbial data will serve as the validation of their process. The project supplied the foundation to help the small processors of Montana to comply with inspection requirements for testing along with assuring the production of a safe meat product. Furthermore, the project has helped to establish contacts with small processors so they know who to contact when they need help. This will lead to continued improvement in the food safety system and help processors stay in business.
Educational & Outreach Activities
Beef Slaughter Validation Study: General Observations and Recommendations for reduced bacterial contamination
Preliminary information shared with State Meat Inspectors at meeting in Helena, April 2010.
Information on project was presented at the Montana Meat Processors Convention in Columbus MT, April 2011
Update on project presented at the Montana Meat Processors Convention in Livingston, MT, April 2012
Recommendations made after completing the study are mostly changes in habits and have little cost to the processor. The exception is installation of temperature monitoring equipment. These systems can be extremely expensive. An alternative has been given to purchasing an expensive device; daily logs of temperature along with analysis of the data. A manual method of recording the temperatures can be as effective as the more expensive recording devices. However, there would not be an alarm available for the manual process.
The project confirmed that current processes were working. It did bring up some concerns of consistency of process. Because the intervention process is required for inspection, all inspected plants have to incorporate E. coli interventions in their harvest process. The project supplied information to meet inspection requirements. The main recommendation to the processors in their day to day operation is create a routine and stick to it. Make sure to pay attention to details and find a way to consistently apply the intervention, similar to what happens in cooking.
Areas needing additional study
The new USDA rules requiring testing for the six relevant non-O157 STEC serogroups makes it necessary to determine if current interventions for O157:H7 are effective on these other serotypes. The ruling on validation will also require the processors to find a way to validate their process. Currently they are using scientific documents. If they are not using Appendix A and B as their documents, they need to make sure that their process matches exactly the process in the paper. This means they have to match particle size, mixing time, cooking time and starting material. Some processors do not have the knowledge to be able to effectively determine if the paper fits their process, so it will be necessary for someone with the training and knowledge to conduct the validation to meet inspection requirements. Also, those processors could do a complete microbial validation study. Again for individual plants, the knowledge is not available. Nor do most have the monetary resources to hire someone to conduct the validation studies. Small and very small processors will rely heavily on the resources of the Universities to meet inspection requirements.