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A Comprehensive Feed Safety Approach for Rendered Products FDA Public Meeting Discussion of Animal Feed Safety System September 23, 2003 David Harlan Taylor.

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Presentation on theme: "A Comprehensive Feed Safety Approach for Rendered Products FDA Public Meeting Discussion of Animal Feed Safety System September 23, 2003 David Harlan Taylor."— Presentation transcript:

1 A Comprehensive Feed Safety Approach for Rendered Products FDA Public Meeting Discussion of Animal Feed Safety System September 23, 2003 David Harlan Taylor Packing Co., Inc An Excel Food Solutions Company

2 Food Animal Production Pet Foods Rendered Co-Products Animal Feed Manufacture Meat Processing Feed Ingredients Consumer Foods Rendering Cycle Plays a Critical Role

3 Dressing Floor Fabrication Further Process Edible Beef Products Inedible Rendering Beef Processing Typical Fed-Cattle Plant Blood Drying Edible Rendering Feed & Technical USDA Ante mortem

4 Dressing Floor Fabrication Edible Beef Products Inedible Rendering Beef Processing Taylor Packing Blood Drying Feed & Technical USDA Ante mortem Further Process

5 CENTRIFUGE Dressing Offal COOKERCOOKER Taylor Rendering Process MIX & GRIND Fab Bone & Fat PRESS (3) SCREEN SolidLiquid COOLER STORAGE GRIND/SCREEN LOADOUT/ BLENDING TANK FILTER BEEF TALLOW TANKS

6 Comprehensive Program Philosophy & Commitment Philosophy & Commitment Raw Material Source, Specifications & Assurances Raw Material Source, Specifications & Assurances Hazard Analysis & Critical Control Point program Hazard Analysis & Critical Control Point program Good Manufacturing Practices Good Manufacturing Practices Employee Training Programs Employee Training Programs Transportation Policy Transportation Policy Third Party Audits Third Party Audits

7 Philosophy & Commitment Preventative Mindset Preventative Mindset Proactive vs. Reactive Proactive vs. Reactive Continuous Improvement Continuous Improvement Commitment from Entire Team Commitment from Entire Team –Leadership –Management –Production

8 Raw Material Specifications In-House Packer Source – 100% Bovine with mixed supply from 70% mature cows and 30% fed-cattle In-House Packer Source – 100% Bovine with mixed supply from 70% mature cows and 30% fed-cattle 100% from Cattle Passing Ante Mortem Inspection Conducted by USDA:FSIS Veterinarian 100% from Cattle Passing Ante Mortem Inspection Conducted by USDA:FSIS Veterinarian Packinghouse Training & Awareness Relative to Potential Physical & Chemical Contaminants Packinghouse Training & Awareness Relative to Potential Physical & Chemical Contaminants CNS Tissue Removed in Packinghouse CNS Tissue Removed in Packinghouse

9 Hazard Analysis and Critical Control Point (HACCP) 7 Principles 1.Assess Hazards 2.Determine Critical Control Points – CCP 3.Establish Critical Limits for CCP’s – CCPCL 4.Procedures to Monitor CCP’s 5.Develop Corrective Action Plans 6.Recordkeeping 7.Verification

10 Potential Hazards 3 Classes Biological Biological –Microbiological –Insect Infestation –TSE’s Chemical Chemical –Pesticides & PCB’s –Lubricants, oils, etc. Physical Physical –Metal –Plastic

11 HACCP Example Microbiological - Pasteurization 1.Assess Hazard Raw material contains potential pathogensRaw material contains potential pathogens 2.Determine Critical Control Points – CCP a.Cooker discharge temperature - TEMP b.Raw material grind - GRIND c.Processing rate - RATE 3.Establish Critical Limits for CCP’s – CCPCL a.TEMP - Minimum 270 o F based on validation study b.GRIND - Maximum 30 mm anvil gap on pre-breaker c.RATE - Maximum 36,000 pounds/hour feed rate

12 HACCP – Microbiological Continued 4.Procedures to Monitor CCP’s a.TEMP - Continuous monitoring by certified thermocouple b.GRIND - Inspection, Weekly measurement of anvil gap c.RATE - Computer tracking of cooker feed auger 5.Develop Corrective Action Plans a.TEMP - Alarm notification, automated discharge shutoff b.GRIND - Repair, Rebuild when gap reaches 30 mm c.RATE - Reduce feed rate if over 36,000 pounds/hour

13 HACCP – Microbiological Continued 6.Recordkeeping a.TEMP - Computer tracking of CCP and alarm log b.GRIND - Operations & maintenance logs c.RATE - Computer tracking of CCP and alarm log 7.Verification Clostridium perfringens testing – indicator organismClostridium perfringens testing – indicator organism 15 day intervals15 day intervals Rotate shift and time within shiftRotate shift and time within shift

14 Plant Operator Screen

15 Recordkeeping Cooker Temperature Trending and Statistical Analysis

16 Good Manufacturing Practices (GMP) Housekeeping Issues Housekeeping Issues Recordkeeping Recordkeeping Pest Control Program Pest Control Program Facility Design & Repair Facility Design & Repair Sanitation Program Sanitation Program Startup & Shutdown Procedures Startup & Shutdown Procedures

17 GMP Example Prevent Salmonella Recontamination APPI model adopted by +99% of industry APPI model adopted by +99% of industry Process zones in facility Process zones in facility Work habits & policies Work habits & policies Startup procedures Startup procedures Reprocessing of product spills Reprocessing of product spills Dry cleaning of finished product areas Dry cleaning of finished product areas Sanitation practices that target “hot spots” Sanitation practices that target “hot spots” Facility design & equipment maintenance Facility design & equipment maintenance Effectiveness verified by finished product testing Effectiveness verified by finished product testing No CCP available except formaldehyde addition

18 Employee Training Specific Modules on HACCP, GMP’s and SOP’s Specific Modules on HACCP, GMP’s and SOP’s New Hires New Hires –Entry at Trainee position –Individualized training over several months Career Advancement Career Advancement –Training program for each position –Certified by written & verbal testing All Employee’s All Employee’s –Quarterly quality training –Immediate team review of feed safety issues

19 Transportation Policy Certification of regulatory compliance by carriers Certification of regulatory compliance by carriers Trucks are only to haul agricultural commodities Trucks are only to haul agricultural commodities Trucks are to be clean prior to arrival Trucks are to be clean prior to arrival Visual inspection of empty trucks upon arrival Visual inspection of empty trucks upon arrival –No visible carryover regardless of past ingredient hauled –Will the integrity of our product be maintained? Assurance of cleanout after delivery Assurance of cleanout after delivery –Included in policy signed by carriers & drivers –Prominent reminder to driver attached to Bill of Lading Clean Conveyances and Inspection Prior to Loading Is the Responsibility of Every Ingredient Supplier!!

20 Third Party Audits 21 CFR APPI Certification via Cook & Thurber APPI Certification via Cook & Thurber –Found high compliance in Rendering Industry –Confirmed by FDA Inspections –Discontinued because of high compliance Facility Certification Institute - FCI Facility Certification Institute - FCI –Requirements are based upon FDA rule –Must prove compliance with FCI program –Ingredient supplier and transport certifications –Must demonstrate adequacy of flushing when co-mingling restricted use products –Annual audits to maintain status in program

21 Thank You Special Thanks To: Debby Capela, Taylor Packing The Taylor & Excel Rendering Team


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