1. United States Department of Agriculture Food Safety and Inspection Service FSIS NOTICE 39-14 CLARIFYING AND EXPANSION OF SAMPLING ELIGIBILITY CRITERIA FOR THE ROUTINE BEEF MANUFACTURING TRIMMINGS (MT60) AND BENCH TRIM (MT55) SAMPLING PROGRAMS Office of Policy and Program Development FSIS, USDA Washington, DC 1

2. United States Department of Agriculture Food Safety and Inspection Service Purpose Cancels FSIS Notice 81- 13 Explains that product eligible for sampling as beef manufacturing trimmings (MT60) is not to be sampled as bench trim (MT55) by FSIS at further processors Incorporates information from previously issued askFSIS questions and answers Provides IPP information on how to determine what product was eligible for MT60 at the slaughter establishment Clarifies the situations in which bench trim (MT55) samples are to be collected 2

3. United States Department of Agriculture Food Safety and Inspection Service Objectives  Discuss the main changes to the notice  Show which published askFSIS Q&As were incorporated into the notice or modified or removed from the system 3

4. United States Department of Agriculture Food Safety and Inspection Service Key Point FSIS’s sampling resources are limited so our routine sampling programs focus on sampling products that weren’t already eligible for sampling 4

5. United States Department of Agriculture Food Safety and Inspection Service Key Point Bench trim sampling (MT55) targets products that were not already eligible for sampling under MT60 beef manufacturing trimmings or MT54 other raw ground beef components sampling program 5

6. United States Department of Agriculture Food Safety and Inspection Service Bench Trim (MT55) Sampling Program Sample product that was derived from the cattle that were not slaughtered on site AND that was not eligible for sampling at the slaughter establishment. MT55 targets raw beef source materials, such as vacuum packaged subprimals, that are not already for sampling under the MT60 beef manufacturing trimming or MT54 other raw ground beef components sampling program. 6

7. United States Department of Agriculture Food Safety and Inspection Service MT55 Additional Examples Est. receives individually vacuum packaged or boxed primal and subprimal cuts and uses to produce smaller pieces of trim or any RNI product –Individually vacuum packaged or boxed primal and subprimal cuts aren’t eligible for MT60 when Producing slaughter est identifies that the product’s intended use is for RI product and identifies controls to ensure product is used as intended. 7

8. United States Department of Agriculture Food Safety and Inspection Service MT55: Additional Examples Est produces smaller pieces of trim from purchased primal or subprimal cuts and intends trim for use in any RNI product –Remember, even if the est uses all the trim in-house (doesn’t ship any trim out), the trim is eligible for sampling 8

9. United States Department of Agriculture Food Safety and Inspection Service MT55 Additional Examples Est. uses, w/o trimming or cutting into smaller pieces, purchased primal or subprimal cuts that weren’t eligible for MT60 sampling to produce any RNI product 9

10. United States Department of Agriculture Food Safety and Inspection Service MT55 Additional Examples Est receives whole, half, or quarter carcasses and produces primal and subprimal cuts that it intends for RNI use NOTE: Whole, half, and quarter carcasses are not eligible for sampling under the MT60 beef manufacturing trimmings program. 10

11. United States Department of Agriculture Food Safety and Inspection Service Examples NOT eligible for MT55 sampling Est. receives purchased raw beef products that are received accompanied by certificates of analysis (COAs) with negative E. coli O157:H7 (or STEC organisms or virulence markers) test results AND does not produce separable bench trim –Raw beef products accompanied by COAs with negative results were eligible for MT60 sampling at the slaughter est 11

12. United States Department of Agriculture Food Safety and Inspection Service Examples NOT eligible for MT55 sampling Est. receives ammoniated beef products and other raw ground beef components (e.g., head meat, cheek meat, heart meat, weasand meat) and uses to produce RNI product –Other raw ground beef components are sampled under the MT54 program 12

13. United States Department of Agriculture Food Safety and Inspection Service Examples NOT eligible for MT55 sampling Est. receives mechanically tenderized product and doesn’t produce separable bench trim and uses to produce any RNI product Est. receives coarse grind and uses to produce any RNI product In both cases, if est. grinds product, ground product is eligible for MT43 sampling 13

14. United States Department of Agriculture Food Safety and Inspection Service Products NOT eligible for MT60 or MT55 Sampling 14 Trim intended for use in raw or RTE product or in other product that will receive a full lethality treatment at a federally inspected est. –Examples of full lethality treatments other than cooking can include high pressure processing and irradiation, provided that establishment has support documentation that shows the treatment achieves a 5-log reduction for Salmonella and applies the treatment consistent with it critical operational parameters. Trim produced from cattle slaughtered under a custom exemption Trim produced under a retail exemption

15. United States Department of Agriculture Food Safety and Inspection Service Key Point FSIS samples raw beef source materials used to produce ANY RNI product under MT60 and MT55 FSIS focuses MT43 raw ground beef sampling on only products that are of greatest public health risk  Products that meet standards of identity of 319.15(a) ground beef,(b) hamburger, (c) beef patties, and similarly produced products 15

16. United States Department of Agriculture Food Safety and Inspection Service Key Point Remember for MT55 and MT60 sample the source materials used to produce the RNI and not the finished RNI product! 16

17. United States Department of Agriculture Food Safety and Inspection Service 17 Examples of Raw Non-Intact Intended Uses Raw beef products that meet the standards of identity for ground beef (9 CFR 319.15(a)) NOTE: Some of the these finished products, or their beef component, may receive a full lethality treatment at a federal establishment. In that situation, don’t collect MT60 and MT55 samples. Raw beef products that meet the standards of identity for hamburger (9 CFR 319.15(b)) Shaped and formed ground beef products other than patties (e.g., meatballs, meatloaf, gyros) Raw beef products that meet the standards of identity for beef patties (9 CFR 319.15(c)) Ground beef meat fillings such as taco meat, tamale meat Other raw beef products that do not meet the these standards but are produced similarly Thinly sliced raw beef derived from reconstructed beef products used in “Philly” style cheese steaks Ground beef sauces or soups including “Sloppy Joe,” chili, etc Multi-ingredient raw ground meat or poultry products for which the establishment labels the product in a manner to show that ground beef is the predominant species in the product Not-ready-to-eat (NRTE) non-intact product that receives a heat treatment but is not fully cooked Raw beef sausages (e.g., fresh sausages, beef chorizo) Char-marked heat-treated but not fully cooked beef patties, chicken-fried steak type product or breaded beef patty that is heat-treated but not fully cooked Diced beef (smaller than ¾-inch) Corned beefMechanically tenderized product

18. United States Department of Agriculture Food Safety and Inspection Service Previously published askFSIS Q&As 18

19. United States Department of Agriculture Food Safety and Inspection Service 19 Sampling Eligibility of Bench Trim and Beef Manufacturing Trimmings Used or Intended for Use in Heat Treated, Not Fully Cooked Products Removed, Incorporated Raw Beef Sampling After the Application of Antimicrobial Interventions Removed, Incorporated Sampling Bench Trim or Beef Manufacturing Trimmings Used to Produce Mechanically Tenderized Product Removed, Incorporated Supporting a Lot Definition Consisting of One Individually Cryovaced Product Available Minimizing Lot Size for Raw Beef Product that is not Individually Cryovaced Available MT55 Sampling Eligibility of Purchased Source Materials Used As-Is (i.e., without producing bench trim) Removed, Incorporated MT55 Sampling Eligibility of Source Material that is Mechanically Tenderized at the Producing Establishment Removed, Incorporated Random Sample Collection of Beef Manufacturing Trimmings and Bench Trim Removed, Incorporated Trimmings may be Subject to FSIS Sampling Throughout the Slaughter and Processing Operations Removed Sampling Eligibility of Bench Trim and Beef Manufacturing Trimmings Used or Intended for Use in Diced Beef Smaller than 3/4 inches Removed, Incorporated Definition of Commingling as it Relates to a Further Processor’s Ability to Support a Lot Definition Consisting of One Individually Cryovaced Product Available Lot Definition for Products that are Routinely Commingled Available Adequate Notification for Bench Trim (MT55) Sample Collection and Limiting Lot Size Available MT55 Sampling Eligibility of Purchased Raw Beef Products Accompanied by Certificates of Analysis Removed Adequate Support for the Intended Use of Beef Primal and Subprimal Cuts Modified and Available Bench Trim (MT55) Sample Collection Procedures of Primal and Subprimal Cuts when Further Processed into Smaller Cuts Used to Produce Multiple Products Removed, Incorporated Potential Differences Between Establishment and PHIS HACCP Processing Categories Available Sampling Eligibility of Bench Trim Regardless of Product Size and Packaging Removed

20. United States Department of Agriculture Food Safety and Inspection Service Questions on Notice 39-14 16 questions received from 8/13 – 8/26/14 –MT55 sampling eligibility when purchased beef product are accompanied by a COA –Managing PHIS profile information when COAs are received with purchased trim. –Instructional statement (for cooking only): is it required for product to be exempt from MT55 –MT55 sampling eligibility when trim is sent to retail facility –Support for intended use and sampling eligibility –When to sample needle tenderized beef 20

21. United States Department of Agriculture Food Safety and Inspection Service Questions? 21