4 replies to this topic

[EHam]

Anyone out there have any information on the hazards of lead bird shot in raw beef? Our supplier has been providing beef to us for quite some time and unfortunately it occasionally contains lead bird shot in certain cuts. It's not an option to switch suppliers and they are not willing to put metal detection/x-rays in place at their facility to prevent the lead shot from getting to us in the first place. The burden just falls on us. We grind, cook and further process the beef into a finished good. We currently find bird shot in our finished goods by means of x-ray inspection...which by the way, is NOT a CCP (please note that we have never had a consumer complaint regarding lead shot).

 

I'm sure we can get quite a discussion going on a few of the issues that I have just pointed out, but with all of this said, I'm mostly looking for advice on how to handle the situation in its entirety and how to address it in the hazard analysis.

 

All feedback is welcome! Thank you!

[Mr. Incognito]

Would they be willing to put the metal detector in if your company paid for it?  I worked for a company that co-packed for another company and they put in a bar code scanner because the company I worked for wasn't willing to flip the bill for it... long story.

 

At any rate...

 

Why isn't it an option to switch suppliers?  Does nobody else supply beef? 

 

Otherwise what is the incoming beef status (ground, chunk, etc) and can you just put an inline metal detector at your raw product in to detect/remove the shot before you further process it?

[RMAV]

What about the root cause of the lead shot getting into the beef?  Where is it coming from?  Perhaps you can help your supplier determine  the source and eliminate it there.

[Charles.C]

Anyone out there have any information on the hazards of lead bird shot in raw beef? Our supplier has been providing beef to us for quite some time and unfortunately it occasionally contains lead bird shot in certain cuts. It's not an option to switch suppliers and they are not willing to put metal detection/x-rays in place at their facility to prevent the lead shot from getting to us in the first place. The burden just falls on us. We grind, cook and further process the beef into a finished good. We currently find bird shot in our finished goods by means of x-ray inspection...which by the way, is NOT a CCP (please note that we have never had a consumer complaint regarding lead shot).

 

I'm sure we can get quite a discussion going on a few of the issues that I have just pointed out, but with all of this said, I'm mostly looking for advice on how to handle the situation in its entirety and how to address it in the hazard analysis.

 

All feedback is welcome! Thank you!

 

Dear Eham,

 

No problem to have a general discussion on haccp / meat but maybe convenient to focus the questions a little.

 

I deduce you  have 3 immediate queries –

(1) How to prevent lead shot arriving within yr carcasses ?

(2) Whether the presence of lead shot is a regarded as a potential health hazard to a consumer.

(3) Is the MD / X-ray step justifiable as a non-CCP ? / Is it necessary at all ?.

 

Please feel free to enlarge the list if desired.

 

Some logical thoughts in previous posts.

 

I suppose the simplest solution to (1) is to change the  supplier as already stated.

Unfortunately, AFAIK, the situation you refer appears (in USA) to be the normal case, ie  legally / generally accepted in meat business so no (external) control measure is mandatory / compellable. I’m not in USA or meat business so please correct me if incorrect. If you are seeking ideas on how to eradicate the causative step, this is maybe more of a cultural question than FS ? Not sure if other countries are similar or not,  I suspect the latter but no data to support ?

 

Regarding (2), i guess it depends on the FSIS compliance requirements. Compliance appears to be controlled by FSIS Directive 7310.5 (2003)(seems too antique, later version?) / 9CFR, part 417. Precise criteria for a hazardous foreign material  criteria are not visibly evident (to me) unlike the comparable document for USFDA.   i presume  rejection/recall  could also result from generic factors within the broad-based scope of "adulteration", eg detection of foreign materials. For present purposes i anticipate that lead shot is regarded as a potential hazard (based on USFDA guidelines / general consumer).

 

 FSIS Directive 7310.5 (2003).pdf   108.58KB   5 downloads

 CFR-2012-title9-vol2-part417.pdf   145.55KB   5 downloads

 

Regarding (3), my first thought on reading yr post was, given yr initial comments, why is the detection step NOT a CCP  in your hazard analysis?   Perhaps you could explain the reason ?. Due simply to legislatory reasons  perhaps (?) which would sort of end the analysis.  According to the directive referred above, it appears (to me)  that  various haccp options are possible (eg sections A,C,E,G). The options involve both CCPs and Prerequsite programs. The currently posed scenario seems possibly matched to A or E, the latter of which you seem to have chosen.? Use of the Codex Tree would presumably demand A.

 

There is a quite lengthy thread on related aspects of (1-3)  for meat items in USA here  –

 

http://www.ifsqn.com...tor/#entry57468

 

As you can see, a lot (but not all) of the “hazard” data is relatively old, (eg ca.2003) and  contains a mixture of  haccp opinions / guidelines / statistics / rules in respect to 2 classic elements of risk assessment analysis, likelihood of occurrence and severity of consequences, plus the legislatory situation. Many of the current US viewpoints, eg  USFDA appear to have re-interpreted such data and issued  legislatory requirements accordingly, including within the category of “adulteration”. Some of the USFDA detail, eg the definition of a hazardous metallic fragment, is specific to the USA as, for example, compared to Europe.  Divergences are not so unusual in FS / haccp of course.

 

Appreciate yr feedback and hopefully further input from other posters.

 

Rgds / Charles.C

 

PS - It's not USA-specific but this "game" link may be of passing (chemical) interest  -

 

http://www.ifsqn.com...indpost&p=56213

 

PPS - I seem to recall seeing a comment somewhere that USDA / USFDA are now following the same foreign material safety criteria but could not  locate any reference. No doubt US meat producers here will have a better, more current, awareness ?

 

3PS - Other readers only too welcome to make their own haccp suggestions.

(have attached the only files i could see as directly relevant, hopefully the OP / meat people will correct / update if in error)

Edited by Charles.C, 14 November 2013 - 10:32 AM.
revised 2,3

[EHam]

My apologies for not responding sooner. We are now in our busy season!

 

Thank you for all of the replies and the information provided by Charles.C. I would like to say that all of the recommended avenues in the first two responses have been explored. I am not of the upper management status and there is no movement to spend money or more time on this issue. I feel it is now my responsibility to present this food safety issue in a reasonable way for management to understand.

 

Regarding (3) that was posted by Charles.C, as I came into my position here, the MD has never been a CCP nor have we (management) ever wanted it to be. However, I will also say that this issue has been overlooked for far too long. It has always been an issue that was looked at as "not reasonably likely to occur". Dare I say we need to look at this a little closer and make some updates! It's going to take some coaxing. Change is something we shouldn't fear, but it's difficult to convince others otherwise.