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!
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
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 –
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 -
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)