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Product Changeovers, ABF to Non-ABF meats

ABF antibiotic free ABF claims

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#1 Turkey

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Posted 13 October 2015 - 01:54 PM

We currently produce products that contain ABF meat and poultry as well as non-ABF meat and poultry. Our current procedures for handling ABF meat during production is to handle it as though it were an allergen (with the exception that it would be ran first of the day before any non-ABF product). If it cannot be ran first, it must be preceded by a complete clean before it can be ran. (We produce RTE deli products). The question that has been raised by the production staff is; Is a complete clean up absolutely necessary or can it be handled as a species change over and all equipment is water clean up only with a pre-op inspection before proceeding to the ABF product?

 

We are not currently required to undergo a separate audit (outside of our GFSI audit) for ABF handling. Has anyone ever undergone such an audit and what are the auditors saying about clean ups between ABF and Non-ABF products? 



#2 gfdoucette07

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Posted 13 October 2015 - 02:17 PM

Turkey,

 

I to worked in a facility that ran abf and non-abf chicken in MN and WI.  We followed the same format you are currently using, our abf birds went first, then transitioned to non-abf.  In the event that an abf flock had to be ran after we cleaned the blew our the conveyors, cleaned up the floors, and just rinsed out the tubs, tanks, and lines and started back up.  This was a full processing plant so we brought in whole birds and cut up for retail.  Not sure if this would be the same in the deli meats sector but I would believe so.  This facility was SQF level 3 (and still is). 

 

Just one guys opinion

 

G



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#3 Charles.C

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Posted 13 October 2015 - 02:23 PM

Hi all,

 

ABF = ?

MN = ?

WL = ?


Kind Regards,

 

Charles.C


#4 gfdoucette07

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Posted 13 October 2015 - 02:30 PM

Sorry Charles

 

ABF= in us meat is raised either AntiBiotic Free or the great old fashion way (but this is a heated debate), given no additional antibiotics during its growth cycle

MN= Minnesota

Wi= Wisconsin



#5 Charles.C

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Posted 13 October 2015 - 03:21 PM

Sorry Charles

 

ABF= in us meat is raised either AntiBiotic Free or the great old fashion way (but this is a heated debate), given no additional antibiotics during its growth cycle

MN= Minnesota

Wi= Wisconsin

 

Hi gfd,

 

Thanks. Actually a rather interesting problem.

 

I would guess the decision relates to whether the level of AB in ABF product complies with the (LOD?) target. Just like allergens except maybe less easy to check (?)

 

I assume the ABF is only for export.


Kind Regards,

 

Charles.C


#6 gfdoucette07

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Posted 13 October 2015 - 03:51 PM

No it is both here and for export, a lot of consumers here are on a organic, free-range, grass fed, all natural, whatever, trend.  The less "stuff" in their food the better even though a lot of that "stuff" makes their food of higher quality and more sustainable.  For instance in poultry (of which I raise turkeys and have worked in a processing plant too)  if my flock gets sick I meet with my veterinarian and we decide on a course of antibiotics (whether its administered via feed, water, or injection) so the flock can get better.  All of these have a period of time after they are administered before the animal can be sent to market.  In the case of ABF flocks if they get sick I have to wait until they "get over it"  this results in the bird not eating/drinking/sleeping well which usually make them more sick and increases my mortality and loss of income.  These ABF flocks usually bring more money per pound but if you finish less pounds it may not mean more income.

 

I personally try to relate it to consumers who think antibiotic free is the way to go like this.  If your child or pet is sick for some reason and after a few days it does not go away do you not look for a medicine or seek a DR?  Would you rather eat poultry given the best care possible and in good health at market or a animal that was weak and not given the best care.

 

The more I can make my animals comfortable (clean bedding, fresh air, quality feed, space to move, and vaccines IF needed) it is in my best interest as the more animals I can send to process the more people I can help feed!

 

This was a long answer to your question Charles but I like promoting what farmers do to put quality products on peoples tables!

 

G



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#7 qalearner

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Posted 13 October 2015 - 05:51 PM

Interesting question indeed. We work with organic products and in order for us to be certified we need to do a complete clean between organic and non-organic products. However, I do not know if there are any standards/regulations when it comes to ABF. All the demand for "natural" (how I hate that word) food has left much to be desired in the way of rules surrounding these types of products. 



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#8 gfdoucette07

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Posted 13 October 2015 - 06:18 PM

QA,

 

Yes while organic has some pretty black/white guidelines, the other terms are very loosey-goosey.  I am still waiting on good rebuttal as to why natural/antibiotic/hormone is SOOOOOO much better than the food we have been making.  Plus I can get a little of the Organic statement however, do these people have a plan for me too feed the population with those standards?  Which also brings up those who push everyone to not eat animals, do they realize the amount of land that would take? We'd better start planting on the moon and Mars! 

 

G



#9 MWidra

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Posted 13 October 2015 - 07:41 PM

The antibiotic free movement started with people not wanting more stuff in their food, but it also is gaining momentum because of the problem of the antibiotic resistant organisms that now plague human medicine.

 

The background for this is that it was found that if you gave low doses of certain antibiotics to meat producing animals, they gained weight faster.  It had nothing to do with illness, and it is still a mystery why it works.  So farmers used antibiotics on the entire herd/flock whether it needed it or not.

 

Now we have the superbugs, and this practice is probably a large part of the cause.  The way to make a resistant bacteria is to give it low doses of antibiotic, and the bacteria that survive and flourish are resistant.  What doesn't kill you makes you stronger.

 

Also, if people eat meat that contains low doses of antibiotic, the same could happen.  The antibiotics were supposed to be withdrawn before slaughter, but there was always someone who cheated.  They find adulterated carcasses even now.  So people want ABF free animals also to stop superbugs from being produced.

 

There is a USDA antibiotic free program, which is one of their process verified programs, but you can give the animals antibiotics if they are ill, and wait until they are free of it to slaughter.  And it's getting harder to get antibiotics for use in animals, now you need a vet to prescribe it.  You used to be able to buy it by the pound in mail order catalogs.

 

I'm sure, gfdouchette, you knew all that, but the others did not have that background.

 

http://www.cbsnews.c...in-animal-feed/

 

Martha


"...everything can be taken from a man but one thing:  the last of the human freedoms--to choose one's attitude in any given set of circumstances, to choose one's own way."  Viktor E. Frankl

 

"Life's like a movie, write your own ending."  The Muppets


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#10 Turkey

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Posted 15 October 2015 - 12:46 PM

Thanks for the replies everyone,

 

I have done some more research,  contacted a process authority,  and spoke with our USDA inspector as well to see what he prefers to see in the situation when non-ABF is ran before ABF. This is what I have found... 

1.Antibiotic free is a labeling issue, therefore there needs to be a complete break between ABF and Non-ABF (which we already know).

2.There is no scientific means to prove that a flock is raised antibiotic free, therefore proof (from the standpoint of the USDA) is given through required documentation.

3. Since all meat is tested to be free from antibiotic residue before slaughter, all meat would be "antibiotic free" except for the fact that USDA has a definition of "antibiotic free" as animals raised without the use of antibiotics.

4. So to comply with the labeling issue we need to make sure that the equipment is "meat free" of Non-ABF meat before moving forward with ABF meat.

5. To be meat free, a water rinse would be effective, (treating it more as a species change over more so than what we would do for an allergen).

6. There needs to be a documented visual inspection before moving forward.

 

Thinking a little more about all of this I have to say that I feel that a water spray down is an effective means of changing over, because we could never validate (by means of testing) a full clean up procedure anyway to show that the equipment is free from residues left behind by Non-ABF meat that would affect the label claim of Antibiotic free.

 

I have also been told that some processors only leave a break (an empty space) on the line between ABF and Non-ABF (even when going from Non-ABF to ABF) products and do no clean up of any sort. At this point in time they may be able to do that legally because they are implementing a practice to make sure that the meat is not mixed. But from a production standpoint I think that there needs to be a little more, such as the water rinse, to ensure the break between non-ABF and ABF. As time goes on and the more that ABF products are produced, I am sure that the government will take more of a stand and establish some validation guidelines as they have with the gluten free label claims. But until then we are responsible for our own policies and practices.



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#11 MWidra

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Posted 15 October 2015 - 01:14 PM

This is an excellent summary of what is needed, and how the USDA system works.  This will help others, I'm very sure.

 

These products with claims like ABF, organic, grass fed, etc, have the potential for being higher value than those produced in the normal manner.  Hope it is a money-maker for your company!

 

Martha


"...everything can be taken from a man but one thing:  the last of the human freedoms--to choose one's attitude in any given set of circumstances, to choose one's own way."  Viktor E. Frankl

 

"Life's like a movie, write your own ending."  The Muppets


#12 Charles.C

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Posted 15 October 2015 - 03:46 PM

Hi Turkey,

 

Thanks for the post.

 

Meat not my area so apologies in advance if my queries have obvious industry answers.

 

I was unable to understand a few of yr points, eg –

 

(1) how do you validate that the batches of yr product pre-categorized as AB and ABF are actually so ? Yr comment No.3 is surely logistically impossible and therefore incorrect even without the USDA restriction ? Somewhere there must also be a testing technical  issue involving LOD ? ie what is the analytical definition of "free"?.

 

(2) As stated, yr points no.4-6 seem (to me) to demand perfect intuition. (Somewhat similar to the visual procedure in use for declaring some food production lines are allergen-free).

Is this procedure in any way (officially?) validated, eg by testing  of the output (claimed) ABF product ?

 

If not, then I just don’t understand where the Science is.

 

(3) Ultimately, for yr assumed "ABF" product do you use a label like  “non-USDA ABF” ? ie what labelling do USDA actually accept ? (I assume USDA must authorise the onward commercialisation of the labelled  "ABF" product?)


Kind Regards,

 

Charles.C


#13 MWidra

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Posted 15 October 2015 - 03:58 PM

CharlesC, this is part of the USDA's process verified program.  There may be science in some of the programs, but not in others.  It's based on ISO 9000 quality verification techniques.

 

There is a labeling that is allowed to be used, and the USDA has to approve your wording and the use of their PVP shield.

 

Here is an overview of this program, which is used for all kinds of claims.  The USDA does not prove that your claim is true, only that you have set up a process that would allow you to make the claim and that you follow it.

 

We are working with them to set up a process approved plan for GMO-Free.  It is an interesting program.

 

http://www.ams.usda....rified-programs

 

Martha


"...everything can be taken from a man but one thing:  the last of the human freedoms--to choose one's attitude in any given set of circumstances, to choose one's own way."  Viktor E. Frankl

 

"Life's like a movie, write your own ending."  The Muppets


#14 Charles.C

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Posted 15 October 2015 - 04:07 PM

Hi Martha,

 

Thanks for the link.

I note they use verify and not validate. Interesting.

Indeed, the USDA ABF concept described by Turkey sounded like a derivative of GMO. Or perhaps a precursor.?

 

I guess It will be informative to see Turkey's operational response, particularly in the context of yr link.

 

PS - i did do a little intial browsing and noticed this (to me) interesting, but lacking detail, link -

 

http://www.greenerch...cfm?LabelID=102

(maybe some of the comments are answered in the documents within yr link)

 

PPS - i also can see the ethical dilemma as well detailed by gfdouchette. Given the volumes involved, a withdrawal compromise is presumably complex?.(a similar approach has afaik been used elsewhere also, eg farmed seafood)


Edited by Charles.C, 15 October 2015 - 04:38 PM.
expanded slightly

Kind Regards,

 

Charles.C


#15 Turkey

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Posted 19 October 2015 - 03:17 PM

Charles,

The term antibiotic free is not a legal claim on a label, we state that the animals were raised without added antibiotics and this claim is validated through documentation that our supplier has given to USDA and provided us.

The testing that happens on all meat regarding antibiotics is to test for antibiotic residue, since a withdraw of antibiotic usage is required before harvesting the animal. So as far as a level of detection for residual testing there is one, yes. However, there are no tests that I can perform after sanitation that would verify that the equipment is free from antibiotic residue resulting from running non-ABF meat. Furthermore, since all meat is tested for antibiotic residue before we process it, it is technically "free from antibiotics" therefore, there is no need to test the equipment. Letters of guarantee, CoA's etc. accompany each shipment of meat received to validate this.

I am not sure of your reference to visual inspection for allergens, as there are tests available for the detection of residual allergen on equipment after the sanitation process. However, the main issue in the ABF and non-ABF is to make sure that the meat does not intermingle and a visual inspection to make sure the line is free from non-ABF is sufficient. Treating it as a species change over and using a water spray down followed by visual inspection, defines the break between the products to ensure that they are not mixed.



#16 Charles.C

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Posted 19 October 2015 - 07:49 PM

Hi Turkey,

 

Thks for yr comments.

 

Perhaps my technical caveats were not stated clearly enough.

 

I am ccertainly no expert on USDA's methodologies.

 

I guess we'll have to agree to (maybe) disagree. No problem.


Kind Regards,

 

Charles.C





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