Bone food safety hazard
Does anyone have any support to bone not being considered a food safety hazard, besides the FDA's hard sharp objects regulation? The products I am working with are intended for the general public and have chicken meat dices included. The occurrence of bone has historically been very low, but our HACCP plan declares it as a reasonably foreseeable hazard. I'm working towards removing this as a hazard due to us being incapable of detecting 100% of bones on our x-ray ccp, and the occurrence rate being so low. I have considered sending what chicken bones I have found for density testing and comparing that with our x-ray technical manual to see if the density is considered not capable. But any other technical support or advice if you have been in a similar situation would be greatly appreciated.
Does anyone have any support to bone not being considered a food safety hazard, besides the FDA's hard sharp objects regulation? The products I am working with are intended for the general public and have chicken meat dices included. The occurrence of bone has historically been very low, but our HACCP plan declares it as a reasonably foreseeable hazard. I'm working towards removing this as a hazard due to us being incapable of detecting 100% of bones on our x-ray ccp, and the occurrence rate being so low. I have considered sending what chicken bones I have found for density testing and comparing that with our x-ray technical manual to see if the density is considered not capable. But any other technical support or advice if you have been in a similar situation would be greatly appreciated.
Hi rachel,
Not my area but I imagine the answer is somewhere in here -
Dear Rachael_Ray37
I have attached the Federal Register announcement and the document that it references concerning bone in meat & poultry. These are 11 years old, but I have not seen or heard of anything newer.
I think you have an issue with X-Ray as a CCP in that poultry bones are a tough find for that technology beacuse of the density concerns you mentioned. If you get a customer complaint, then your CCP failed. I would look to the minimum detectable size by your equipment - if is is better than 7mm, then that, along with the document and FDA's FM guidance should provide sufficient support...depending on our intended target and reasonableness that the elderly and young will not consume.
KTD
Bone Particles & FM in Meat & Poultry Prod - FR.pdf 194.7KB 63 downloads
Bone Particles & FM in Meat & Poultry Prod.pdf 9.98MB 69 downloads
Does anyone have any support to bone not being considered a food safety hazard, besides the FDA's hard sharp objects regulation? The products I am working with are intended for the general public and have chicken meat dices included. The occurrence of bone has historically been very low, but our HACCP plan declares it as a reasonably foreseeable hazard. I'm working towards removing this as a hazard due to us being incapable of detecting 100% of bones on our x-ray ccp, and the occurrence rate being so low. I have considered sending what chicken bones I have found for density testing and comparing that with our x-ray technical manual to see if the density is considered not capable. But any other technical support or advice if you have been in a similar situation would be greatly appreciated.
Hi rachel,
Bones in food seem to have always been a rather contentious subject with respect to haccp hazard analyses. Most publications somewhat side-step the feature.
I was unable to find any recent (poultry) refs where bone fragments were associated with CCPs and the popular FDA reference tends to imply to disregard unless specifically labelled as boneless, eg -
Hard or sharp natural components of a food ( e.g. bones in seafood, shell in nut products) are unlikely to cause injury because of awareness on the part of the consumer that the component is a natural and intrinsic component of a particular product. The exception occurs when the food="s" label represents that the hard or sharp component has been removed from the food, e.g., pitted olives. The presence of the naturally occurring hard or sharp object in those situations (e.g., pit fragments in pitted olives) is unexpected and may cause injury. FDA has established Defect Action Levels for many of these types of unavoidable defects in other Compliance Policy Guides and therefore they are not subject to the guidance in this document.
the data from KTD's remarkable archive seems to still be sort of relevant based on these two relatively recent articles -
method-developed-to-detect-bone-fragments-in-boneless-chicken.pdf 318.14KB 42 downloads
Getting a Handle on Foreign Materials.pdf 1.3MB 61 downloads
This recent haccp plan seems to regard >7mm bones as a hazardous criterion although the topic is not further explored within the (rather questionable) CCP analysis.
haccp plan for chicken ball plant.pdf 109.06KB 52 downloads
PS - i might add that despite the above comments i have always (traditionally) included a deboning step as a CCP stage in my seafood haccp plans via a, laboriously located, size definition for a (seafood) hazardous bone.
Thanks so much!