17 replies to this topic

[LSB]

Greetings all,

I have a question about allergens in a beef slaughter setting. Is anyone here a beef slaughter and certificated to BRC? If so are you considering the milk of the cow as an allergen?

We have previously stated that "no allergens are used in the process", but do have other PRP's in place to mitigate the risk, and government regulation.

Any advice would be much appreciated, i am only a year and a half into BRC.....

[Charles.C]

Greetings all,

I have a question about allergens in a beef slaughter setting. Is anyone here a beef slaughter and certificated to BRC? If so are you considering the milk of the cow as an allergen?

We have previously stated that "no allergens are used in the process", but do have other PRP's in place to mitigate the risk, and government regulation.

Any advice would be much appreciated, i am only a year and a half into BRC.....

 

Hi LSB,

 

Apologies for my ignorance regarding beef slaughter but can you supply a little more BRC related context to yr query ? eg  Is there a specific clause involved ?

 

Why do you think yr cow's milk is not an allergen ?

[mgourley]

Charles,

It's actually a good question the OP asked. And I think he answered your last question in his post.

Regardless the food safety standard, is milk considered when bovine (or other) slaughter HACCP/Food Safety Plans are put together?
 

I would be interested to see what people in that industry have to say, since I am totally ignorant of live kill facilities.

 

Marshall

[Charles.C]

Charles,

It's actually a good question the OP asked. And I think he answered your last question in his post.

Regardless the food safety standard, is milk considered when bovine (or other) slaughter HACCP/Food Safety Plans are put together?
 

I would be interested to see what people in that industry have to say, since I am totally ignorant of live kill facilities.

 

Marshall

 

Hi Marshall,

 

Yes, you're right. Partially anyway, maybe.

 

Along with things like antibiotics and hormones.

 

I could not find any hazard consideration of milk allergen in beef haccp plans although there are literature claims of occasional, allergic type correlations to eating meat.

 

One sample haccp plan -

 

 haccp beef hazard analysis, 2012.doc   79.5KB   27 downloads

[LSB]

Specific BRC related context would be anything pertaining to risk assessment of allergens. I do not have the specific clause listed in this instance.

In beef slaughter there is a documented 0 tolerance check for fecal, milk, and ingesta. My thoughts being i could use that as a preventative control of some sort; but in regards to a direct hazard analysis or risk assessment i have not completed due to the fact it has never been an issue before. i know some others in the industry identify it as an allergen, which is correct; but i just do not know if opening up that can of worms i will do any good since preventative controls and hot water pasteurization is utilized. Back to one of the comments, i do not think that milk is not an allergen, but it not specifically used as an ingredient in the fabrication of any of our products is my thought process. Am i wrong in that statement?

[Charles.C]

Specific BRC related context would be anything pertaining to risk assessment of allergens. I do not have the specific clause listed in this instance.

In beef slaughter there is a documented 0 tolerance check for fecal, milk, and ingesta. My thoughts being i could use that as a preventative control of some sort; but in regards to a direct hazard analysis or risk assessment i have not completed due to the fact it has never been an issue before. i know some others in the industry identify it as an allergen, which is correct; but i just do not know if opening up that can of worms i will do any good since preventative controls and hot water pasteurization is utilized. Back to one of the comments, i do not think that milk is not an allergen, but it not specifically used as an ingredient in the fabrication of any of our products is my thought process. Am i wrong in that statement?

 

Hi LSB,

 

It is probably more accurate to focus on risk assessment/hazards associated with the process inputted items in respect to their impact on the finished product / safety of the final consumer. This is formally defined by the Scope of the HACCP Plan.

 

Related hazards can be intrinsic or extrinsic, direct or indirect, as evaluated for example using  ingredient hazard "trees" and listed in analyses such as previous attachment. (for a  typical "tree" see the excel example in post/thread here -

https://www.ifsqn.co...nts/#entry38494

 

Operationally, from a "CCP" POV, it is common to set the Allergen Control Program as a PRP which is noted in BRC7 (clause 2.2.1).

 

I'm not very familiar with haccp / slaughter business however I anticipate that the "allergenic aspect"  must have been considered already in the Literature (somewhere) since you can find it discussed in  respect to final  consumption meat consumption. I  note there is no mention of allergenic hazards in the haccp plan previously attached which should be fairly US - authoritative (ex "meathaccp" website).

 

Perhaps beef processors here may have further allergen-related comments.

[Scampi]

Not familiar with beef HOWEVER, in Canada in poultry that is OVER 12 weeks of age, an allergen statement must be in place for the presence of EGG.................

 

found this from https://www.fsis.usd...pdf?MOD=AJPERES

 

3. Hide removal (manual and mechanical) a. This is the point in the process where the hide is removed from the animal. Hides are a significant source of contamination (e.g., dust, dirt, feces, mud). It is important to maintain sanitary conditions when handling the hide. b. Questions that IPP are to consider when verifying sanitary dressing and process control procedures at hide removal include, but are not limited to: i. What measures does the establishment use that minimizes the likelihood of contamination of the carcass during the opening of the hide (other than sticking)? For example: 1. Has visible contamination been removed at the cut line (e.g., with air knives or by steam vacuuming)? 2. Does the establishment remove the udder in a manner to prevent contamination of the carcass with milk, as well as to prevent contamination of the exposed carcass by the hide, or by a soiled knife or employee hand? 3. What measures does the establishment use to limit cross

 

 

So in order to satisfy BRC and USDA you need control measures in place.....and should the udder be perforated, you need some sort of written deviation to handle the carcass in question

 

Hope this helps

[Charles.C]

Hi Scampi,

 

Some good searching.

 

i attach the relevant further mentioned FSIS reference within yr link.

 

 FSIS_6420.2.pdf   64.61KB   23 downloads

 

I note there is a stated zero tolerance for visible milk.

 

However no mention of allergenic associations/ implications

[MsMars]

OP... My two cents is that you don't open that can of worms.  Admittedly I have no bovine slaughter experience, but in poultry slaughter it's the same zero tolerance policy for feces and ingesta, but obviously did not consider feed components (as would be contained in ingesta) as allergenic risks. My line of thinking is that milk would fall under this same umbrella, and you are on the right track with your preventive control UNLESS for whatever reason udder perforation is just common practice or occurrence and you're dealing with A LOT of milk.

[MsMars]

Addition to previous post: perhaps you could do a swab study for milk protein if you were concerned?

[Charles.C]

Addition to previous post: perhaps you could do a swab study for milk protein if you were concerned?

 

I'm still surprised if  FSIS have not looked at this aspect already and "somehow" discounted it as a significant risk. Particularly as consumer reports seem to support some related allergenic events.

[MsMars]

Particularly as consumer reports seem to support some related allergenic events.

 

I guess I had never heard of this.  Was this related to milk contamination from processing, or the more common occurrence of a subsequent beef allergy diagnosis in someone with a milk allergy?

[Scampi]

It's a specific allergen point as it relates to BRC Mrs.Mars

 

The guidance doesn't suggested it is considered an allergen, and one could assume that the heifers would be weaned from milking prior to slaughter (kind of like feed withdrawl for medication)

 

Here is a USDA beef slaughter model where it says;

 

"Potential hazards should be controlled through the SSOPs, and the application of a microbiological intervention(s) later in the process. Recommend that the establishment should develop a written SOP for the entire dehiding process to demonstrate the proper skinning procedure"

 

http://haccpalliance...efslaughter.pdf

 

So i'm thinking it's not an allergen per say, but like Mrs Mars pointed out about poultry, slaughterhouses are required to have a process in place to deal with a carcass IF it becomes contaminated (we don't condemn poultry with spilled ingesta.....those carcasses are reconditioned)

Edited by Scampi, 10 December 2018 - 08:51 PM.

[MsMars]

I do certainly see how milk (along with feces and ingesta) pose a microbial contamination risk. So OP probably has controls in place for that. But an allergen risk? To me, that's a stretch. 

 

As Charles said in post #4, I've found documented cases of allergic reactions after eating meat - because of an allergy to meat.  But documented cases of an allergic reaction to meat stemming from milk contamination? Nil. 

 

I'll stand by my original advice in that IMO when it comes to mentioning milk as an allergen, I would keep the lid tightly on the can. 

[LSB]

Thanks for all the great comments/ dialogue here. i could not agree more about keeping a lid tight as preventative controls are already in place, and it is not a issue (perforation of mammary glands).

You guys rock! 

[Charles.C]

I guess I had never heard of this.  Was this related to milk contamination from processing, or the more common occurrence of a subsequent beef allergy diagnosis in someone with a milk allergy?

 

Hi MsMars,

 

Apologies -  I previously slightly misunderstood some references  I noted which discussed a connection between milk allergy and eating beef however the biochemical reason is a potential correlation between certain structurally similar allergenic constituents in each food matrix but  not due to milk residue in the beef, per se.

 

These comments illustrate the issue although some "disparity" is apparent -

 

Note: A small number of people with cow's milk allergy may develop a reaction to beef. Thus, those with cow's milk allergy should be careful when eating beef or foods containing beef.

https://www.hopkinsm..._diet_85,P00023

cf. -

 

Parents often wonder whether their child can eat beef, since milk and beef both come from cows. But recent studies have shown that children with cow's milk protein allergy only rarely have problems eating beef or veal. Therefore, most milk allergic children can eat beef without any problem.

http://www.drpaul.co...milkallergy.php

 

PS - Also noticed these quite interesting compilations during searching -

 

 Survey - Undeclared food allergens,2018.pdf   195.15KB   16 downloads

 Review - Bovine Milk Allergens,2017.pdf   718.29KB   20 downloads

 

No comments observed regarding detection of milk residues in raw beef.

[MsMars]

Review - Bovine Milk Allergens,2017.pdf

 

"However, none of them reacted with heated meats, suggesting the implication of heat denaturation in the reduction of serum albumin allergenicity..."

 

Very interesting read Charles - certainly illustrates the complexity of milk allergy!

[Scampi]

I just wanted to add that this is a case where a facility needs an auditor who really is an expert (or at the very least has worked in the field) slaughter. GFSI have to write programs that will function for most facilities.  This is a case of process trumping a clause