BSE - Questions & Answers Part 2

• The rules will not be retroactive. The non-ambulatory disabled ban took effect December 30. The interim rules only apply to products that are derived from cattle slaughtered on or after Monday, January 12, 2004.

What is “presented” for slaughter? Can the animals be removed from the premises if not presented?

• Animals that are identified to inspection program personnel for ante-mortem inspection and are on the premises (or have not been specifically excluded from inspection) are considered to be presented. They can be removed if they have not been presented and have no other restrictions placed on them. If they have been presented, they can be removed with the permission of, and under the supervision of, the proper officials.

Are (bob veal) calves under the same restrictions?

• All cattle, (i.e. bovines: Bos taurus, Bos indicus) not all ruminants, are subject to the provisions of the non-ambulatory disabled rule. This includes calves. The existing regulatory provisions providing for treating animals on site, or moving to another location remain.

If a non-ambulatory disabled animal is brought on an official establishment premises, but not removed from the transport vehicle and not presented for inspection, what is FSIS’s role?

• FSIS is to ensure that the animal is humanely handled.

Are FSIS VMOs to call APHIS for dead animals on the transport vehicles coming on official premises or ones that are rejected by the establishment and have not been presented for inspection?

• No.

Are FSIS VMOs to call APHIS for any/all non-ambulatory disabled cattle condemned by FSIS?

• Yes, VMOs should call the Area Veterinarian-In-Charge (AVIC). The call should be documented with the name of the APHIS contact and whether APHIS decided to test. Helpful information that FSIS VMOs may provide include whether the animal was non-ambulatory disabled and whether the animal exhibited CNS signs. This is further discussed in FSIS Notice 5-04.

If a sample is taken by APHIS from a non-ambulatory disabled animal and the plant has no capability to hold the carcass pending test results where can the carcass be taken?

• Carcasses can be sent to a lined landfill, in accordance with state or local sanitary codes. The establishment must maintain records of carcass disposition. These records should include the identification of the animal.

When establishments are slaughtering non-segregated animals of mixed ages (both less than 30 months as well as 30 months and older) what is the required intervention for cleaning the equipment (e.g., splitting saw) between animals?

• All plants that slaughter cattle and/or process cattle carcasses or parts have the responsibility of developing, implementing, and maintaining written procedures for the removal, segregation, and disposition of Specified Risk Materials (SRMs.) These procedures must be incorporated into the plant’s HACCP plans, SSOPs, or other pre-requisite program.
  
  This could be accomplished by segregating the older (30 months and older) and younger (less than 30 months) cattle, then slaughtering and processing the younger cattle first, followed by the older animals. The establishment should be cleaned and sanitized before slaughtering the next group of younger animals to prevent cross-contamination of the younger cattle with SRMs from the older cattle. The establishment can also determine other acceptable means to meet these requirements.
  
  For example, when 30 months of age and older cattle are intermingled with younger cattle, an establishment may include cleaning and sanitizing procedures in their operational sanitation SOPs for equipment to prevent cross contamination. These procedures need to address sanitation between slaughter of animals 30 months of age and older and subsequent younger animals. Please refer to FSIS Notice 10-04.

Can T-bones, brains, and the like, be saved from older animals (30 months and older) in custom exempt facilities?

• SRMs are considered adulterated and ineligible for human food. This applies to custom slaughter as well as to inspected operations. As such, traditional bone-in cuts of beef, such as T-bones, porterhouse, and rib roasts cannot be saved for human food, unless the SRM portion of the cut (i.e. the vertebral column) is removed, resulting in a semi-boneless cut. The other alternative is to completely bone out the product.

Can I cut steaks from the loins of cattle 30 months of age or older first and then remove the SRMs associated with the vertebral column?

• No, at this time FSIS believes that potential contamination with exposed dorsal root ganglia (DRG) should be limited to the maximum extent practical and does not view this additional contamination as necessary or appropriate.

Must the SRMs be removed at slaughter?

• No, there is no requirement to remove the SRMs at slaughter. The carcasses/parts can be shipped to another inspected facility provided documentation to ensure the removal of the SRMs from products for human food accompanies the product. The shipping establishment must consider in their hazard analysis, decisions on food safety hazards that can occur before, during, and after entry into the establishment.
  
  Are the SRMs allowed to go to inedible rendering?
  
  SRMs are currently not restricted from entering inedible channels (e.g. rendering); however, when an animal is being tested by APHIS for BSE, FSIS inspection personnel should request that the SRMS not go into inedible rendering until a negative BSE result is obtained.

If SRMs are not rendered can they be denatured and sent to an approved landfill?

• FSIS considers it acceptable to send carcasses or parts from animals that are being tested by APHIS for BSE to a lined landfill, in accordance with state or local sanitary codes, when a test result has not yet been received. The establishment must maintain accurate records documenting the location of carcass or parts disposal.

If the establishment is removing the meat from around the vertebral column with electric (“wizard”) knives, is this a potential problem when used around the transverse processes of the thoracic and transverse vertebrae?

• FSIS is not currently restricting such manual deboning procedures. However, as noted in the January 12, 2003 interim final rule on SRM, FSIS is seeking comments on whether this procedure may contaminate meat with an SRM. It is up to the plant to develop, implement, and maintain written procedures for the removal, segregation, and disposition of SRMs. These procedures must be incorporated into the plant’s HACCP plans, SSOPs, or other pre-requisite program.

Is the shipping establishment required to provide documentation with every shipment?

• The shipping establishment must include in their hazard analysis decisions on food safety hazards that can occur before, during, and after entry into the establishment. The shipping establishment can ship bone-in product with SRMs (e.g. vertebral columns) as long as they verify their removal in the receiving establishment. In addition, the shipping establishment must provide documentation on every shipment of product containing SRMs (e.g. vertebral columns from cattle 30 months and older) to the receiving establishment. Please refer to Notice 4-04.

If the shipping establishment is removing all SRMs, is there a need to certify every shipment?

• No. If the establishment is also shipping bone-in products from cattle under 30 months, they should provide adequate documentation to the receiving establishment that verifies their SRM control programs. This would not necessarily be needed on a shipment by shipment basis.

Must a receiving establishment have certification from the shipping establishment if they are receiving bone-in products?

• One option that may be used is for the receiving establishment to have a letter from its supplier attesting to the fact that product is from cattle under 30 months. However, as with E. coli O157:H7, FSIS would expect the receiving establishment, as part of its prerequisite program, to perform on-going verification. This can be accomplished by visiting or contacting the shipping plant on a quarterly basis to verify the shipping plant's on-going commitment to its assurance. FSIS would also have the same expectation with respect to assurances that the carcasses or parts shipped are from animals under 30 months.

Do the SRM regulations apply to custom slaughter? Can cattle be farm slaughtered and processed in custom facilities?

• Specified Risk Materials are considered adulterated and are not eligible for human food—this applies to custom products as well. Cattle can be farm slaughtered and processed in custom facilities, provided they were not non-ambulatory disabled cattle, which are adulterated. The requirement for written control programs does not apply to custom operators.

What is the FSIS policy on custom slaughter? For example, if a producer has an animal that he/she wants killed for consumption by his/her own family, and the animal has a broken leg that won’t allow it to walk, can he/she take it to a custom plant and have it slaughtered for his/her own use, (i.e. not for sale)?

• All non-ambulatory disabled cattle are to be precluded from the human food chain (i.e., condemned). This determination is derived from the Title 1 Section 1 (m)(3) of the Federal Meat Inspection Act. Specifically,
  
  The term ''adulterated'' shall apply to any carcass, part thereof, meat or meat food product under one or more of the following circumstances: if it consists in whole or in part of any filthy, putrid, or decomposed substance or is for any other reason unsound, unhealthful, unwholesome, or otherwise unfit for human food.
  
  Ambulatory cattle may be custom slaughtered under our current regulations (9 CFR 303.1).

When an establishment has a non-ambulatory disabled cow they want to slaughter "custom exempt" at a federally inspected facility, should the on-site FSIS inspector segregate it and call a VMO so it can be condemned?

• If the establishment is preparing to custom slaughter a non-ambulatory disabled cow (cattle) at a federally inspected establishment, then the animal should be controlled by the inspector until the VMO can condemn it. If the animal has not been presented for inspection, it could be removed from the premises without permission from FSIS. (If FSIS personnel have reason to believe it will be taken elsewhere for slaughter—then OPEER should be informed. The burden of proof is on FSIS).