One Meating Place Elizabethtown, PA 17022 Phone: [phone] Fax: [phone] Website: www'aamp'com

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One Meating PlaceElizabethtown, PA 17022
Phone [phone] Fax (717)
367-9096Website www.aamp.comEmail
aamp_at_aamp.com
AAMP Update 2009
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Topics

• Legislative Issues
• Interstate Shipment, COOL
• Regulatory Issues
• E. coli O157H7, Non-Ambulatory Cattle, HACCP
  Plan Validation, Food Defense
• Custom/Retail Exemptions
• Humane Handling
• FDA Feed Ban/Rendering
• AAMP Resources
• Website, Nutrition Labeling Services
• AAMP Convention

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Does it Affect You?

• If you think that these topics or regulations
  dont affect you, you may be wrong!

• State Inspection Programs
• Must enforce requirements "at least equal to"
  those imposed under the Federal Meat and Poultry
  Products Inspection Acts
• Custom/Retail Exemption
• Must comply with the regulations in 9CFR 303 -
  Exemptions

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Legislative Issues
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Interstate Shipment

• Passed as provision within the 2008 Farm Bill
• Creates Title V Program for the Federal Meat
  Inspection Act
• Optional program for state-inspected plants with
  25 employees or less
• Does not replace existing state program
• States will have to individually adopt the
  program to utilize it

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Interstate Shipment

• USDAs Role State Coordinator a federal
  employee responsible for each state to provide
  oversight
• Will reimburse states for at least 60 of the
  costs
• Establish a program for state-inspected plants
  with more than 25 employees to transition to
  federal inspection if they are interested in
  shipping interstate
• Provide grants for states to use to help state
  plants transition to the new Title V program

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Interstate Shipment

• Timeline currently developing program details
• Public comment period (public meetings and/or
  hearings) prior to promulgating final rule
• Enactment of the provisions within 18 months of
  releasing the final rule
• Concerns?
• How similar will this be to the T/A program?
• Will states adopt the program?
• Will plants take advantage of the program, or
  will it end up being too challenging?
• Will this negatively impact the state programs?

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Interstate Shipment

• Historically, AAMP has supported interstate
  shipment legislation as a fairness issue
• Many federal plants ask the question Why dont
  establishments simply go federal?
• Communication
• More education prior to regulation
• Dont want to go through the hassle
• Supporters are hoping that this option will prove
  to be viable

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Country of Origin Labeling

• COOL included in 2008 Farm Bill started
  implementation on September 30, 2008
• Final Rule went into effect March 16, 2009
• Commodities of interest beef, lamb, pork, goat,
  chicken
• Includes ground product and whole muscle cuts
• Animals already in the U.S. before July 15, 2008,
  are considered U.S. origin
• Definition of a Retailer for COOL
• Must be licensed under the Perishable
  Agricultural Commodities Act (PACA)

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Country of Origin Labeling

• Definition of a retailer under PACA
• Any person engaged in the business of selling any
  perishable agricultural commodity at retail
• Any location where invoice costs exceed 230,000
  of perishable agricultural commodity during a
  calendar year
• Definition of perishable agricultural commodity
  
• Fresh and frozen fruits and vegetables
• PACA licensing only applies to invoice costs of
  230,000 of fresh and frozen fruits and
  vegetables/year, and not revenue generated from
  other products.

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Country of Origin Labeling

• Product Designations
• U.S. Country of Origin, Multiple Countries of
  Origin, Imported for Immediate Slaughter, and
  Foreign Country of Origin

• Ground Product Labeling
• The country or countries-of-origin of the inputs
  that went into the product, OR a list of
  reasonably possible countries of origin that
  could be in the product
• 60-day inventory window

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Country of Origin Labeling

• Processed Products
• NOT COVERED under COOL

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Country of Origin Labeling

• February 20, 2009 letter from Secretary Vilsack
  encourages meat processors to
• Go above and beyond regulations
• Provide information about production steps (born,
  raised, slaughtered)
• Include information on processed meat products
• Reduce the time allowance for ground beef
  inventory

• USDA will be closely reviewing industry
  compliance related to these suggestions to
  determine the future of COOL

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New Presidential Administration Congress

• Power shift in Congress and Presidential seat
  with Democrats in control
• Many unknowns still missing key personnel
  appointments
• Food safety issues likely to be in the limelight
  with the latest food recalls could mean focus on
  Single Food Agency
• Secretary of Agriculture Vilsack already an
  advocate of this proposal
• Many in Congress support as well

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Regulatory Issues
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Addressing E. Coli O157H7

• Increasing scrutiny of this pathogen has led to
  new challenges for meat processors
• More emphasis being placed on testing programs
  for E. coli O157H7
• USDA considered revising the definition of
  adulteration to include E. coli O157H7 in
  primals and subprimals
• FSIS released new Draft Compliance
• Guides highlighting their expectations

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Addressing E. Coli O157H7

• Establishments have
• Struggled to determine what more they could do
• Questioned the USDA mark of inspection
• Assessed the amount of ground beef sold
• Determined if ground beef should be produced
  under the retail exemption regulations

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Addressing E. Coli O157H7

• FSIS Sample Testing Frequencies
• FSIS expects increased testing frequencies when
  using product that has not been previously
  tested.

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Addressing E. Coli O157H7

• When to test?
• Take sample when USDA samples
• Document information thoroughly
• Consider possible intensified testing during peak
  months (April through October)
• Hold tested product!
• Guidelines for Holding Tested Products available

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USDA Non-Ambulatory Cattle Position

• March 14, 2009, Agriculture Secretary Tom Vilsack
  Announced Final Rule for Handling of
  Non-Ambulatory Cattle
• USDA issued a final rule to amend the Federal
  meat inspection regulations for a complete ban on
  the slaughter of cattle that become
  non-ambulatory after initial inspection by FSIS
  inspection program personnel.

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USDA Non-Ambulatory Cattle Position

• Is the Non-Ambulatory Rule Applicable to Custom
  Establishments?
• 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
• Only ambulatory cattle may be custom slaughtered
  under the Agencys current regulations (9 CFR
  303.1).
• Custom operators are permitted to slaughter
  cattle that become non-ambulatory disabled after
  they are delivered if the custom operator does
  not observe any other condition that would render
  the animal unfit for human food.

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USDA Non-Ambulatory Cattle Position

• AAMP Release of Liability
• Document for processors to protect themselves if
  animals go down after delivery, prior to
  slaughter
• Tool to remind livestock producers of the
  applicable regulations related to downer animals
• Available on the AAMP website, www.aamp.com,
  under the Members Only section

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HACCP Plan Validation

• Previous published regulation
• 1996 Federal register 61 FR 38826-38827
• Title 9 CFR 417.4(a)(1) Validation,
  Verification, Reassessment

• Upon completion of the hazard analysis and
  development of the HACCP plan, the establishment
  shall conduct activities designed to determine
  that the HACCP plan is functioning as intended.

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HACCP Plan Validation

• According to FSIS officials
• This will be implemented to all HACCP plans, all
  CCPs, and all products within each HACCP
  category.
• Currently focusing on Listeria monocytogenes
  interventions in RTE products and E. coli O157H7
  interventions in raw beef products.
• Still awaiting specific guidance from FSIS
• No NRs or enforcement actions based on lack of
  in-plant validation until a Federal Register
  notice is issued

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Food Defense Initiative

• Currently voluntary, but FSIS is monitoring
  participation closely
• Third survey conducted in August of 2008
• 41 of total plants surveyed had a plan
  (previously 31)
• Large plants exceed 90 adoption small plants
  exceed 50 adoption but very small plants have
  less than 20 adoption
• FSIS intends to draft a proposed rule making food
  defense plans mandatory however, not a priority
  for issuance in FY09

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Food Defense Initiative

• Guidance
• AAMP website has sample plans available
• FSIS guidance material, Developing A Food
  Defense Plan for Meat and Poultry Slaughter and
  Processing Plants

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Small and Very Small Plant Outreach

• askFSIS
• Web Seminars or Webinars
• Regulatory Education Sessions
• Guidance documents, QAs, IKE Scenarios
• Small Plant News

www.fsis.usda.gov/Small_Very_Small_Plants/index.as
p
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Custom/Retail Exemptions
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Custom/Retail Exemptions

• Separate custom/retail products by time or space
• Custom operations are required by the FMIA to be
  reviewed periodically
• FSIS may refuse, withdraw, or modify any
  exemption when it is determined that such action
  is necessary.

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Retail Exemption

• According policy clarification from FSIS
• Retail sale is not restricted in interstate
  movement when processed under retail exemption,
  as long as original product was federally
  inspected
• Retail sale may be over the counter, via
  internet, or other means including common carrier
• What about multiple ingredient products sold to
  HRI?
• If poultry or raw meat product, retailer can add
  ingredients to inspected and passed amenable
  products that they grind and sell to HRI, within
  the limits of 9 CFR 303.1, without loss of retail
  exemption
• 9 CFR 303.1(f) prohibits retailers, under
  exemption, from the sale of cooked, cured, smoked
  meat products to HRI

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Retail Exemption

• FSIS will be taking more samples at the retail
  level for E. coli O157H7
• Authority given by the FMIA
• Samples taken at retail must be paid for by FSIS
  at fair market value
• In 2008, FSIS took 362 samples of raw ground beef
  from retail establishments nearly double what
  was taken in 2007

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Humane Handling
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Humane Handling

• Increased scrutiny of animal handling because of
  Hallmark/Westland Packing Co. incident in 2008
• Know the applicable regulations and policies
• 9 CFR 313 Humane Slaughter of Livestock
• Also applies to exotics (9 CFR 352.10)
• FSIS Directive 6900.1, Revision 1 and FSIS
  Directive 6900.2, Revision 1
• FSIS Notice 16-08
• HIKE Scenario examples

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Humane Handling Requirements

• Remember, you are liable for the animals as soon
  as the truck or trailer comes onto your property
  ensure that animals are handled properly as
  they are unloaded
• Maintain livestock facilities in good repair and
  always provide access to water in holding areas
• Animals must have room to lie down in holding pen
  if held overnight, and have access to feed if
  held longer than 24 hours
• Consider implementing a Systematic Approach to
  Humane Handling for your facility

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FDA Feed Ban Rendering Issues
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FDA Feed Ban

• New FDA Feed Ban is now in effect
• Designates Cattle Materials Prohibited in Animal
  Feed (CMPAF)
• The entire carcass of BSE-positive cattle
• The brains and spinal cords from cattle 30 months
  of age and older
• The entire carcass of cattle not inspected and
  passed for human consumption that are 30 months
  of age or older from which brains and spinal
  cords were not removed
• Tallow that is derived from other materials
  prohibited by this rule that contain more than
  0.15 insoluble impurities and
• Mechanically separated beef that is derived from
  the materials prohibited by this rule.
• Specified Risk Materials (SRMs) designated by
  USDA are different than CMPAF

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FDA Feed Ban

• Renderers likely to change their pick-up policies
• What are your options for disposing of unwanted
  material?
• Disposal in trash or local landfill
• Composting
• Incineration
• Burial
• FSIS permits the return of SRMs to customers,
  provided that they are properly denatured
• Renderers may require additional recordkeeping,
  documentation, and segregation of materials
• AAMP resources available in the Members Only
  section of www.aamp.com.

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Rendering

• Change in Feed Ban regulation means increased
  cost of rendering
• In turn, you must consider what costs need to be
  passed on to your customers
• Hide market currently collapsed
• Many processors receiving little to no money for
  their hides
• Due to state of the economy, demand for leather
  goods is down

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AAMPs Resources
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The AAMP Website

• Membership Benefits and Services
• Food Safety Information
• Events and Workshops
• Regulatory Affairs
• Meat Industry News
• Important Links
• Members Only Section

www.aamp.com It Is One Powerful Tool!
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Nutrition Labeling Services

• Genesis Nutrition Labeling Formulation Database
  meets USDA and FDA criteria
• Analysis include
• Camera-ready label format
• Food list with spreadsheet
• Pricing for each analysis
• 45 for AAMP members
• 85 for non-members
• Not just for meat products
• Benefits Reasonably priced, quick turn around
  time, and completely confidential!

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Questions