# Presentation: 574963

## A Comprehensive Feed SafetyApproach for Rendered Products FDA Public MeetingDiscussion of Animal Feed Safety System September 23, 2003

- David Harlan
- Taylor Packing Co., Inc
*An Excel Food Solutions Company*

**Notes:**
Thank Dr. Erdtmann and the Institute of Medicine for the invitation.

My background is primarily from the rendering side of the beef packing industry. 

Presentation will cover both the edible beef processing and rendering sides of the business.

**Food Animal **
**Production**

**Pet **
**Foods**

**Rendered**
**Co-Products**

**Animal Feed**
**Manufacture**

**Meat **
**Processing**

**Feed Ingredients**

**Consumer**
**Foods**

- Rendering Cycle Plays a Critical Role

## Beef Processing Typical Fed-Cattle Plant

- Dressing Floor

-  Fabrication

- Further Process

- Edible Beef Products

- Inedible
- Rendering

- Beef Processing Typical Fed-Cattle Plant

- Blood Drying

- Edible
- Rendering

**Feed & Technical**

- USDA                *Ante mortem*

**Notes:**
Fed cattle are typically processed in the following manner.  

A large beef processing facility will process 4 to 6,000 head of cattle each day.  

Prior to entering the dressing floor, the USDA conducts ante mortem inspection on the live animal.  

The animal is stunned, bled and then dressed during which the USDA conducts post mortem inspection on the carcass and organs.  

Once complete the sides of beef are chilled for several days.  Then they are fabricated into wholesale beef cuts.  

These cuts and meat trimmings can be further processed on site into case ready or ground beef products or shipped to specialized meat processing facilities. 

Inedible portions of the carcass generated during dressing are sent to an inedible rendering plant for the production of MBM and tallow.  

However, bones and fat trimmings from fabrication go to a separate edible rendering process where fat is melted to produce edible tallow and dried bone is sold for gelatin manufacture.  

In addition blood is processed to produce a dried blood meal.   

## Beef ProcessingTaylor Packing

- Dressing Floor

-  Fabrication

- Edible Beef Products

- Inedible
- Rendering

- Beef ProcessingTaylor Packing

- Blood Drying

- Feed & Technical

- USDA                *Ante mortem*

- Further Process

**Notes:**
While very similar to fed-cattle plants, cow plants are typically smaller in scale and generally do not contain an edible rendering process.  

This schematic is typical of Taylor Packing where we processes around 1900 head of cattle a day the majority being cull dairy cows.  

Materials generated from both the dressing and fabrication steps are mixed together and then rendered.  

## Taylor Rendering Process

- CENTRIFUGE

-  Dressing Offal

**C**
**O**
**O**
**K**
**E**
**R**

**MIX & **
**GRIND**

-  Fab Bone & Fat

- PRESS (3)

**SCREEN**

- Solid

- Liquid

- COOLER

- STORAGE

- GRIND/SCREEN

- LOADOUT/
- BLENDING

- TANK

- FILTER

- BEEF TALLOW
- TANKS

## Comprehensive Program

- Philosophy & Commitment
- Raw Material Source, Specifications & Assurances
- Hazard Analysis & Critical Control Point program
- Good Manufacturing Practices
- Employee Training Programs
- Transportation Policy
- Third Party Audits

## Philosophy & Commitment

- Preventative Mindset
- Proactive vs. Reactive
- Continuous Improvement
- Commitment from Entire Team
- Leadership
- Management
- Production

## Raw Material Specifications

- In-House Packer Source – 100% Bovine with mixed supply from 70% mature cows and 30% fed-cattle
- 100% from Cattle Passing Ante Mortem Inspection Conducted by USDA:FSIS Veterinarian
- Packinghouse Training & Awareness Relative to Potential Physical & Chemical Contaminants
- CNS Tissue Removed in Packinghouse

## Hazard Analysis and Critical Control Point (HACCP) 7 Principles

- Assess Hazards
- Determine Critical Control Points – CCP
- Establish Critical Limits for CCP’s – CCPCL
- Procedures to Monitor CCP’s
- Develop Corrective Action Plans
- Recordkeeping
- Verification

## Potential Hazards3 Classes

- Biological
- Microbiological
- Insect Infestation
- TSE’s
- Chemical
- Pesticides & PCB’s
- Lubricants, oils, etc.
- Physical
- Metal
- Plastic

## HACCP Example Microbiological - Pasteurization

- Assess Hazard
- Raw material contains potential pathogens
- Determine Critical Control Points – CCP
- Cooker discharge temperature - **TEMP**
- Raw material grind - **GRIND**
- Processing rate - **RATE**
- Establish Critical Limits for CCP’s – CCPCL
- TEMP - Minimum 270**o** F based on validation study
- GRIND - Maximum 30 mm anvil gap on pre-breaker
- RATE - Maximum 36,000 pounds/hour feed rate

## HACCP – MicrobiologicalContinued

- Procedures to Monitor CCP’s
- TEMP - Continuous monitoring by certified thermocouple
- GRIND - Inspection, Weekly measurement of anvil gap
- RATE - Computer tracking of cooker feed auger
- Develop Corrective Action Plans
- TEMP - Alarm notification, automated discharge shutoff
- GRIND - Repair, Rebuild when gap reaches 30 mm
- RATE - Reduce feed rate if over 36,000 pounds/hour

## HACCP – MicrobiologicalContinued

- Recordkeeping
- TEMP - Computer tracking of CCP and alarm log
- GRIND - Operations & maintenance logs
- RATE - Computer tracking of CCP and alarm log
- Verification
- Clostridium perfringens testing – indicator organism
- 15 day intervals
- Rotate shift  and time within shift

## Plant Operator Screen

## Recordkeeping

- _Recordkeeping_
- Cooker
- Temperature
- Trending and
- Statistical Analysis

## Good Manufacturing Practices (GMP)

- Housekeeping Issues
- Recordkeeping
- Pest Control Program
- Facility Design & Repair
- Sanitation Program
- Startup & Shutdown Procedures

## GMP Example Prevent Salmonella Recontamination

- APPI model adopted by +99% of industry
- Process zones in facility
- Work habits & policies
- Startup procedures
- Reprocessing of product spills
- Dry cleaning of finished product areas
- Sanitation practices that target “hot spots”
- Facility design & equipment maintenance
- Effectiveness verified by finished product testing

- No CCP available except formaldehyde addition

## Employee Training

- Specific Modules on HACCP, GMP’s and SOP’s
- New Hires
- Entry at Trainee position
- Individualized training over several months
- Career Advancement
- Training program for each position
- Certified by written & verbal testing
- All Employee’s
- Quarterly quality training
- Immediate team review of feed safety issues

## Transportation Policy

- Certification of regulatory compliance by carriers
- Trucks are only to haul agricultural commodities
- Trucks are to be clean _prior_ to arrival
- Visual inspection of empty trucks upon arrival
- No visible carryover regardless of past ingredient hauled
- Will the integrity of our product be maintained?
- Assurance of cleanout after delivery
- Included in policy signed by carriers & drivers
- Prominent reminder to driver attached to Bill of Lading

- Clean Conveyances and Inspection Prior to Loading
- Is the Responsibility of Every Ingredient Supplier!!

## Third Party Audits21 CFR 589.2000

- APPI Certification via Cook & Thurber
- Found high compliance in Rendering Industry
- Confirmed by FDA Inspections
- Discontinued because of high compliance
- Facility Certification Institute - FCI
- Requirements are based upon FDA rule
- Must prove compliance with FCI program
- Ingredient supplier and transport certifications
- Must demonstrate adequacy of flushing when             co-mingling restricted use products
- Annual audits to maintain status in program

## Thank YouSpecial Thanks To:Debby Capela, Taylor Packing The Taylor & Excel Rendering Team