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VERIFYING SANITARY DRESSING – A SYSTEMS 

APPROACH 

Introduction 

There are two purposes of this module. First, we will provide some background 

information about sanitary dressing and the procedures in the slaughter 

processes for cattle and how they may impact sanitary dressing. Second, we will 

provide guidance on how to verify compliance using the instructions in FSIS 

Directives 6410.1 and the thought process for using the systems based approach 

to making compliance determinations. 

Resources 

FSIS PHIS Directive 5000.1 Verifying an Establishment’s Food Safety System

FSIS PHIS Directive 6410.1 Verifying Sanitary Dressing and Process Control 

Procedures by Off-line Inspection Program Personnel (IPP) in Slaughter 

Operations of Cattle of Any Age 

9 CFR 310.3, 310.17(a), 310.18(a), part 416, part 417 

Objectives 

To demonstrate mastery of this module, the student will 

1. Define: 

 Process control procedures 

 Sanitary dressing procedures 

 Contamination of carcasses and parts 

2. Describe the role of sanitary dressing and process control procedures as 

part of an establishment’s food safety system.

3. Identify points in the slaughter process where contamination is most likely 

to occur. 

4. Explain how to verify that slaughter operations are implementing 

appropriate sanitary dressing procedures to prevent contamination. 

5. Explain how to verify that establishments are properly applying 

intervention treatments. 

6. Describe how to use a system based approach to determining 

compliance. 

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Outline 

 Definitions 

 The Role of Sanitary Dressing Procedures in the Food Safety System 

 A Systems Approach to FSIS Verification of Sanitary Dressing and 

Process Control Procedures 

 Potential Contamination Points in the Slaughter Process 

 Establishment Interventions 

 Determining and Documenting Noncompliance 

Definitions 

Process Control Procedure: A defined procedure or set of procedures 

designed by an establishment to provide control of operating conditions that are 

necessary for the production of safe, wholesome food. The procedures typically 

include observing or measuring system performance, analyzing the results to set 

control criteria, and taking action when needed to ensure that the system 

continues to perform within the control criteria. The procedure would include 

planned measures taken by the establishment in response to any loss of process 

control. In addition, the procedure can be used as support for decisions made in 

the hazard analysis. 

Sanitary Dressing: Practice of handling carcasses by establishment employees 

and machinery, throughout the slaughter process, in a manner that produces a 

clean, safe, wholesome meat food product in a sanitary environment. 

Contamination of Carcasses and Parts: Carcasses and parts, based on 

organoleptic inspection, have been prepared, packed, or held under insanitary 

conditions that may have caused them to come into contact with filth, or that may 

have caused them to be injurious to health and are condemnable unless they can 

be effectively reprocessed. Contamination can originate from two sources: 

1. Substances not related to the species being slaughtered like, oils, rail 

dust, condensate, and unidentified foreign material. 

2. Substances related to the species being slaughtered like digestive 

content, milk, ingesta or bile. Sanitary dressing procedures minimize this 

type of contamination. 

The Role of Sanitary Dressing in the Food Safety System 

FSIS continues to find positive E. coli O157:H7 results in samples of ground beef 

and trim, and we continue to have recalls - some associated with human illness. 

These positive results can be attributed to ineffective sanitary dressing and 

process control procedures that lead to insanitary conditions during slaughter. 

Improvement in sanitary dressing and other process controls can reduce the 

levels of Salmonella and other enteric bacteria. FSIS believes that 

establishments should focus more closely on their sanitary dressing and process 

control procedures to prevent carcass contamination. 

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Effective Sanitary Dressing Procedures Prevent Carcass Contamination 

Effective sanitary dressing and process control procedures are crucial to an 

establishment’s ability to produce a clean, safe, and wholesome product.

Establishments must handle beef carcasses, organs and other parts in a sanitary 

manner and prevent contamination with fecal material, urine, bile, hair or dirt, or 

foreign matter in accordance with 9 CFR 310.18(a). Since these sources can 

contain pathogens, establishments should reduce the potential for exposure to 

any food safety hazard during removal of hide, feet, GI tract, and internal organs. 

The design of the establishment’s slaughter operation must include a means to 

measure how well the sanitary dressing procedures accomplish this purpose and 

actions if contamination does occur. Sanitary dressing procedures must be 

designed to prevent insanitary conditions and they must prevent the 

contamination of carcasses. 

Sanitary Dressing Procedures are Part of the Food Safety System 

Sanitary dressing procedures lay the foundation for an effective food safety 

system including Critical Control Points (CCPs) designed to prevent, eliminate, or 

reduce hazards to acceptable levels. 

Establishments must operate and be maintained in a manner sufficient to prevent 

the creation of insanitary conditions and to ensure the product is not adulterated, 

as required by 9 CFR 416.1- 416.5. Examples of means to achieve this include: 

 Maintaining adequate separation of carcasses, parts and viscera during 

dressing. 

 Routinely cleaning and sanitizing equipment and hand tools used to 

remove contamination or to make cuts in the carcass. 

 Arranging equipment to prevent the contact of successive carcasses with 

contaminated equipment. 

 Washing hands and aprons frequently. 

 Implementing decontamination and antimicrobial intervention treatment 

such as carcass washes or sprays, to address contamination that could 

not be prevented in the slaughter process. 

The point of sanitary dressing and process control is to prevent the creation of 

insanitary conditions (i.e., contamination) and to ensure that carcasses are as 

clean as possible throughout the entire slaughter operation. The establishment 

should not be waiting until just before the carcasses complete the slaughter 

process to address sanitary dressing. 

Establishments may elect to maintain written sanitary dressing and process 

control procedures as part of their HACCP Plan, Sanitation SOP, Good 

Manufacturing Practices (GMP), or other prerequisite programs. If the sanitary 

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dressing procedures are used to support decisions made in the hazard analysis 

in accordance with 9 CFR 417.5(a) (1), establishments must maintain records 

addressing the sanitary dressing and process control program. The records must 

demonstrate that the program is effective and thus decisions made in the hazard 

analysis can be supported on an on-going basis. 

A food safety system includes all aspects of the operation, from the beginning of 

the product flow, receiving; to the end, shipping. Establishment’s must consider

all potential food safety hazards that may occur. They must consider the animals 

entering the establishment. How clean or muddy are transport trucks? How often 

should the holding pens be washed down? Are animals hauled long distances? 

How many animals can be unloaded before they are subjected to overcrowding? 

How does the condition of the animals effect or overwhelm establishment 

antimicrobial interventions? Consider what will happen to the primals or sub 

primals when they are shipped from the establishment. Consider the testing that 

product intended for grinding will undergo. How can the establishment ensure 

product is safely stored at a proper temperature? These are just a few of 

numerous factors and variables that can impact carcass contamination, 

effectiveness of antimicrobial interventions, and pathogen testing results. 

Systems Approach to FSIS Verification 

The thought process for verifying these procedures is to use a systems based 

approach. Verification activities begin at live receiving and continue through the 

whole process flow through slaughter, fabrication and grinding operations. This 

means that the Agency expectation is not to wait until the final rail to verify 

sanitary dressing and process control procedures. 

Verification of a food safety system requires that inspection program personnel 

(IPP) evaluate production operations by looking at all aspects of those operations 

and assessing the interactions between them. IPP accomplish this through 

observation of the implementation of a variety of plans and procedures (e.g., 

HACCP plan, Sanitation SOP, prerequisite programs, FSIS and establishment 

testing results) and through the review of documents associated with those plans 

and procedures. 

IPP should think beyond the boundaries of the slaughter floor. FSIS verification 

does not end when carcasses leave the slaughter area. Carcasses move on to 

fabrication and become fabricated products like rounds, steaks, trimmings, 

drums, thighs, and ground beef. Any contamination incidents on the slaughter 

floor can impact in the microbial quality of the resulting ground product. 

The systems approach to conducting verification activities also means 

considering what has happened in the past. Look at previous NRs for sanitary 

dressing noncompliance, zero tolerance failures, and evaluate establishment and 

FSIS microbiological test results. Are there seasons or months that typically 

cause spikes in positive results or contamination events? 

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Perform sanitary dressing verification activities in conjunction with ante-mortem 

and post-mortem inspection, verification tasks for controlling fecal material, 

ingesta, and milk in slaughter operations (zero tolerance), sanitation performance 

standards, sanitation SOP, and HACCP verification tasks. You should be familiar 

with these other tasks as they were discussed previously in our training. 

PHIS Sanitary Dressing Task 

IPP that perform off-line slaughter verification duties are to use the PHIS (beef) 

sanitary dressing task to verify compliance with the regulatory requirements. 

Schedule the task at the frequency identified in the task list. The task does not 

have to be completed in one day if more time is needed to gather information 

regarding the sanitary dressing and process control procedures. 

Off-line IPP are to verify the establishment’s sanitary dressing and process 

control procedures. The purpose of the task is to focus on all aspects of their 

dressing procedures in relation to the food safety system and not just one step of 

the process. Since verification involves assessing the whole slaughter system, 

IPP are to evaluate the sanitary dressing and process control procedures as a 

whole. 

Possible Indications of Loss of Control 

The following examples are types of findings that can indicate loss of control: 

 A comparison of results of current and previous IPP reviews indicates 

there has been an increase in contamination. 

 Evidence that contamination events are not being effectively prevented. 

 Input indicating there is an increase in positive pathogen results from 

either FSIS or establishment microbiological testing. 

When the information gathered suggests that the establishment has lost process 

control, IPP are to determine if the establishment has taken measures to restore 

process control. Examples of measures an establishment may take include: 

cleaning of contaminated equipment, removing excessive mud via cattle washes, 

or additional checks to verify process control. IPP may schedule additional 

directed tasks in the PHIS system if they need to verify that the establishment 

has brought the process back under control. Certain events that could indicate 

the need for additional tasks could be: online IPP feedback, muddy conditions on 

trucks, animals, pens, or cages, and increased fecal findings. 

Potential Contamination Points in the Slaughter Process 

FSIS has identified the points in the slaughter process where carcasses are most 

vulnerable to contamination. This was determined through scientific literature 

review as well as best practice guidance created by industry. The steps listed are 

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in sequential order for ease of presentation but are not all inclusive. The points 

listed are most frequently associated with carcass contamination. 

When conducting verification at the vulnerable points in the slaughter process, 

personal safety is paramount. Conduct observations from a safe vantage point, 

especially at the sticking and rodding locations. In addition, FSIS personnel are 

to follow good employee hygiene practices to ensure that verification activities do 

not result in cross contamination. 

Beef Slaughter Process – Potential Contamination Points 

A. Live receiving/holding: When cattle arrive, there is an increased 

potential for contamination with enteric pathogens such as E. coli 

O157:H7 and Salmonella due to their presence on the hide and in feces. 

Transport to the slaughter facility, loading and unloading, and commingling 

with other cattle can cause stress and an increased shedding of 

pathogens. 

B. Sticking: This is the point in the process where the animal is bled. The 

establishment must minimize contamination of the carcass during the cut. 

C. Hide removal (manual and mechanical): This is the step where the hide 

is removed from the animal. Hides are known to be a significant source of 

contamination (e.g., dust, dirt, feces, and mud). It is important to maintain 

sanitary conditions when handling the hide. 

D. Wash cabinets: Can be utilized at point(s) in the slaughter process. 

Measures need to be implemented by establishments to prevent cross 

contamination during use. 

E. Bunging: A cut is made around the rectum to free it from the carcass, and 

then it is tied off to prevent spillage of fecal material. 

F. Brisket opening: This is the point where the brisket is split. 

G. Head removal: It is important to maintain sanitary conditions when 

removing the head because cross contamination can occur if the head 

comes into contact with insanitary heads, equipment and employees. 

H. Rodding the weasand (esophagus): The establishment uses a metal 

rod to free the esophagus from the trachea and surrounding tissues. 

Weasand meat can be salvaged for use in raw ground beef production. 

Typically the weasand is tied off to prevent rumen spillage. 

I. Evisceration: Viscera are removed including edible offal, heart, 

intestines, paunch, liver and spleen. If viscera are not handled properly or 

if employee hygiene is poor, contamination of the carcass and edible offal 

can occur. 

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J. Carcass splitting: This is the point where carcasses are split vertically 

into two halves. 

K. Head and cheek meat processing: Meat is removed from the head and 

cheek. This meat can be used in the production of raw ground beef 

products. 

Gather Information Using Questions 

Off-line IPP are to gather information about process control using questions to 

assist them in determining whether an establishment’s slaughter operation meets 

regulatory requirements and is not creating insanitary conditions resulting in 

adulteration. The questions provided here are not all inclusive and will vary 

depending on the type of slaughter operation being conducted. Refer to FSIS 

PHIS Directive 6410.1 for a complete list of questions. These example questions 

are for reference purposes only. 

From Directive 6410.1 (Cattle) 

 What measures if any, does the establishment take to reduce the 

pathogen loads of in-coming animals? 

 What measures if any, does the establishment take to determine the 

incoming bacterial load on animals? 

 What measures do the establishments use to minimize carcass 

contamination during opening of the hide? 

 What measures are taken to prevent cross contamination during hide 

removal or evisceration? 

 Is adequate distance between carcasses maintained to prevent cross 

contamination? 

 What measures has the establishment implemented to ensure that 

contamination of heads, equipment, and employees does not occur? 

 Do the employees maintain proper hygiene practices to prevent the 

creation of insanitary conditions? 

 Do establishment employees remove visible contamination from the area 

to be cut by trimming or steam vacuuming? 

 Is the establishment sanitizing and cleaning knives and saws between 

each carcass? 

 Does the establishment employ any validated decontamination or 

antimicrobial interventions treatments at these points in the process that 

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are effective in reducing the presence or counts of microbial 

contaminants? 

Establishment Interventions 

An intervention is a process step that has the purpose of eliminating or reducing 

a hazard to an acceptable level. How well the establishment performs its sanitary 

dressing procedures directly impacts whether the decontamination and 

antimicrobial intervention treatments will be effective and accomplish their 

intended results. 

Overwhelming the System 

When incoming contamination overwhelms the intervention treatments, reduction 

of E. coli O157:H7 or other pathogens may no longer meet the standard of 

reduction. So even though the establishment may have validated interventions at 

strategic locations in the slaughter process, it doesn’t afford them any leeway or

allowance for sloppy dressing procedures and employee hygiene such as 

rupturing guts, not cleaning hands, gloves, knives or equipment. The 

interventions will not achieve their intended effect if the incoming bacterial loads 

on the hide or feathers are so great that they overwhelm the antimicrobial 

properties. 

Supporting the Food Safety System 

FSIS will have questions about the establishment’s ability to support that the food

safety system is having the effect that the hazard analysis anticipates, unless the 

establishment has: 

 Documentation that supports that the food safety system at slaughter, 

including sanitary dressing procedures coupled with all intervention 

treatments, is effective under the actual conditions that apply in its 

operation; or, 

 The establishment has reassessed its system in response to new or 

revised procedures or interventions that have been implemented and has 

determined that no changes were needed. 

Validation 

In accordance with the requirements for initial validation in 9 CFR 417.4(a)(1), an 

establishment that has CCPs designed to control contamination during the 

slaughter and dressing operation is to validate the individual CCPs to ensure that 

they are effective in preventing, eliminating, or reducing pathogens to an 

undetectable level under the establishment’s operating conditions. Until

establishments demonstrate that the interventions employed at each CCP will 

achieve the anticipated effect under actual in plant conditions, the effectiveness 

of the CCP is only theoretical. 

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In accordance with the requirements for supporting the hazard analysis in 9 CFR 

417.5(a) (1), the hazard analysis must include all documentation that supports 

the decisions made for the food safety system. If an establishment determines 

that it can prevent contamination during slaughter through its SOP, GMP or other 

prerequisite program, then it needs to include support for that judgment in the 

hazard analysis. Unless the establishment demonstrates that the measures 

implemented through the SOP, GMP or other prerequisite program coupled with 

the decontamination and antimicrobial intervention treatments will achieve the 

anticipated effect under actual in-plant conditions, FSIS will view the 

effectiveness of the food safety system as theoretical. The intervention 

treatments referenced must be able to achieve the anticipated effect under actual 

in-plant conditions to be considered validated. 

Establishments can demonstrate the effectiveness of their individual intervention 

treatments by ensuring that they are being used to control hazards at the CCP in 

a manner consistent with the parameters of any scientific, peer-reviewed, 

published or challenge studies. One mechanism available for establishments to 

demonstrate controls achieving their intended effect is testing a representative 

sample of carcasses for microbial indicators of process control. The testing would 

occur prior to and after the application of controls to show that the anticipated 

reduction has occurred. 

FSIS Verification of Establishment Interventions 

Consider the following questions about establishment interventions: 

 Has the establishment considered the level of contamination that may be 

present on incoming animals? 

 Is the establishment effectively using sanitary dressing procedures to 

minimize contamination to prevent the creation of insanitary conditions? 

 Are establishment’s interventions proven effective under actual in-plant 

conditions? 

 Does the establishment describe how test results will be used to 

investigate and adjust the food safety system to ensure it is adequate to 

control E. coli O157:H7 and other pertinent pathogens? 

If IPP have concerns that the establishment’s interventions do not achieve the 

intended reduction in organisms, they are to contact the District Office and 

request that an EIAO conduct a Food Safety Assessment 

Determining and Documenting Noncompliance 

Compliance determinations will be made using the GAD thought process, gather 

information by asking questions, assess the information, and determine 

compliance. Some of the information you could gather includes: 

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 Conditions observed on trucks, cages and pens during ante-mortem, 

 Observations of sanitary dressing procedures at vulnerable points 

 Feedback from on-line food inspectors, 

 Results from zero tolerance checks, either FSIS or establishment, 

 Sanitation performance standards observations 

 HACCP verification task results 

 Lab sampling results (FSIS or establishment), 

 Review of establishment data, 

 NRs, MOIs, and weekly meeting notes. 

Indications of Potential Noncompliance 

Some observation findings such as those listed below should serve as prompts 

to direct IPP to points in the process where sanitary dressing procedures are not 

being properly implemented. 

 Repeated or ongoing noncompliance related to contamination of 

carcasses with feces, milk or ingesta at the final rail for livestock (zero 

tolerance). 

 Increased contamination of carcasses or parts due to environmental 

conditions, like weather or season or other factors affecting the condition 

of incoming animals that have not been addressed by the establishment. 

 Feedback from IPP indicating an increase in positive pathogen results 

from either FSIS or establishment results. 

 Inappropriate design or use of facilities, equipment, or utensils for the type 

or size of cattle slaughtered. 

 Results of any establishment programs designed to prevent insanitary 

conditions during dressing procedures that may not support decisions 

made in the hazard analysis. 

 Feedback from on-line IPP indicating increased incidents of carcass 

contamination. 

Incidental contamination (e.g., ingesta, feces, UFM, rail dust) does not 

automatically represent an insanitary condition. Even if there are observations of 

contamination on carcasses during the slaughter process, the establishment still 

has the opportunity to implement measures that will address the contamination 

before the carcasses complete the slaughter process. IPP must assess the 

available information and evaluate each occurrence of incidental contamination 

to determine whether the establishment has failed to prevent the creation of 

insanitary slaughter conditions prior to carcasses completing the process. 

When assessing information gathered, one individual finding may not necessarily 

be an indication of regulatory noncompliance or a system failure. For example, 

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isolated occurrences of fecal contamination observed during the verification of 

process control procedures is not automatic evidence that establishment has 

failed to maintain sanitary dressing. When making determinations of regulatory 

compliance and process control, off-line IPP are to consider how all the 

information gathered relates to the food safety system. 

After assessing the information gathered during FSIS verification off-line IPP are 

to determine whether noncompliance exists. 

Document Noncompliance 

When there is evidence that the establishment is not implementing its sanitary 

dressing procedures, or the procedures are ineffective in preventing the creation 

of ongoing insanitary conditions, off-line IPP are to document noncompliance. 

1. For livestock, cite 9 CFR 310.18(a) to address contamination of the 

carcass, and 9 CFR 416.1. In the description of the noncompliance, 

explain the situation(s) which support the determination of noncompliance, 

and include the appropriate SPS regulation to address the insanitary 

condition. For example, include 9 CFR 416.5 if improper employee 

hygiene practices have resulted in contamination of the carcass. 

2. Review the NR file in the USDA office to determine if previous 

noncompliance have been or should be linked to demonstrate a trend of 

noncompliance. Associate them as necessary in accordance with the 

instructions in FSIS Directive 5000.1 to document that a trend of 

noncompliance is occurring. 

Summary 

Sanitary dressing procedures are a key to preventing insanitary conditions, 

particularly at the vulnerable points in the slaughter process. Contamination on 

the carcasses is the result of an insanitary condition caused by ineffective 

sanitary dressing procedures. Reducing E. coli O157:H7, and other pathogens 

such as Salmonella, is a regulatory requirement and ensures food safety. 

Interventions need to be capable of reducing or eliminating a food safety hazard 

and not be overwhelmed by the amount of contamination or number of 

pathogens on the carcass. Noncompliance determinations should be reached 

using the GAD thought process and systems approach. The slaughter process is 

a system, so remember to use a system based approach in evaluating the entire 

slaughter system. Compliance with sanitary dressing and process control 

procedures is determined in relation to the entire food safety system, not just one 

contamination incident. 

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Verifying Sanitary Dressing Workshop 

Scenario: 

Open Beef is a one shift cattle slaughter establishment in Petaluma, CA. The 

establishment slaughters approximately 500 head of cattle per day. It produces 

carcass halves and quarters, primal and sub-primal parts, edible offal, beef 

trimmings, head meat and cheek meat. Open beef applies lactic acid as an 

antimicrobial intervention spray to carcasses at the final wash step. The cheek 

meat, head meat and beef trimmings are intended for use in ground beef 

products. 

After stunning, the carcasses are hoisted on a chain driven rail. The head and 

tongue are removed for head inspection. The viscera are removed onto a moving 

line for viscera inspection. 

Robert Allen is a GS-8 CSI, and has just come back to the office from conducting 

ante-mortem inspection on a truckload of cattle just arriving. It’s been raining for

the last 3 days and he wonders if it will clear up before the weekend 

He has already received some feedback from on-line inspectors regarding 

contamination on heads and carcasses. The establishment has recently 

employed a mud scoring system in response to some zero tolerance failures last 

month. He determines that a directed sanitary dressing procedure is appropriate 

to add to the task calendar based on feedback and observations. 

Answer the following questions using your notes and module content. 

1. What are some FSIS records to review while performing the task? 

2. What are some establishment records to request? 

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3. Define the “systems based approach” for verifying sanitary dressing. Does 

the systems based approach prescribe a time frame for completing the 

task, a sequential order? 

Based on the following information below, please arrive at a compliance 

determination using the systems based approach covered in the module. 

Upon initiation of the beef sanitary dressing task on 2/04/16, CSI Allen reviews 

FSIS records and several establishment documents that address sanitary 

dressing and process control procedures. The following prerequisite programs 

serve as support for decisions made in the hazard analysis. 

 GMP 01 Employee Hygiene Practices 

 Prerequisite program for cabinet hot water reuse 

On 2/04/2016, CSI Allen observed repeated instances within a 5 

minute period, where establishment employee hygiene practices 

associated with the removal of hide from the hind legs were not 

being implemented as written, resulting in carcass contamination. 

The applicable section of the written GMP requires that the 

employee must sanitize the knife each time a cut is made through 

the hide. The employee in question did not sanitize the knife 

between cuts and only occasionally sanitized between carcasses. 

The slaughter foreman was notified of the findings and a Sanitation 

performance Standard (SPS) noncompliance record would be 

documented. 

On 2/05/16, CSI Allen observed an establishment employee 

inspecting the filters of the recirculation tanks for the wash cabinet. 

Employee cleaned the filters but did not flush the cabinet tank as 

described in the establishment prerequisite program. Management 

was notified of their failure to properly implement their prerequisite 

program. 

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On 2/06/2016, CSI Allen observed repeated instances of 

establishment employees not sanitizing knives during removal of 

udders between carcasses resulting in carcass contamination. The 

employee hygiene GMP for knife trimming requires that team 

members sanitize knives during udder removal between each 

carcass. An employee was observed removing udders of three 

carcasses before sanitizing the knife. The slaughter foreman was 

notified and an SPS NR was documented. 

On 2/06/2016, CSI Allen observed the establishment conducting a 

zero tolerance CCP check. The result was a failure at the CCP due 

to fecal contamination on the shank. The establishment immediately 

initiated corrective actions to include trimming and re-inspection of 

affected parts. Establishment determined the cause of the failure 

was an employee who failed to properly clean their apron resulting 

in cross contamination during evisceration. A review of 

establishment records indicated that there were two zero tolerance 

failures during the four previous production shifts for the same 

cause. 

On 2/07/2016, on-line CSI Wilson working on the final rail advised 

me that there had been contamination on the leading foreshanks of 

several carcasses. Each carcass had been railed out for trimming. 

After further investigation, I saw contamination on three of the next 

ten carcasses. I immediately conducted a zero tolerance verification 

check which failed. The slaughter foreman was notified and a zero 

tolerance NR was documented. 

On 2/08/2016, I was advised by CSI Jones, processing inspector in 

the Fabrication department at Open Beef, that FSIS results for trim 

produced on 2/04/16 had tested positive for E. coli O157:H7, and 

was currently retained pending the implementation of corrective 

actions in accordance with 9 CFR 417.3. 

On 2/08/2016, I reviewed FSIS noncompliance records for the last 

two weeks, 1/24/15 through 2/06/16 since the last sanitary dressing 

task had been performed. I observed 4 SPS noncompliances were 

documented and associated citing the establishment’s inability to

implement company GMPs as written resulting in carcass 

contamination. Additionally two zero tolerance NRs had been 

documented by FSIS. 

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4. What are your conclusions regarding compliance? Is there regulatory 

noncompliance with the sanitary dressing task? Why or why not? If so, 

what are the relevant regulations verified and cited? 

5. What additional actions would you take? 

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