To: NMA General Members

Fr: Rosemary Mucklow, NMA Executive Director

Re: Incoming Raw Materials for Grinding August 26, 1997


One of NMA’s members asked today how to break the linkage when one in-coming shipment of raw materials is used over several days in ground beef products. The classic question is a lot of meat in the range of 10,000 to 20,000 (or more) which may be added to production at the rate of 2,000# a day over a 5 to 10 (or more) days’ production.

The classic answer is that whether the raw materials arrive in 60# boxes or 2,000# combos, E.coli 0157:H7 is recognized to occur at a point source location on one piece of meat/fat in the total quantity and is not uniformly distributed throughout all the boxes or the combo bins from the supplier plant. (Remember, if present it will have come from a point source location on one carcass, not uniformly from the entire carcass surface or the carcass that preceded or followed it on the line.)

The past and current interpretation at FSIS is that if a container (combo or box) of meat is split, with half used today and the other half used tomorrow, then the production of the two days is linked and would be so linked in a recall situation. Careful record-keeping by the processor is essential to ensure that partial containers are not held over from one day to the next and do not link lots separated by clean-up. Further processors should maintain vendor source records for each component of the day’s production and customer destination by production date for tracking purposes. See FAX Alert of August 25 for discussion about handling rework which is equally important.

One of our consultants suggests that the processor develop data with random tests for E.coli 0157:H7, Total Plate Count and Generic E.coli on in-coming shipments. He suggests two random sampling points per quantity received. Further, the processor must have demonstrated handling procedures to be able to assure that recontamination does not occur.

A processor may do this type sampling, or may request such sampling of the supplier with appropriate vendor certification. While it is clear that such sampling in no way guarantees that the entire lot does not contain E.coli 0157:H7, such testing or vendor certification is the first critical control point in the receiving firm’s HACCP.

Again, there is no substitute for maintaining good records. Microbiological profiling of incoming raw materials, by vendor, is just good operating practice and may be helpful if later questions arise.