This document summarizes David Harlan's presentation on Taylor Packing Co.'s comprehensive animal feed safety approach for rendered products. Some key points:
1. Rendering plays a critical role in recycling animal co-products and waste into useful feed and technical ingredients.
2. Taylor has a preventative and proactive philosophy ensuring raw material quality and compliance with HACCP, GMPs, training programs, and third-party audits.
3. Potential hazards are analyzed and critical control points established to control microbiological, chemical and physical risks, such as pasteurization temperature for pathogens.
4. Recordkeeping, testing, and verification ensure the safety system is effective and continuously improved.
Comprehensive Feed Safety Approach for Rendered Products
1. 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
5. Taylor Rendering Process
Dressing Offal
MIX &
GRIND
FILTER
TANK
Liquid
LOADOUT/
BLENDING
C
O
O
K
E
R
BEEF TALLOW
TANKS
CENTRIFUGE
Fab Bone & Fat
STORAGE
SCREEN
GRIND/SCREEN
COOLER
Solid
PRESS (3)
6. 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
7. Philosophy & Commitment
Preventative Mindset
Proactive vs. Reactive
Continuous Improvement
Commitment from Entire Team
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–
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Leadership
Management
Production
8. 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
9. Hazard Analysis and Critical
Control Point (HACCP)
7 Principles
1.
2.
3.
4.
5.
6.
7.
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
10. Potential Hazards
3 Classes
Biological
– Microbiological
– Insect Infestation
– TSE’s
Chemical
– Pesticides & PCB’s
– Lubricants, oils, etc.
Physical
– Metal
– Plastic
11. HACCP Example
Microbiological - Pasteurization
Assess Hazard
1.
•
1.
Raw material contains potential pathogens
Determine Critical Control Points – CCP
a. Cooker discharge temperature - TEMP
b. Raw material grind - GRIND
c. Processing rate - RATE
2.
Establish Critical Limits for CCP’s – CCPCL
a. TEMP - Minimum 270o F based on validation study
b. GRIND - Maximum 30 mm anvil gap on pre-breaker
c. RATE - Maximum 36,000 pounds/hour feed rate
12. HACCP – Microbiological
Continued
4.
Procedures to Monitor CCP’s
a.
TEMP - Continuous monitoring by certified
thermocouple
b. GRIND - Inspection, Weekly measurement of anvil gap
c. RATE - Computer tracking of cooker feed auger
5.
Develop Corrective Action Plans
a. TEMP - Alarm notification, automated discharge shutoff
b. GRIND - Repair, Rebuild when gap reaches 30 mm
c. RATE - Reduce feed rate if over 36,000 pounds/hour
13. HACCP – Microbiological
Continued
Recordkeeping
6.
a. TEMP - Computer tracking of CCP and alarm log
b. GRIND - Operations & maintenance logs
c. RATE - Computer tracking of CCP and alarm log
Verification
6.
•
•
•
Clostridium perfringens testing – indicator organism
15 day intervals
Rotate shift and time within shift
17. 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
18. 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
19. 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
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–
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!!
20. Third Party Audits
21 CFR 589.2000
APPI Certification via Cook & Thurber
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–
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Found high compliance in Rendering Industry
Confirmed by FDA Inspections
Discontinued because of high compliance
Facility Certification Institute - FCI
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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 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.
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.
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.