High Event Period (HEP) Kari Godbey & Chad Martin

Transcription

1 High Event Period (HEP) Kari Godbey & Chad Martin

2 History, Evolution and Truth Sampling and Analysis Platform are part of the integrated Food Safety System. We must listen to the signals that the system provides. There is no magic number, but some really good guidelines. Primals can be affected and must be assessed. Implementation of an EFFECTIVE HEP is critical to protecting public health, customer confidence and company brand.

3 Systemic vs Localized Systemic Implicates all product produced during event. Almost always implicates primal cuts (intact). FSIS Compliance Guideline: Seven or more positive results out of 30 consecutive samples containing same source materials. Localized Implicates specific period of time/specific lots. May or may not implicate primal cuts. FSIS Compliance Guideline: Three or more positive results out of ten consecutive samples from production lots containing same source materials.

4 Factors to Consider Consideration of HEP is not just for slaughter plants. All processors should be aware of the concept of multiple positives and what they mean. Identifying and responding to HEPs minimizes the chance of releasing adulterated product into commerce. Evaluation of multiple positives should consider lean point, common contact surfaces, time, rework, environment, slaughter source, sanitation or any combination of these factors.

5 Consequences of HEP Reflect a loss of confidence in food safety system Negative test results cannot be trusted Lack of appropriate controls will trigger recall

6 Map & Know Your Process

7 HEP Plan Critical to have a written plan. Make sure plan is well-thought out and supportable. FSIS Compliance Guideline for Establishments Sampling Beef Trimmings for Shiga Toxin-Producing Escherichia coli (STEC) Organisms or Virulence Markers. August STEC.pdf?MOD=AJPERES

8 Importance of Conservative Approach React at initial screen POS to hold products. Don t wait until further confirmatory tests are completed. At that point it may be too late Better to retain more and release than retain too little and recall.

9 Some points to consider Know what may be implicated BEFORE sampling. A POS may result in recall of other products at other EST s (including your own). Sampling does not ensure Food Safety. Sampling is verification of your Food Safety System. FSIS does not mandate sampling. Local Inspection cannot dictate raw material samples must be taken. Suppliers conduct rigorous verification sampling that can be used as part of your purchase specifications. Many times these include not only E. coli O157:H7, but also non-o157 STECS. Be familiar with supplier s Food Safety Systems.

10 Small Plants & Further Processors Not uncommon for management to cover numerous roles due to limited resources. Do not delay on developing and implementing HEP action plan. Someone MUST understands: Lotting Process Product Flow HEP Plan

11 Reacting to HEP Divert all known positives to safe end point Rendering Cooker with validated lethality process Maintain control of all implicated negative test lots. Implicated negative test lots: Consider other sampling that has been conducted. Divert to safe endpoint (rendering/cooking) Dealing with subprimals: Cook Only Rendering Antimicrobical Treatment and Testing Verification Lotting and Testing

12 Sampling, Analysis and Verification Rigorous Testing and Analysis Easier to identify potential HEPs Can help minimize implicated window Greater statistical confidence in test results Use process control data and know your baseline Helps identify adverse trends before they escalate to system failures. Creates data-based support for HEP decision making

13 Recordkeeping Keep a written record of decision making related to HEP action plan on file with HACCP records. Have SOP for disposition and tracking of affected lots. Complete corrective actions for HEP.

14 SUMMARY Data driven decision making based on highly sensitive & robust trim sampling methods. Each plant should have a HEP program to accurately assess the results of daily production. All results must be assessed for determination of window or event. Chronological Sequencing of Entire Day Rework / Combo ID Controls Individual Combo Results for pinpointed assessment of activity Traceback to affected lot(s). Multiple POS requires action to be taken on POS and NEG raw material in and around the time of the activity, may reach out to other carcass parts (primals, subprimals). Respond - Take corrective actions on the system to improve performance.