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For Business and Industry:
Notice 68-05 Verification Activities at Establishments that Transport
or Receive Cattle Carcasses or Parts with Vertebral Columns that Contain
Specified Risk Materials (SRMs) |
Q. Are there any specific requirements for company seals, as described in FSIS Notice 68-05? For example, can they simply use a padlock to seal the trailer in transport with specified risk materials (SRMs) on board?
A. FSIS Notice 68-05 instructs inspection personnel to verify that an establishment which transports beef containing vertebral column with SRMs "maintains control of the carcasses or parts while they are in transit (e.g., through company seals) or ensures that the carcasses or parts move under FSIS control (e.g., under USDA seal or accompanied by FSIS Form 7350-1)". If under company seal, FSIS verifies that the establishment can demonstrate control of the products until they reach the receiving establishment. Inspection personnel are to ensure that the method of control is equivalent to use of tamper-evident seals and does not allow diversion for other purposes. Any unloading of the controlled products without the knowledge of the establishment, and without providing clear evidence (allowing FSIS verification) that control has been maintained would not be allowed.
The use of a padlock alone does not provide adequate control unless it can be demonstrated that it cannot be opened during transit before reaching the other official establishment.
Q. Is it permissible to break the company seal and off-load other products (other than parts which contain vertebral columns) prior to arriving at the final destination with the parts which contain SRMs?
A. Beef containing vertebral column is adulterated as defined by the Federal Meat Inspection Act due to the presence of specified risk materials (9 CFR 310.22) which prohibits them from entering commerce. However, under appropriate control of either FSIS or the company, FSIS is allowing establishments to move these products to other federally inspected establishments. Breaking of company seals at intermediate destinations would be permissible if the establishment has a method to ensure company (or USDA) control of the products containing SRMs at each intermediate destination. Inspection personnel are to ensure that the method of control is equivalent to use of tamper-evident seals, does not allow diversion for other purposes or unloading of the controlled products without the knowledge of the establishment, and provides clear evidence (allowing FSIS verification) that control has been maintained.
Q. EST A slaughters cattle and provides carcasses containing the vertebral column to EST B, located in the next town. EST B transports the carcasses from EST A to EST B in a transport vehicle owned and controlled by EST B. The carcasses are further processed at EST B. The Public Health Veterinarian is satisfied that both EST A and EST B have documentation to demonstrate that all carcasses leaving EST A arrive at EST B and that EST B removes and disposes of all SRM. Based on this, is the establishment required to use company seals?
A. If the establishment has developed an alternative means to maintain control of the adulterated products, the use of company seals is not specifically required. Inspection personnel are to ensure that the method of control is equivalent to use of tamper-evident seals, does not allow diversion for other purposes or unloading of the controlled products without the knowledge of the establishment, and provides clear evidence (allowing FSIS verification) that control has been maintained.
Q. FSIS permits establishments to transport carcasses that contain vertebral columns from cattle 30 months of age and older, to another official establishment. Can an establishment that is inspected under a participating state meat program be the recipient of such carcasses?
A. No. Products moving from a federal establishment to a state-inspected establishment are moving from an establishment under Federal Inspection to a plant with a different inspection system. Consequently, product is considered to be in commerce. Adulterated products, such as beef products containing specified risk material (e.g. vertebral column) are not permitted to move in commerce.
Q. FSIS Notice 68-05 clarifies that beef carcasses from cattle 30 months of age and older can be shipped with vertebral columns still in. Can these carcasses be shipped with spinal cord still present within the vertebral column? These carcasses are shipped split, but there are often mis-splits where the spinal cord is still present?
A. FSIS Notice 9-04 "Verification Instructions for the Interim Final Rule Regarding Specified Risk Materials (SRMs) in Cattle" states that "The vertebral columns from cattle 30 months of age and older do not have to be removed during the slaughter operation." The vertebral column refers to the vertebrae and intimately associated structures (e.g. dorsal root ganglia), and does not include the spinal cord. It is intended that the slaughter establishment will make every effort to remove the spinal cord during slaughter operations, though small bits of spinal cord may sometimes remain attached to the vertebral column. The establishment should not knowingly leave portions of spinal cord in vertebral column (such as when mis-splits occur), as this may increase the likelihood of cross contamination of meat products with spinal cord material.
Q. Can an establishment collect spinal cord for sale for human consumption from cattle younger than 30 months of age?
A. Spinal cord material from cattle younger than 30 months of age is not a specified risk material as listed in 9 CFR 310.22. There is no regulation that prohibits an establishment from harvesting spinal cord from cattle younger than 30 months of age for human consumption, provided it is wholesome, unadulterated, and properly labeled.
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Last Modified: February 13, 2006 |
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