FSIS Issues Directive for Inspections for HPP in Meat, Poultry & Egg Products
The Food Safety and Inspection Service issued a directive giving FSIS inspection program personnel (IPP) instructions for verifying an establishment’s intended use of High Pressure Processing (HPP), an antimicrobial treatment for use on meat, poultry and processed egg products without prior-approval from FSIS.
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Uses Include Reducing Listeria, Controlling E. coli
FSIS said anticipated uses of HPP within food safety systems include:
- Reducing Listeria monocytogenes (Lm) post-lethality in post-lethality exposed Ready-to-Eat (RTE) meat and poultry products to qualify for Alternative 1 or Alternative 2, Choice 1 status in accordance with 9 CFR 430.4(b)
- Addressing the control of pathogens in the food safety system, such as E. coli O157.H7 in beef manufacturing trimmings.
If HPP Used, IPP to Perform HACCP Verification
According to the directive, when an official establishment uses HPP as an antimicrobial treatment, IPP are to verify that the hazard analysis supports the use of the HPP treatment in controlling pathogens in the product. IPP are to perform a Hazard Analysis and Critical Control Points (HACCP) Verification task to verify compliance with 9 CFR 417.2(a)(1) and (2). IPP must verify, among other things, if the establishment: (1) includes the HPP process in the flow chart and the intended use; (2) maintains supporting documentation to demonstrate that the HPP process can adequately address the identified hazards; (3) provides scientific supporting documentation to show the log reduction achieved for the specific pathogen identified in the hazard analysis and the critical operational parameters necessary for the process to achieve the stated log reduction; (4) defines a process for every type of food treated; etc.
IPP Must Verify Even if HPP Used for Shelf Life Extension or Tenderization
FSIS said when an official establishment uses HPP to achieve food quality characteristics and does not include HPP in its food safety system (such as HPP for extension of shelf life or tenderization), IPP is to verify that the establishment maintains decision-making documents to support the exclusion of the antimicrobial treatment from its hazard analysis and food safety system.
The directive said if an establishment follows reprocessing criteria, in order to eliminate an adulterant, it is is important that good manufacturing practices are followed to minimize further cross-contamination and additional growth of pathogens. Unless the establishment has date to justify other reductions, the following are minimum expected lethalities:
Reprocessing Lm-adulterated RTE product. An HPP process that achieves a 5-log Lm reduction should be sufficient.
Reprocessing Salmonella-adulterated RTE product. An HPP process that achieves a 5-log Salmonella reduction for meat products and a 7-log reduction in poultry products should be sufficient.
Reprocessing E. coli O157:H7-adulterated raw or RTE product. An HPP process that achieves a 5-log E. coli O157:H7 should be sufficient.
Annual Data Analysis for Potential Trends and Noncompliances
FSIS said on an annual basis, the Data Analysis and Integration Group is to review Public Health Information System (PHIS) data on verification activities for the use of HPP in the hazard analysis for potential trends and noncompliances.