October 11, 2005
Volume 1 Issue 31

Pulling the spaghetti apart.

My Editorial staff has been spending many hours trying to get the “fuzzy” out of the blur between these two Organizations.  The FDA is a separate group from USDA; however, their jurisdictions sometimes cross.  When they cross it creates confusion.  I know we at CC4F News get confused.  I believe our friends at NAMP who are helping us through this process have said it best.  This quote comes from Ann Rasor, Director of Scientific and Regulatory Affairs for NAMP. 

"Meat, poultry and egg processing establishments that are under exclusive jurisdiction of FSIS/USDA are exempt from the provisions under Title III (Safety of Food and Drug Supply) of the Bioterrorism Act.  If other Titles of the act affect them or their establishments, they must follow the provisions.  Overall, the act encompasses food, drug, drinking water, biological agents and toxins, and national preparedness and public health emergencies, so there are entities that are regulated by USDA that may still have provisions that can affect them."

In talking to a large Provision's manufacturer, we learned that the meat part of their business will be governed by the USDA as it is now, per Ann’s quote, but since they also provide condiments and sauces to their market these will be covered under FDA and will be tracked accordingly.  (Again this is consistent to what we have learned.)  So to all my associates who are hybrids, this is not good news for the required record keeping.  What I mean by hybrids is that they not only are USDA inspected processors, but they also distribute food products clearly under the FDA Bio Act; qualifying your company for dual jurisdiction.  Please refer back to issue 30 for those record keeping requirements.

Lastly, to all you folks that break cases, i.e. each’s, we cannot get a firm grip on how these products will be handled from a record keeping standpoint.  As soon as the case is broken, they lose their USDA traceability.  We will keep you informed on this issue as soon as we get clarification on our research.  

Feedback from our readers informs us to keep identifying these issues for them.  Keep your comments coming. 

These issues could have a profound effect on your costs.  So lets look at USDA/FSIS.

USDA

WHO: 

The processors who qualify and must comply with the regulations set by the USDA are Meat, Poultry, and Egg Processors. 

There are two exemptions:

1. Custom Exemption
   • Example:  The farmer raised or bought cattle and slaughtered it, and then prepares it for his/her family.
2. Retail Exemption
   • Example: Meat/Poultry that is processed from a single location and displayed in the store at the site the meat or poultry was slaughtered.  (Butchery)

Provided by expert Dennis E. Burson,

University of Nebraska-Lincoln

Within the USDA is the organization called FSIS, Food Safety and Inspection Service.  FSIS enforces the three acts: Federal Meat Inspection Act, Poultry Products Inspection Act, and the Egg Products Inspection Act.  FSIS enforces a program called HACCP, Hazard Analysis Critical Control Point.  HACCP is a “mandated program of individual responsibility for the grower, handler and processor”.  Basically, “HACCP is a system of quality control management placing responsibility for the result totally in the hands of the manufacturers and handlers of the product”.  To learn more about HACCP, visit http://www.ehcan.com/HACCP.html.    

Also, to view the background of the Inspection System, expert Dennis E. Burson from the University of Nebraska-Lincoln has provided AMI Meats with an “Overview of the U.S. Meat and Poultry Inspection System”. 

WHEN: 

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