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Oklahoma State University - Robert M. Kerr Food & Agricultural Products Center


FAPC Building

SRM compliance includes record keeping

STILLWATER, Okla. – Threats to the safety of the food supply in recent years have forced government officials to enforce stringent safety measures, as well as record keeping processes to ensure the safety measures are properly followed.

The U. S. Department of Agriculture Food Safety and Inspection Service requires that specific risk materials, or SRMs, not only be removed, segregated and disposed of properly, but also that these procedures be properly documented on a daily basis, said Kyle Flynn, FAPC meat plant manager.

“By now we are all aware of the additional regulations that BSE [Bovine Spongiform Encephalopathy] has caused the FSIS to enforce, such as not utilizing non-ambulatory animals for human consumption,” Flynn said. “I am sure that Oklahoma meat processors are all disposing of the SRMs properly, but where we may fall short is in the record keeping requirement documenting the removal, segregation and disposition of SRMs.”

FSIS regulation 9 CFR §310.22 clearly defines the procedures for proper handling of SRMs and proper documentation.

The regulation states:

(d)(4) Recordkeeping requirements. (i) Establishments that slaughter cattle and establishments that process the carcasses or parts of cattle shall maintain daily records sufficient to document the implementation and monitoring of the procedures for the removal, segregation, and disposition of the materials listed in paragraph (a) of this section and any corrective actions taken.
(d)(4)(ii) Records required by this section may be maintained on computers provided that the establishment implements appropriate controls to ensure the integrity of the electronic data.
(d)(4)(iii) Records required by this section shall be retained for at least one year and shall be accessible to FSIS. All such records shall be maintained at the official establishment 48 hours following completion, after which they may be maintained off-site provided such records can be made available to FSIS within 24 hours of request.

“We need to make sure that we have daily records that thoroughly document proper handling of SRMs in cattle of all ages,” Flynn said. “It is essential that the SRM removal and disposal procedures be addressed in the meat processor’s HACCP [Hazard Analysis and Critical Control Point] plan or SSOP [Sanitation Standard Operating Procedures].”

USDA FSIS clearly and specifically defines and outlines what constitutes a SRM. FSIS regulation 9 CFR 310.22(a) defines SRMs as:

a)(1) The brain, skull, eyes, trigeminal ganglia, spinal cord, vertebral column (excluding the vertebrae of the tail, the transverse processes of the thoracic and lumbar vertebrae, and the wings of the sacrum), and dorsal root ganglia of cattle 30 months of age and older;

(a)(2) The tonsils of all cattle; and

(a)(3) The distal ileum of all cattle. The small intestine may be used for human food if:
(a)(3)(i) It is derived from cattle that were inspected and passed in an official establishment in the United States or in a certified foreign establishment in a country listed in 9 CFR 327.2(b) as eligible to export meat and meat products to the United States and it is otherwise eligible for importation under 9 CFR 327.1(b), and

(a)(3)(ii) The distal ileum is removed by a procedure that removes at least 80 inches of the uncoiled and trimmed small intestine as measured from the ceco-colic junction and progressing proximally towards the jejunum or by a procedure that the establishment demonstrates is effective in ensuring complete removal of the distal ileum.

To fully comply with USDA regulations, meat processors must ensure proper records are kept of all SRM disposal procedures.

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CONTACT:

Kyle Flynn
Meat Plant Manager
Robert M. Kerr Food & Agricultural Products Center
148 FAPC
Stillwater, OK 74078
Phone: 405-744-6071
Fax: 405-744-6313
E-Mail: kyle.flynn@okstate.edu

Oklahoma State University, U.S. Department of Agriculture, State and Local Governments Cooperating. The Oklahoma Cooperative Extension Service offers its programs to all eligible persons regardless of race, color, national origin, religion, sex, age, disability, or status as a veteran, and is an equal opportunity employer.