From: Food Quality & Safety magazine, August/September 2014

Foreign Material Controls in the Red Meat Industry

by Steve Sayer

The USDA Food Safety and Inspection Service (FSIS) is responsible for ensuring that U.S. meat and poultry products offered to consumers are safe, wholesome, unadulterated, and properly labeled. In fulfilling these responsibilities, the agency’s laboratories perform microbiological analysis of meat products, including investigations for foreign materials in the likes of metals, wood, and glass.

Prevention of this type of contamination begins on the farm or ranch where the livestock are raised. Producers of livestock have implemented their own safeguards to assure foreign materials do not enter the meat supply.

For beef, both national (USDA) and state regulatory programs work diligently to ensure domestic and imported beef, and beef by-product is the safest and highest quality beef possible.

Only wholesome, unadulterated products are eligible to bear the mark of USDA when they enter into the general commerce. In the case of foreign material contamination, the latest statistics evinces that the incidence in USDA-inspected establishments remains small: less than four hundredths of 1 percent.

If USDA inspectors find products containing foreign materials because the establishment did not properly segregate and dispose of contaminated product, inspectors have the power to take regulatory control actions by issuing non-compliance records that require the establishment to develop a written corrective action and preventive measure(s), while contemporaneously ensuring no harmful product has entered into the general commerce. In the event contaminated product does enter into commerce, establishments are advised to initiate a recall that would be announced by the USDA through the media and its website.

FSIS encourages, but does not require, meat processing establishments have detection technology available in the likes of metal detectors (ferrous, non-ferrous, and stainless steel) and/or X-ray machines (metals, glass, wood, plastics, etc.) in order to eschew physical contamination.

USDA-inspected establishments must have supportable justification from academia studies and/or in-house validation studies regarding how the procedures they employ will detect any possible foreign materials present. If foreign material contamination occurs, inspection program personnel must verify that an establishment follows their detection, segregation, and final product disposition procedures to ensure the contamination is removed.

This is all accomplished by having mandatory Hazard Analysis and Critical Control Points (HACCP) designed to preclude any chemical, physical, or biological hazard(s) from cross contaminating the otherwise wholesome meats.

Criteria for Objectionable Materials

4 defects > 0.5 inch in its greatest ­dimension = re-work the entire bin

(the definition of 0.5 inch in its greatest dimension is 0.5 inches in length, width, and/or diameter)

HACCP and Prerequisite Programs

USDA inspectors verify that the HACCP requirements associated with a Prerequisite Program for foreign material are met on a continuing basis. For example, inspectors verify the requirements associated with a Prerequisite Program for foreign material in a raw ground beef process by performing verification procedures on the detection devices themselves and by reviewing the establishment’s applicable HACCP recordkeeping.

A USDA-regulated HACCP system requires that an establishment must conduct a hazard analysis to determine the food safety hazards reasonably likely to occur in the production process and identify the preventive measures that the establishment can apply to control those hazards. Historical data and customer complaints are also considered when creating a hazard analysis.

If the establishment’s detection equipment is calibrated and finds product with foreign material contamination within the levels of detection, the Prerequisite Program would be considered as operating as designed, and detection is successful (e.g., a metal detector rejects boneless beef). The establishment should evaluate the rejected product and, based on the findings of the product evaluation, determine the root cause of the contamination. Then the establishment should evaluate the incident to determine whether additional controls are needed to preclude the presence of foreign material in the future.

The study of foreign materials found in food is called Microanalytical Entomology. The U.S. FDA and the Association of Official Analytical Chemists (AOAC) have published reference articles, books, and methods on this subject that discuss methods of analyses, contaminant identification, and contaminant significance.


In addition to the large dollar amounts that processors and manufacturers spend annually to ensure foreign objects are detected and removed from domestic meat products, livestock producers are also implementing their own safeguards to keep foreign objects, like buckshot, from entering the food supply. Livestock producers are educating their employees and neighbors not to fire shotguns for herd control, and not to allow hunting of other wildlife in the vicinity of cattle herds.

Buckshot can inadvertently hit cattle from such practices, and the financial losses are magnified when the plant must detect and remove this foreign material later in the manufacturing process. As a result, livestock producers are increasing their efforts to reduce this potential source of contamination.

Voluntary Safeguards

There presently exists a voluntary governmental program for beef establishments that produce fresh boneless beef and frozen ground beef for the nation’s schools and a variety of institutions that requires objectionable materials to be removed. This program is named the National School Lunch Program (NSLP).

The program requires a written technical proposal approved by governmental auditors from the Agricultural Market Service (AMS) that involves written procedures from the transportation of livestock (humane handling of livestock) thru the entire continuum of beef slaughter, fabrication, and ground beef.

The NSLP involves and promotes both food safety (HACCP program and FSIS inspection) and food quality requirements (i.e., fat percentage, net weights, and objectionable materials removal) that must meet AMS set parameters addressed within each USDA establishment’s technical proposal requirements.

The AMS’ technical proposal is based on the ISO 9000 series and requires the plan, do, check, and act format on every process step (from transportation of livestock to final delivery of finished beef products) to generate excellent conditioned boneless beef and frozen ground beef.

One key element of the program is the detection and elimination of objectionable materials (natural tissues of meats) as well as foreign physical materials (metals, plastics, stones, and glass).

A typical description involving objectionable materials in a plan, do, check, and act format of a NSLP technical proposal is partially cited below.

Description of Process—objectionable materials. Major lymph glands (pre-femoral, popliteal, and pre-scapular) thymus gland, and the sciatic nerve (lies medial to the outside round). All bone, cartilage, and the following heavy connective tissues; white fibrous—shoulder tendon, elbow tendon, silver skin (from the outside round), sacrociatic ligament, opaque periosteum, serous membrane (peritoneum), tendinous ends of shanks, gracilis membrane, patelleras ligament (associated with the stifle joint), Achilles tendon, and the yellow elastin, back strap, and abdominal tunic.

Trained quality assurance personnel ensure that the following objectionable materials are removed using a knife: the major lymph glands (pre-femoral, popliteal, and pre-scapular), thymus gland, bone cartilage, sciatic nerve, shoulder tendon, elbow tendon, sacrociatic ligament, opaque periosteum, tendinous ends of the shanks, patellar ligament (stifle joint), and internal fat (kidney, pelvic, and heart fat).

Plan: How will QA meet the production step? All boneless beef products that are intended for the NSLP program shall be subject to visual inspection to ensure that the above objectionable materials are removed and placed into an inedible container. An approximate 30-pound sample shall randomly be taken from a combo bin (containing raw boneless beef) and re-inspected for any objectionable materials; approximately every 30 minutes, plus or minus 15 minutes.

Do: The actual production step. Beef carcasses are de-boned by skilled butchers. Achilles tendons and external fibrous tissues are removed by the butchers prior to de-boning the hind shank. The rump portion of each carcass is opened by knife cuts to separate muscle groups, exposing other tissues, such as silver skin, gracilis membranes, sacrociatic ligaments, popliteal lymph nodes, abdominal tunic, and pre-formal lymph nodes, which shall be removed. Back straps are removed by butterflying open the neck and back portion of the beef chuck, once the bone is removed. The neck portion and the strap are trimmed off.

USDA-inspected establishments must have in place supportable justification from academia studies and/or in-house validation studies regarding how the procedures they employ will detect any possible foreign materials present.

The back portion are pulled out to expose the attaching membrane, which is cut by a knife and cleanly pulled away from the muscle tissue.

Boneless shoulder clods are then turned upside down exposing the interior side of the muscle and the pre-scapular lymph nodes. At the two areas where the shoulder and elbow tendons protrude, the clod is checked on the butt end where the shoulder tendon protrudes approximately 1 to 2 inches, depending on the size of the shoulder clod, and at the point portion where the elbow tendon protrudes is also checked for defects.

Afterwards, the boneless beef travels down a conveyer belt and ends up accumulating directly into a combo bins. At this juncture, personnel visually examine the boneless beef trimmings. The boneless beef that is destined for the NSLP program is placed into cardboard bins lined with a food grade plastic liner, fully and properly labeled at the end of pack-off. At this point of the process, QA personnel perform the on-line inspection for objectionable materials.

Check: How do you verify using quality assurance check? As the combo bins of boneless beef that are destined for the NSLP are in the filling process, an on-line Partial Quality Control program is performed and documented by trained QA personnel. At approximate 30 minute intervals (beginning from the start of each production shift if school lunch product is being processed), plus or minus 15 minutes, an approximate 30-pound grab sample of product is removed from a combo bin and placed inside an edible labeled tote and inspected by a trained QA.

An off-line organoleptic (visual) re-inspection is performed afterwards under enhanced lighting. The boneless beef is then scored using a criterion for on-line inspection for boning defects. If the criterion is exceeded, all product produced from the last acceptable check will be tagged, re-worked, re-inspected, and documented.

In Summary

The NSLP is a demanding and unforgiving program that’s stricter than any other commercial or governmental program today. By reading through the plan, do, check, and act format, it’s imperative that constant employee training is required in order for the program to meet all of the AMS requirements and guidelines. Failure to follow selected AMS guidelines can lead to a disqualification status. Plants can get reinstated by forwarding a cause and effect corrective action that is approved by selected officials at the AMS.

The Global Food Safety Initiative (GFSI) involving Safe Quality Food (SQF), British Retail Consortium (BRC), and the FSSC 22050 does not contain any such detailed requirements. However, if USDA establishments have the ability to adopt both the NSLP and GFSI programs into their operations, such pro-active programs will power their operations several levels higher than that of their competitors.

I’ve always advised qualifying companies who are vertically integrated (slaughter, fabrication, and grinding) that want to have the NSLP and GFSI programs integrated within their company operations to successfully implement and accomplish the myriad standards involving the NSLP first before attempting GFSI certification.

The trails of documentation, management commitment, and employee training that’s required to meet the many standards of the NSLP naturally prepares a company’s operations towards the even more demanding, but rewarding, international standards of GFSI.

Sayer, a 30-year-veteran of the beef industry, is a consultant at S&R Consulting, LLC, in Aliso Viejo, Calif. Reach him at



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