The guideline results from an increase in the number of recalls of meat and poultry products contaminated with foreign materials, the agency says.

“In many cases, the recalling establishments had received multiple customer complaints before these recalls,” the FSIS reports. “While FSIS specifically developed this document to address foreign-material customer complaints, establishments can apply the information to other customer complaints of adulterated or misbranded products in commerce. FSIS encourages establishments that may receive customer complaints for adulterated or misbranded meat and poultry products to follow this guideline.”

The FSIS says that a product containing foreign materials is adulterated even when a physical food safety hazard is not present. The organization recommends that industry participants begin using the guideline and says that it could update the document in response to suggestions. The comment deadline is May 15, 2019. 

Increases in foreign-matter contamination is likely the result of the increasing use of automation and machinery to perform tasks that were once done by hand, says Chris Fuller, owner and operator of Fuller Consulting, a San Diego-based meat processing consulting firm. 

“The amount of time a product is spending in contact with machines leads to a higher likelihood of contamination by those machines,” he says. “Robust preventative maintenance programs and the use of metal detectors are essential to limiting this risk, but are not 100 percent effective.”

Indeed, he says the “biggest issue” is contamination from the metal shavings, shards or pieces coming from such machinery as grinders, mixers, cutters, slicers and dicers. 

A host of prospective hazards

Other potential contaminants include wood, nails and screws from pallets; knife blade pieces; plastics from machine parts, including plungers and guides; and pieces from rubber gloves, pens and markers falling from employee frock pockets, Fuller says.

Metal adulterants often result from machinery vibration, which can cause nuts and bolts to loosen over time, while plastic contaminants frequently develop from wear to conveyor belts and guards, says Betsy Kaesontae, manager of Managed Services North America at NSF International, an Ann Arbor, Mich.-based food safety auditing firm and standards developer.

“If not properly managed, equipment parts can fall in the production line and into the product itself,” she says.

Poultry incidents frequently occur during the slaughter process when rips in workers’ gloves create debris, says Andrew Lorenz, president of We R Food Safety, a Menomonie, Wis.-based food safety-consulting firm.

He says poor machine maintenance is a common trigger for red meat contamination, noting, “modern equipment is complex, resulting in more wear points,” which leads to unsecured machine parts.

Unstable machinery, along with meat and poultry plant layouts that make products more vulnerable to contaminants, are key causes of incidents, says John Butts, adviser to the chief executive officer at Land O’ Frost, a Lansing, Ill.-based lunchmeat supplier, and principal of St. John, Ind.-based consulting firm Food Safety By Design.

“Wear points on machinery that is not perfectly aligned can produce loose metal,” he says, as can the disassembly of complex equipment for cleaning and upgrades.

“As equipment and facilities age, the risk typically increases,” Butts says.

Faster run rates and larger batch sizes of products also can trigger incidents, Fuller says, adding that “as volume increases, the chances of contamination increase intrinsically when scaling any program or operation.” 

Deal with the dearth of workers

Further drivers of foreign-material contamination are a shortage of plant workers, which can lead overworked employees to take shortcuts rather than follow proper operating procedures, along with sub-par employee training, Lorenz says.

“Consumer themselves even can contaminate the proteins during handling or preparation,” Bucknavage says. “It is important to never assume the contamination only comes from the meat product itself.”

Yet, because adulteration often results from small incidents that go unnoticed in plants, it can be difficult to identify potential hazards or isolated incidents, he says.

“Although every ounce of meat shipped should be run through a metal detector, this will not catch plastic or rubber,” Fuller says. “It is management’s and food safety quality assurance personnel’s responsibility to build a robust intervention program to limit the risk of contamination no matter the scale and size of the operation.” 

To best protect meat and poultry from foreign objects, processors should conduct a complete hazard analysis of their operations, “with an eye on where any material can get into the process,” Bucknavage says. “It is important to ensure that procedures are in place to eliminate potential sources of contaminants.”

Appropriate employee training also is key for minimizing events, as it is vital for workers to understand the importance of food safety and the need to actively identify hazards and take corrective action, he says.

Kaesontae adds that operators should train and retrain employees on a regular basis and ensure workers are able to visually identify foreign material in meat and poultry, particularly because metal detectors and other devices that expose adulterants cannot typically pinpoint such elements as plastic and hair.

“After identifying issues, the operator must develop a plan to replace or repair the sources of product contamination,” she says.

Give attention to incident prevention

Quality assurance personnel who primarily collect data also should undergo the necessary food safety training so they too can spot and move to eliminate possible sources of contamination, Kaesontae says. 

“Using both in-person oversight through internal audits and inspections, as well as implementing proper technology, can help catch an issue once it’s already arisen and before the product ships,” Fuller says. “But the best way to limit contamination is through proper and robust preventative maintenance of all equipment to ensure that all parts are properly aligned, lubricated and have smooth surfaces to avoid shavings or shards from flaking off machines and going into products.”

Processors also need to properly align devices with plastics and other softer materials or the elements will wear down and flake into products, he says, while it also is important to remove “brittle” plastics from operations to prevent plastic shattering because of impact or exposure to heat or cold.

“Brittle plastics are dangerous and easily breakable during processing and difficult to clean up once broken,” Fuller says. “Soft, pliable plastics are key to improving the chances of eliminating foreign material contamination of plastic.”

Keep tabs on the appropriate technology

Along with metal detectors, major tools for locating adulterants include X-ray devices, inline screens, sieves and magnets, Bucknavage says.

Because foreign objects often become smaller during processing, it is challenging to pinpoint all articles, Butts says.

“Every step in the production process possesses some level of risk, he says. “Foreign materials are difficult to impossible to inspect completely out of a product.”

Many processors, meanwhile, lack the manpower to visually inspect every item, Lorenz says, adding “there is a balance between keeping costs down, providing affordable products and dealing with the risks of a contamination event.”

Because animal inherent materials, such as bone or cartilage, can be especially difficult to spot, it is important for processors to keep a strong focus on their preventive programs and enhance their equipment and food safety processes as necessary, says Jorge Correa, vice president, market access and technical affairs, for the Ottawa-based Canadian Meat Council.

Nevertheless, he says, “Technology is becoming more sophisticated and able to detect extraneous materials more efficiently. Meat companies keep improving their food safety systems with technology advances and adding X-ray systems to go with the metal detectors that are already in place.”

Incorporating such equipment in processing plants, however, can be cumbersome.

Kaesontae says operators must be willing to devote the necessary time and earmark the appropriate finances to purchase and support machinery, such as ensuring device calibration is always correct.

Pre-operational technology inspections to identify such threats as loose screws and pieces of plastic and metal also are essential, she says.

Recognizing the threat of adulteration is the first step, and the key factor, in protecting meat and poultry, Butts says.

“Locating the potential risks, followed by the development of preventive practices, is critical,” he says, adding that processors also can reduce incidents by measuring and validating the effectiveness of their food safety protocols.

Lorenz says it is important for operators to monitor their acceptance quality limit (AQL), an inspection standard that pinpoints the worst tolerable quality level.

In addition, plants need to confirm their Sanitation Standard Operating Procedures (SSOPs) are working effectively, he says. The FSIS requires processors to have SSOPs, which are specific, written procedures for cleaning and sanitizing production facilities to prevent product adulteration. 

Allied in safety

Even with strong preventative measures in place, consumer complaints about foreign objects in their meat or poultry still are likely to occur, analysts note, and it is crucial that operators thoroughly investigate incidents and determine the validity while keeping shoppers in the loop.

“The vast majority of consumers who discover an issue want to help resolve the situation,” Lorenz says. “But there is a fine line in how much information companies should share. Too much and you may open yourself to a lawsuit; not enough and you may cause one.”

Operators should report back to consumers following an investigation, Lorenz adds, which includes thanking them for their assistance and stating there is confidence the issue was resolved.

“The consumer is the reason why your company is in existence,” he says. “Make them part of the team and the process when possible. Demonstrating that you truly value your customers, and that you are dedicated to providing them with the best product possible, is the true key to successfully navigating the consumer complaint.”

Bucknavage says processors need to take every charge seriously and probe each incident. Data collection should include obtaining pictures of the objects found in the meat or poultry, he says.

In addition, processors should respond to all consumer accusations within 24 hours, and to conduct rigorous scrutiny using Corrective Actions-Preventive Actions (CAPA) procedures that are intended to eliminate undesirable and recurring situations, Kaesontae says. 

“Operators have to keep in mind that the complaint is a reflection of the entire operation and shouldn’t be the sole responsibility of the quality assurance staffers,” she says.

Following incidents, processors can slowly win back customer trust by owning up to the problem and showing how the situation will be corrected and not allowed to happen again, Fuller says.

“Admitting responsibility and making it right with your loyal customers can actually improve brand loyalty so long as it’s not a recurring problem,” he says. “Make sure the issue is addressed and cannot happen again by performing a root cause analysis and applying corrective actions to remove the risk from your process.” NP