Whether or not the August 2013 proposed rule to mandate prominent labeling of raw “mechanically tenderized” beef is implemented by USDA-FSIS, producers of non-intact raw beef products (including ground) need to consider the raw materials used when assessing their food-safety system. This means establishments purchasing raw beef for non-intact use must know what actions the supplier has taken, and, based on that information, consider the potential hazards in their hazard analysis.
Whether the raw beef products have been harvested under a HACCP system with at least one CCP to control shiga toxin-producing E. coli (STEC). This should be available from every slaughter establishment; many of whom provide this information on-line. Indeed, FSIS expects the purchaser should obtain assurances that the supplier has a HACCP plan with a CCP to address STEC.