Issue View | Council III | 2020 Biennial Meeting

This is a brand new Issue.

Committee to Update CFP Guidance on Beef Ground at Retail

This Issue proposes creating a committee to update the "Guidance Document for the Production of Raw Ground Beef at Various Types of Retail Food Establishments."¹ Outbreaks continue to be associated with beef ground at retail that was not intended for grinding (e.g., trim from intact steaks or roasts, and "pull backs"). In addition, FSIS surveillance has shown that 54%² of retailers have no records associated with beef grinding in violation of 9 CFR 320.1(b)(4).³ These records help facilitate traceback in outbreak investigations and may be used to recall potentially injurious products from commerce. CFP's current guidance does not address intended use or the new grinding records requirement. Updating the guidance document would help increase awareness of record-keeping requirements and promote the adoption of safe grinding practices to help prevent illness from raw beef ground at retail food establishments.

Shiga toxin-producing Escherichia coli (STEC) is estimated to cause 265,000 illnesses in the US annually, including 3,600 hospitalizations and 30 deaths.⁴ Outbreaks continue to be associated with beef ground at retail that was not intended for grinding (e.g., trim from intact steaks or roasts, and "pull backs"). In many outbreak investigations, inadequate grinding records and insufficient sanitation between source lots at retail have hindered investigators' ability to determine the ultimate source of the implicated beef.

CFP developed the "Guidance Document for the Production of Raw Ground Beef at Various Types of Retail Food Establishments"¹ (2012 I-014) to share best practices for grinding beef, including a record keeping template. In 2015, FSIS issued the "Records to be Kept by Official Establishments and Retail Stores that Grind Raw Beef Products" rule.⁵ The rule requires grinders to maintain records on supplier names, establishment numbers, lot numbers, and production dates of the raw beef components used to make ground beef products (9 CFR 320.1(b)(4)³). Since CFP published the guidance and FSIS finalized the grinding records requirement, there have been three outbreaks associated with food establishments grinding beef that was not intended for non-intact use.

As presented at the CFP Pre-meeting Workshop in 2018,⁶ federally inspected meat processing plants that produce beef, identify the products' "intended use." Two common intended uses are: "intact" such as steak and roasts, or "non-intact" such as ground or mechanically tenderized beef.^7,8 Intact steaks may be considered a ready-to-eat food by searing without being fully cooked because contamination with pathogenic bacteria would only occur on the surface of the product (Food Code (§3- 401.11(C)(3)).⁹ However, grinding causes STEC to move to the interior of the beef, which may increase risk of foodborne illness if consumed undercooked (e.g., rare or medium rare). For this reason, meat processing plants implement more stringent process controls for beef intended for non-intact use.⁸

Per FSIS routine ground beef sampling¹⁰, 83% (248/298) of retail food establishments reported grinding individually vacuum packaged whole muscle beef (a product intended for intact use). Retail food establishments can reduce risk of STEC when grinding raw beef by: (1) applying antimicrobial intervention to the beef intended for intact use before grinding, or (2) purchasing beef intended for non-intact use.^6,8 However, of the 248 retail food establishments who ground vacuum packaged beef, only 21 (8%) implemented additional food safety steps to eliminate STEC before grinding.¹⁰

The 2014 CFP guidance¹ does not include information on how the beef source material and its intended use affects food safety. Additionally, the CFP guidance document does not mention that retailers are required to keep grinding records since it was developed prior to the issuance of the Grinding Record Keeping Rule.

References (noted above with superscript numerals)

1. Guidance Document for the Production of Raw Ground Beef at Various Types of Retail Food Establishments. URL: http://www.foodprotect.org/media/guide/CFP%20Beef%20Grinding%20Log%20Template%20Guidance%20Document%20-%208-8-2014.pdf
2. USDA-FSIS Enforcement Records: October 1, 2016 - September 30, 2019
3. 9 CFR 320.1(b)(4) - URL: https://gov.ecfr.io/cgi-bin/text-idx?SID=64ec97c3205d4b15340b3577e35c22d5&mc=true&node=se9.2.320_11&rgn=div8
4. Scallan E, Hoekstra RM, Angulo FJ, Tauxe RV, Widdowson MA, Roy SL, et al. Foodborne illness acquired in the United States---major pathogens. Emerg Infect Dis 2011;
5. 80 FR 79231, Records to be Kept by Official Establishments and Retail Stores That Grind Raw Beef Products. URL: https://www.fsis.usda.gov/wps/wcm/connect/6bb824d5-70ce-4c1d-8801-b18346fa595c/2009-0011F.pdf?MOD=AJPERES
6. Sherri (Jenkins) Williams. Intended Use of Non-Intact Products. Pre-Meeting Workshop, Conference for Food Protection (CFP) 2018. Richmond, VA. (slides attached)
7. 2017 Food Code Section 1-201.10(B) Terms Defined "Intact Meat" and "Meat". URL: https://www.fda.gov/media/110822/download.
8. FSIS Compliance Guideline for Minimizing the Risk of Shiga Toxin-Producing Escherichia coli (STEC) in Raw Beef (including Veal) Processing Operations. URL: https://www.fsis.usda.gov/wps/wcm/connect/c1217185-1841-4a29-9e7f-8da6dc26d92c/Compliance-Guideline-STEC-Beef-Processing.pdf?MOD=AJPERES.
9. 2017 Food Code §3- 401.11(C)(3). URL: https://www.fda.gov/media/110822/download
10. FSIS Directive 8010.1 Methodology for Conducting In-Commerce Surveillance Activities. URL: https://www.fsis.usda.gov/wps/wcm/connect/66a3ae47-3a55-426e-8bab-ea7b2175c9be/8010.1.pdf?MOD=AJPERES

The Conference recommends that a Committee be convened of members from all constituencies in the CFP. The Committee will be charged with:

1. Reviewing the available guidance and recommend changes to update and address continuing issues, such as:

1. Low compliance with grinding records requirements,
2. Grinding beef intended for intact use,
3. Lack of sanitation (including records of sanitation) throughout the production day, and
4. What to do if inadequate grinding records are found

2. Determining appropriate mechanisms for sharing the committee's work,

3. Reporting the committee's findings and recommendations to the 2022 Biennial Meeting of the CFP.