This Milwaukee meat processor proves HACCP documentation requirements need not deter food safety initiatives.

HACCP is the safety program many food processors love to hate. And with regulators and customers pressuring food companies to develop a HACCP plan, there's plenty of love to go around.

Mandated for meat in 1998 and lambasted as a paper chase by many ever since, HACCP remains clouded by confusion and misperceptions five years after the federal government made Hazard Analysis and Critical Control Points the centerpiece of food safety initiatives. "Three quarters of food companies may say they have a HACCP plan, but they really just have a quality plan," confides one HACCP trainer. He likens HACCP to the food-safety leg of a three-sided quality system. The other two legs are prerequisite programs, including GMPs, standard sanitation operating procedures (SSOPs), pest control, recall procedures and traceability; and quality control, including raw-material specifications, equipment, training and analytical tests.

Wis-Pak Foods, a division of Milwaukee, Wis.-based Emmpak Foods Inc., embraced the principles of Total Quality Control in the mid-1980s, which made the segue to HACCP in the early 1990s a natural progression. "You have to have a good corporate philosophy to make it work," points out Chris Bodendorfer, vice president of quality assurance, and food safety is central at Emmpak. That's not to say HACCP is a painless process: the preventive measures, monitoring requirements, corrective actions, verification procedures and record-keeping requirements can be tedious. And record keeping is especially complicated for a vertically integrated beef processor. But HACCP is the formal blueprint for food safety initiatives at the 112-year-old firm. Food safety is a priority, and HACCP plans document how it is to be accomplished.

Continuous reevaluation

The most virulent pathogens pose a threat at one stage or another in beef processing. Emmpak has to address all of them as product moves from slaughter to boning to raw- or cooked-meat processing. Different HACCP plans are in place for different products and processes, each crafted to target the pathogen that poses the greatest risk.

Emmpak's proactive approach to food safety results in frequent equipment upgrades and new processes, and each one triggers a HACCP reevaluation.

USDA's HACCP mandate for meat processors was still rolling out in 1999 when the Food Safety and Inspection Service, USDA's enforcement arm, recommended that processors reexamine their plans and determine if Listeria monocytogenes contamination was a hazard reasonably likely to occur. FSIS's action came in the wake of the Bil Mar Foods recall of 35 million pounds of hot dogs and other cooked meats linked to 37 Listeriosis cases.

Emmpak managers already were reassessing their processes, exposure levels and validation procedures, so the FSIS mandate wasn't a disruption. "We were out of capacity and wanted to do a better job when we remodeled," recalls Bodendorfer. "We hired independent consultants and told them, 'Go in and give us your honest opinion of our process and where we might be vulnerable.' When FSIS acted, it reinforced our belief we were doing the right thing."

The review culminated in a $6.5 million upgrade at Emmber Foods, the cooked whole muscle and specialty meats division of Emmpak. In FSIS's opinion, fully cooked deli meats, hot dogs, bologna and patties pose the greatest likelihood of microbiological hazards for beef. Five of the seven meat biological hazards identified by the agency -- Salmonella, E. coli 0157, Listeria monocytogenes, Clostridium perfringens and Clostridium botulinum -- are associated with fully cooked beef products.

Emmber's clean room, state of the art in 1994, was completely rebuilt. Five separate clean rooms, three for sliced meats and two for deli face cuts, were created. A one-micron filtration system was installed, and employees undergo a triple-scrub process before entering. Acid-treated floors also were installed.

Environmental hazards are targeted under HACCP, but bacteria aren't the only life form in a plant. The human beings working there also must be considered, and a safety initiative should take them into consideration, points out Tom Rourke, vice president of product research and development. One clean-room air exchange is done every two minutes. Rourke estimates the positive air pressure creates a wind chill of about 30 degrees F in those rooms. Two exchanges would create a 20 degree wind chill, resulting in very uncomfortable working conditions.

Raw and cooked meat areas were completely segregated in the renovation, effectively creating two plants under one roof. Separate employee entrances, lunchrooms and other facilities were built to safeguard against any cross-contamination. Employees and visitors wear color-coded uniforms, with explicit prohibitions against crossing into, for example, the cooked meat area with a raw meat lab coat.

Personnel pass through footbaths at the entrances and foot and hand baths at strategic points within the plant. Stainless steel wall and ceiling panels have been installed throughout.

Drains are breeding grounds for bio-film, and stainless-steel drains and traps were part of the update. Rather than limit the upgrade to the immediate area, stainless-steel piping was extended to a point beyond the walls of the clean rooms, according to Rourke. SSOPs call for regular washing and sanitizing of the traps and piping.

SSOPs are prerequisites to hazard analysis. Quality control also is a separate issue. HACCP falls under the rubric of food safety. "If HACCP is followed, it is your food safety program," insists Jennifer L. Johnson, director of laboratory services and a certified HACCP instructor. Johnson recently was hired to set up and run a new microbial testing lab. The facility, being built in space freed up when Emmpak opened a new 150,000-sq.-ft. distribution center, will speed turnaround time on swab tests and allow the company to test to specific customer requirements.

"In order for something to be of value, I need a fast result," Johnson emphasizes, and that need isn't always filled when suppliers develop new food-safety tools. To illustrate, she says a manufacturer could develop a new and improved sanitizing system, but unless there is a way to quickly measure and monitor it, the technology is useless.

"The food industry is always coming up with new ways to do things," whether it is new equipment, a new process or new packaging material, Johnson adds. She is working with Bodendorfer in reassessing the HACCP plan as new equipment and processes are introduced.

An eye for improvements

Emmpak has experimented with several new technologies for meat, and it continues to investigate leading-edge systems. Emmpak's slaughter operation was the second in the nation to install an automated steam pasteurization system for split carcasses, and the company began studying irradiation six years ago.

Much of that work is under the direction of Rourke. "You certainly don't want to be on the bleeding edge," he remarks, "but, then again, if we can use technology such as high pressure to improve food safety, we're going to take a look at it."

Those evaluations can take years. Rourke's evaluation of irradiation reached the consumer testing phase last year. "I was excited about irradiation a year ago as a treatment for ground-beef patties and ready-to-eat items," he says, but tepid consumer response is a cause for concern.

Ultraviolet light is another safety technology studied at Emmpak, but the 0.5 log reductions the company achieved argue against deployment.

Breathable cryogen, a coolant similar to liquid nitrogen but so benign that humans can breathe it, is more promising. "You get fluctuations in temperatures in chilling equipment," Rourke observes. "Wouldn't it be great to have breathable cryogen lines running through your plant to instantly cool a room?" One possible application: the post-pasteurization chill cabinet, where rapid chilling is considered a critical control point (CCP).

Closer to implementation is high pressure, a nonthermal pasteurization process ready for widespread commercial deployment. The technology isn't appropriate for the hamburger patties manufactured at Wis-Pak -- the patties would resemble meatballs after being subjected to 87,000 psi -- but it would be appropriate for cooked meats. Even with clean room conditions, slicing poses food safety risks.

Three high-pressure units may be installed to work in conjunction with Emmber's clean rooms. The carving operation in the clean rooms currently is not considered a CCP, Johnson says, because there is no way to monitor any potential contamination.

Emmpak is the first beef processor to deploy a system using acidified sodium chlorite for beef trim microbe reduction (see related story). "Once you cut the meat off the bone and start handling it, you know there is the potential for microbes to contaminate the meat," observes Cayce Warf, R&D director at Alcide Corp., the system's developer. "Until this system was developed, there was nothing to treat beef trim, so you couldn't say it was a critical control point." Even with the system, it is the prerogative of each plant's management to determine if that process constitutes a CCP.

Judicious use of CCPs

As a practical matter, regulators and HACCP consultants recommend a conservative approach toward CCP designation. "Flexibility in how to address identified hazards is inherent in HACCP systems," the Food and Drug Administration recently pointed out in its final rule on HACCP for juice processors. "HACCP's flexibility also permits processors to select the appropriate control measures in the context of how the whole system functions, allowing processors to use the most appropriate and economical methods."

In years past, food companies were designating 25 or more critical control points, and that was a mistake. Today, one to five CCPs is deemed appropriate. "If you have more than five, you really haven't effectively focused on what is critical," advises Clifford Pappas, head of quality and HACCP programs at the American Institute of Baking. "You want to minimize the number of critical control points because those become absolutes."

Emmber limits its deli-face process to four CCPs, including cook/chill. Objective, science-based measures of factors associated with pathogen kill rates can be taken at each point, and achieving those objectives has been deemed critical to the process. Under HACCP, it is every manufacturer's prerogative to rank the severity of the physical, chemical and microbial dangers in a process. Only preventive measures that can be monitored and verified can be CCPs.

"Hazard analysis is one of the steps people always want to skip," Johnson warns. "If you're sloppy with this analysis, there's a great likelihood of problems down the line."

Because it is flexible, HACCP can appear arbitrary. Metal detectors are almost always flagged as CCPs in a commercial bakery, for example. Some meat processors include them; others do not. "Whether or not you designate metal detectors depends on how you answer your decision-making tree," Bodendorfer says. Errant buckshot can end up in cattle's flanks, so metal detectors do serve a function. But Emmber's hazard analysis deemed that metal fragments posed a quality problem. Pathogen-control is a greater hazard-prevention priority, and the plant's four CCPs focus on that. A CCP breach could necessitate a shutdown of the system until the source of the problem is identified and corrected.

Probe roasts periodically are run through Emmber's 40,000 lb.-capacity continuous cooker to verify cook temperatures and dwell time. Time and temperature in the chiller also are recorded. The results are run against an American Meat Institute model to confirm microbial kill rates. Probe results are gathered for each rack of meat cooked in the plant's smokehouse.

Roasts that are to be sliced in a clean room pass through an aqua-flow sanitizer, where they are subjected to a chemical rinse. This is done to kill any pathogens on the outside of the package. Chilling the meat to less than 40 degrees by the time it reaches packaging is another critical, measurable process.

Unitherm Food Systems developed the aqua-flow pasteurizer for pasta processing, and two of the half-dozen units in the field are used at Emmpak to sanitize roasts. The sanitizers were validated at an independent lab to achieve a 3 log pathogen reduction, according to Unitherm president David Howard, and the unit automatically shuts down if water temperatures fall below the level needed to achieve a 180-degree surface temperature on the roasts.

"Emmpak deserves a lot of credit for taking the lead in food safety," Howard says. "Capital costs were never an issue with them. The only criteria was that the stated pathogen reductions were accomplished without altering the flavor profile."

Shutting down lines while identifying the source of a CCP breach runs contrary to the production orientation in most plants. Emmpak spends a lot of time educating workers and winning their support for control efforts. "If you draft a HACCP plan and don't get the involvement of sanitation, R&D, maintenance, even the salespeople, you're going to have problems," Bodendorfer says. "You have to educate maintenance people on the basics of microbiology so they understand why they must have separate sets of tools for the raw and cooked meat areas. Everyone has to go through HACCP training and be involved in the decision-making process if the plan is going to work.

"HACCP is a living document that must constantly be reviewed and updated," she concludes. "Is it a lot of paperwork? Yes, indeed. But when it comes to crunch time, you can review the data and determine if a problem exists within your plant."

While HACCP is gradually being mandated throughout the food industry, as a practical matter most companies already face pressure from customers to establish plans. The KISS principle is worth remembering when formulating HACCP, and food processors should note the Emmpak model of plans that advance food safety without unnecessarily hamstringing operations.

Emmpak pioneers sodium chlorite use for beef

Acidified sodium chlorite is being used at 26 chicken processing plants as a pathogen control strategy to treat 4.8 billion pounds of poultry, and Emmpak Foods will become the first beef processor to commercially apply the food-safety technology.

Emmpak is installing a spraying system from Alcide Corp., Redmond, Wash., to treat beef trim with an acidic solution (2.5 to 2.9 pH) of sodium chlorite -- essentially salt and lemon juice -- in concentrations of 500 to 1,200 ppm. A Chicago area processor will apply the technology to beef carcasses sometime this spring.

FDA cleared sodium chlorite for use with red meat in 1999, and in February USDA accepted the results of water solution uptake tests that determined no cellular changes result from treatment, thereby allowing processors to use the antimicrobial without a label declaration.

"This is good news for us and the meat processing industry," says Cayce Warf, Alcide's R&D director, who was involved in 12 weeks of testing at Emmpak's pilot plant. The process results in a 2-log pathogen reduction, supplements existing food-safety systems and operates at modest cost: only 2 to 3 ounces of solution per pound of trim is needed. It is applied in 10 to 15 seconds as product passes through an auger with a spray manifold.