Department of Agriculture, Food and the Marine
Trader Notice MH 10/2015
To: All Food Business Operators at Approved Meat Establishments
Subject: Non-Cominglement of Beef from non-USDA approved plants with that from USDA
approved plants
Scope
Applies only to USDA approved beef slaughter plants, stand alone cutting plants, processing plants and cold stores
which also handle beef originating in non-USDA approved plants.
Background
It is a condition of United States Department of Agriculture (USDA) approval that beef in any form originating at
plants which are not USDA approved cannot comingle with beef originating in USDA approved plants. This noncominglement applies to loading bays, chill corridors, carcase chills, pre-boning chills, boning halls, wrapping and
packaging areas, marshalling areas, box chills, and cold stores.
Standards for Non-cominglement
1. Exposed Beef
Beef carcases, quarters, cuts and trims eligible for export to the US must be clearly marked as such. Beef in
carcase sides, quarters, and unwrapped/unpackaged cuts and trims from non-USDA approved plants cannot be
present in the same room at the same time as carcase sides, quarters, and unwrapped/unpackaged cuts and trims
which originate in USDA approved plants. Such rooms include loading bays, chill corridors, carcase chills, preboning chills, boning halls, wrapping, and packaging areas.
2. Wrapped/packaged Beef
Once beef originating in non-USDA approved plants is wrapped and packaged it must be spatially segregated
during marshalling and storage from beef originating in USDA approved plants. In practice this means that
a. Marshalling areas, box chills and cold stores must have designated, clearly identified areas or
beef originating in USDA approved plants and beef originating in non-USDA
approved plants. There must be clear separation between these designated areas/bays.
bays for
b. Beef originating in USDA plants must be physically separated from beef originating in nonplants during blast freezing and refrigerated transport.
USDA
Note: Cominglement is an American term used to describe contact between or mixing of product from non-USDA
certified establishments with that of USDA certified establishments.
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Role of Food Business Operator (FBO)
The FBO at USDA approved premises must draw up a Standard Operating Procedure (SOP) in consultation with
the Veterinary Inspector which clearly describes how the FBO will guarantee non-cominglement of beef
originating in non-USDA approved plants with beef originating in USDA approved plants. The SOP must describe
at least the following:
1. That exposed beef originating in non-USDA approved plants must not be present in the same rooms at the
same time as beef originating in USDA approved plants. It must describe the handling of each beef type in
each of the following areas:
a. Loading Bay
b. Chill Corridors
c. Carcase Chills
2. Exposed beef originating in non-USDA approved plants must not be present in the pre-boning chills at the
same time as beef originating in USDA approved plants.
3. Exposed beef originating in non-USDA approved plants must not be present in the boning hall or
wrapping/packaging areas at the same time as beef originating in USDA approved plants. Each beef type
must go through the boning hall and wrapping/packaging areas on an “all in-all out” basis. This means that
all meat, including trims, must be cleared out of these areas before beef of the opposite type is permitted to
enter.
4. Boned beef originating in USDA approved plants must have a separate batch code and be clearly
identifiable and distinguishable from boned beef originating in non-USDA approved plants.
5. Wrapped/packaged beef originating in non-USDA approved plants must be segregated from beef
originating in USDA approved plants:
a. It must be physically separated in the marshalling area from beef originating in non-USDA
approved plants.
b. It must be physically separated in blasts freezers.
c. Box chills/cold stores must have designated bays, clearly identified to store beef originating in nonUSDA approved plants separately to beef originating in USDA approved plants
d. USDA eligible beef must be physically separated from non-USDA eligible beef during refrigerated
transport.
6. The non-cominglement of beef must be monitored and verified by appropriate staff at predetermined
intervals, and signed records maintained.
7. Non-compliances (evidence of cominglement) must be documented and reported to the Veterinary Office
8. Corrective actions must be implemented which:
a. Determine the cause of the non-compliance (cominglement)
b. Initiate preventative action that will ensure that recurrence will not occur.
9. Determination of the disposition of any beef involved must be carried out by the Veterinary Inspector (VI).
Any changes in the eligibility for US markets of any formerly eligible beef must be clearly reflected in the
labelling used and the traceability records that are maintained.
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Audrey Lyons
Meat Hygiene Division
8th June 2015
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