Department of Agriculture, Food and the Marine.
Trader Notice: MH 44/2014
To: All Bovine slaughtering plants
Subject: EXCLUSION OF KIDNEYS FROM BOVINES CLASSIFIED AS
COWS (D) AND BULLS (B) FROM THE FOOD CHAIN
Background
Studies carried out in Ireland (Canty, et al, 2014) have shown that an estimated
11.3% of cattle slaughtered in Ireland have kidney cadmium concentrations in
excess of the EU ML of 1 mg/kg. The same study “estimates that the kidneys of
most prime cattle and all cattle under three years of age will conform with EU
requirements.” (See attached paper)
Canty et al Cd
bovine kidney.
Article 14, (1) of Regulation 178/2002 states: “Food shall not be placed on the
market if it is unsafe.
Article 5 of Reg 852/2004 requires FBOs to have a documented HACCP based
Food Safety Management System that addresses hazards that must be
prevented, eliminated or reduced to acceptable levels. Cadmium in bovine
kidneys may be considered to be such a hazard.
Scope
This exclusion of kidneys applies to those harvested from cattle classified as
Cows (D) and Bulls (B). These are also referred to in this Trader Notice as “DB
animals”.
Role of the Food Business Operator.
1. Food Business Operators (FBOs) are required to re-analyse the risks
associated with the harvesting of bovine kidneys for human consumption to
include the presence of cadmium in kidneys of cows and bulls as a chemical
hazard that is reasonably likely to occur.
2. This risk analysis must result in the production of an amended
FSMS/HACCP Plan that addresses the cadmium hazard in kidneys either as
an HPR, CP or CCP, to ensure that the action taken is to remove kidneys of
cattle classified as Cows (D) or Bulls (B) from edible product and place in
Cat 3 containers.
3. The FBO must then draw up a procedure (SOP) to deal specifically with:
a. How carcases from which kidneys must be removed and placed in Cat
3 containers are identified to the operative carrying out this task.
b. The procedure for removal of kidneys from DB animals and
placement in Cat 3 containers.
c. The procedure for removal of these Cat 3 containers from the
slaughter floor to ensure that kidneys from DB animals are not
allowed back into consignments of edible kidneys.
d. The procedure for verification at named intervals by a supervisor or
QA that kidneys of cattle classified as Cows (D) or Bulls (B) are
excluded from the food chain.
e. The corrective action procedure and preventative action to be
deployed if it is found that kidneys from DB animals have not been
removed from the food chain.
Food business operators are advised that the above procedures are effective
from 1st December 2014. These procedures will be subject to review in mid2015.
________________________________
John O’Neill
Meat Hygiene Division
19th November 2014