<p> Department of Agriculture, Food and the Marine.</p><p>Trader Notice: MH 44/2014</p><p>To: All Bovine slaughtering plants</p><p>Subject: EXCLUSION OF KIDNEYS FROM BOVINES CLASSIFIED AS COWS (D) AND BULLS (B) FROM THE FOOD CHAIN </p><p>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)</p><p>Canty et al Cd bovine kidney.</p><p>Article 14, (1) of Regulation 178/2002 states: “Food shall not be placed on the market if it is unsafe.</p><p>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.</p><p>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”.</p><p>Role of the Food Business Operator.</p><p>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.</p><p>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.</p><p>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.</p><p>Food business operators are advised that the above procedures are effective from 1st December 2014. These procedures will be subject to review in mid- 2015.</p><p>______John O’Neill Meat Hygiene Division 19th November 2014</p>