Date 2014 Jan. 14 &15 Jan.21 4-Mar Mar. 11 Mar. 18 Mar. 25&26 Apn1&2 Apr. 22&23 7-May 14-May 21-May June 2&3 16-Jun l7-Jun 23-Jun 24-Jun 8-Jul 9-Jul 144u 15-Jul 21-Jul 22-Jul Lot :1 172 177 207 210 212 216 220 232 238 241 243 249 250 254 257 258 257 260 265 265 267 268 270 271 272 Head (4) DOAs 5000 r? 3 00 #0000 Dle U) Condemns 4 7f - United States Department of Agriculture Memorandum of Interview January 4. 2014 Iowa Rabbit Co. l.l.C. 606 Lyon St. Jewellthis time. since it is my first visit and inspection at this facility I will only reference observations and suggestions. I will list them in a bullet form with no particular order or signi?cance attached. Label check; At ?rst Kim was applying label with USDA inspection bug 45099 (Sigourney est. numbers), she to changed to l?25 S-R Employee was dressed for production and picked up foot wash mat and contacted the front of apron-l made her wash off Cooling rack was too close to concrete wall and carcasses protruding from sides of the rack were contacting the concrete wall? made her move it over and rinse the affected carcasses i have concerns about ventilation being adequate enough to prevent condensation dripping on finished product A gray tote was used to hold edible "seconds" product: gray totes are usually only used for inedible product The body cavities. neck area and front of legs are well rinsed at both rinse stations but the backs are sort of hit-and-miss at. times (twice I stopped production at final rinse to show fecal smears on back in tail area) The long red hose in hallway was tangled and as employee pulled it into packaging room the tangle contacted aprons hanging on the wall and actually knocked one to the floor (I told about it) Twice I had final rinse employee. stop and wait fOr the water to get up to 160+ degrees. and then re-rinse the carcasses before placing them in cool water tank Your SOPs state each employee shall dip their hands in sanitizer and knives will be dipped in sanitizer between each production procedure: SPS issues 1. Employee making ?rst skinning cut on the free hind leg would frequently make the cut on 3-5+ animals without dipping the knife and infrequent clipping of foot shears 2. The hide puller pulls the hide off, then pushes the carcass through the window and then dips his hands. contaminating the carcass: it would be better if he dipped before shoving the carcass 3. The first eviscerator removes one to several perineal structures without dipping the left hand covered by cloth cut glove-she docs dip knife between each rabbit: this is a concern because she slides her left thumb down the inside of the hooked back leg to grab the structures. probany contaminating that area 4. Final rinsed carcasses can be too close together and sometimes when the cut to remove carcass from foot in book is made the foot falls out and contacts the next Food Safety and Inspection Service Office of Field Operations Des Memes District Office Neal Smith Federal Budding, 210 Walnut St . Room 985. Des Moines IA 50309-2123 515-727-8960 Fax: 515?727-8991 An Equal Opportunity Prowder and Employer USDA 6. 8. - United States Department of Agriculture carcass which has already received its tinal rinse(especially when the east hanging rabbits are done ?rst) In the stick and pelting room- sometimes with both pclters pulling pelts there would be a pelted carcass hanging between and contacting a non-pelted rabbit- placing more pressure on the carcass rinses preventing cross contamination and further sanitary production. As it gets closer to lunch break the ?short cuts" gets more prevalent. HACCP issues: The last rabbit had a fecal pellet attached to the perineal region and as processing continued the feces became smeared and I checked it before it was placed in the cooling tank. I showed it to and she placed it in the seconds tote. without any further corrective actions. If had been doing a HACCP check that would have been a failure and non-compliance I did not observe anybody performing (B) either day. Positive observations: Pro?Op and facility cleanliness is exceptional Eviscerators ask ifthey have any doubt about any lesions or abnormalities observed All employees are very willing to accept suggestions and or corrections dips his knife in both tanks between rabbits (6) DVM Food Safety and Inspection Sen/ice Of?ce of Field Operations Des Moines District Of?ce Neal Smith Federal Building. 2t0 Walnut St. Room 985. Des Me-ines EA 50309-2123 Voree 515-727-8960 Fax. 515-727-8991 An Equal Opportunity Prowder and Employer QSDA United States Department of Agriculture Memorandum of lV'lemorandum February 25:36. 2014 No concerns or issues observed on Tuesday. February 25. 3014. 'li'wo issues observed on Wednesday. 3326.520] 4. . Employees need to be careful taking wooden pallets into pack off room. Lety carried a pallet into the pack ol?t? room and both door edges contacted the pallet which had been on the ?oor. I instructed her to wash the door edges and had check with her to con?rm she had cleaned the edges. This is important because rabbit carcasses on the cooler racks routinely contact the same edges. Approximater 20 boxes on the bottom of the pallet were labeled incorrectly. The referenced labels did not contain the SDA "bug" with establishment number withion the circle. I informed and he instructed to remove the incorrect labels and replace with the correct labels with the correct net weights. (6) DVM. Food Safety and Inspection Service Office of Field Operations Des Mo-nes District Office Neal Smith Federal Building. 210 Walnut St . Room 985 Des Memes IA 50309-2123 Voice: 515-727?8960 Fax 515727?899l An Equal Opportunity Provider and Employer March 12,2014 Memorandum ofwrong labels: Lot 207, March 4, 2014, whole rabbits, pair legs March 4, 2014, at end of shift: I was aware they were 8x6=48 rabbits short of carton count on pallet and hand written weights document March 11, 2014, at start of shift: I asked to see shipping manifest from March 4, 2014, Lot 207. The manifest showed cartons of whole rabbits and cartons of 40 ct. hind legs shipped with a designating USDA inspected product inquired as to how they shipped cartons of whole rabbits when I had verified by box count and written weight document that they had only produced cartons Kim notified Bob Ollinger, business manager, who in turn notified Steve DeBruin, CEO, of the discrepancy. informed them that I couldn't allow them to label new product until the issue was resolved, so they decided to request voluntary inspection for March 12th and to label and package Tuesday?s slaughter as FDA. March 11th Iowa Rabbit requested voluntary inspection for the 12?" for which I obtained approval and orders from (6) (Iowa Rabbit was hoping the 8 cartons could be identified and shipped back) 0700 March 12, 2014, I informed Iowa Rabbit shipping product without USDA inspection could be Class 1 recall and I would have to speak with (6) or DO before allowing packaging and labeling of any more product. Iowa Rabbit notified the customer and they attempted to get warehouse employees to find the 8 cartons in question and after 4 hours had located only 3 cartons with FDA labels 1300 March 12,2014, Bob and Steve decided instead of trying to identify the 8 cartons and recalling those 8 they w0uld recall the entire shipment to sort out the discrepancy (as the warehouse was charging for services and they needed to produce more USDA product). I contacted Steve Day in D0 to see if they could package March 12, 2014?s slaughtered rabbits and he stated they could since it was a voluntary recall USDA Uniled Slates of Aquculmre Letter of Caution Wurth I. 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[\Aua inl'urmcd 111;"ch Mun: ||n|>hud rm 1er day and lel'r plcmiscs 1 1.21114, I asked 1 1 DA mspecrerl pmducl 1 asked hm yuu rm unly pmduccd earmm rabbilsl under Int number 3'17, latch (m March 6. 21114. 115 bung tight cartons on 4 hur couldn't C\plaln ho" (he) shipped I She insured me the) DID N01 package and label any non-I inspected rabbils to fill the mler hm mud hme ddrlerl ednnm hrs-melee In fiini>h urder. hm rhe packages or canons mum nul commde labels the USDA hug (thus. \Vcrc FDA 1115 euch assured me mm hecurdmh 11>> their numbers dd 1 luhlered hh I '1qucxnuning1lle number 011 rlecirled \nlunlur recall lhl: emirel 5.1110113, l'll me lhi~ 111 inl'm'm yllu lhal product labeled m1 5m inspeclm rmpeemm could Inihalc class 1 recall and [him Letter 0" shnuld hc a \Aamlng. ll yuur 1r>> properly puckagc. label and 5111p produeed under inspection, Thi< 1 ul'Camian uill exvire ml 12.30151 w. Food Sa'ety ah: lnspecllor Sew as one cl Fleld Operahm Des Me he; 0 5"10' 01m Neal 3mm reue 21w. sx Ream 935 Des Me has lA 5030921: We>> 51572 :1 Fax 5'5721399' Alqula 0mm um v" (6) DVM, PHV FSIS USDA March 18, 2014 Bob Olinger Iowa Rabbit LLC 606 Lyons St Jewell, IA 50130 Reference: boxes rabbits shipped on March 7,2014 Dear Bob: Thank you for y0ur letter describing Iowa Rabbi plan of action. The shipment of rabbits arrived during my presence today. Together with the various letters of correspondence, my observation of product and your plans to repackage as FDA rabbits I will consider this incident closed. Sincerely, (6) PHV FSIS USDA - United States Department of Agriculture emorand um l? Interview Date: July 16. 2014 Topic: Carcass spacing lo: Kim Heiderseheitlt Plant Manager Iowa Rabbit LLC. Jewell. Iowa 'l'hese past few days. While short staffed. your crew in the cviseerating room get in a hurry and start to take short cuts and not keep space between the carcasses until the ?nal cold water rinse. They have been instructed numerous times to "space" them. Sanitary dressing and no contact are the only two methods that you have to prevent cross contamination before the ?nal rinse. Wednesday. after the first carcass wash, cvisceration and cold water rinse there was a fecal smear and even a ?pellet? on the belly wall ofa rabbit in a "group of four" shoved down for the. hot water bath. 1 hope to see an improvement. (6) Food Safety and Inspection Service Office of Field Operations Des Moines District Office Neal Smith Federal Building. 210 Walnut St. Roam 985. Des Moines IA 50309-2123 Voice: 515-727?8960 Fax 515-727-8991 An Opportunity Previder and Employer gs DA United States Department of Agriculture January 23. 3014 To: Kim I had a couple ol? issues this week thal _\ou should monitor. 1. [.Jnskinncd rabbits rolled into the fresth skinned rabbits before moving on to eviscerations. I demonstrath to what i intend to see and he responded. for now an way. (6) gives ?nal 180 rinses and then handles skin covered leg. with mesh glove cox-cred hand- and then moves other rabbits forward without sanitizing her mesh glove. 1 demonstrated to her and she also responded. Id (6) DVM, PHV Food Safety and Inspection Semce Office of Field Operations Des Memes District Of?ce Neal Smith Federal Building. 210 Walnut St. Roam 985. Des Molnes IA 50309-2123 Vance. 515-727-8960 Fax 515-727-8991 An Equal Opportunity PrOVlder and Employer 6/2/14 Pre?op 3 dead mosquitoes on packaging table (6) handling "dirty (hang)" needs to be sure and dip hand before grabbing carcass (especially to hold belly wall when torn)- AND - if he uses knife- be sure and dip handle Need to clean grill on exhaust fan Everybody needs to get in habit of dipping knives before sheathing More bruises on hind legs than in past - Using leg hook to catch to load? Food Safety and From: Date: 10/9/2014 Subject: Meeting Date: 10/7/2014 Meeting Time: 2:00 PM Establishment: - Iowa Rabbit, LLC Reason Code: Other Other Reason Other Code: Comments: Inspection Service 1400 Independence Avenue, SW. Washington, DC. 20250 5150A mdeW (6) Sanitation Memorandum of Interview Date: 10/7/14 Topic: Sanitation This MOI is being issued to highlight some less than optimum sanitation practices. In the pelting room, pelted rabbits are allowed to contact non-pelted rabbits which most of the time have grossly contaminated pelts. Several rabbits are shoved together before or after the slices in the left back leg have been made and the exposed leg muscle tissue frequently contacts the dirty fur of an adjacent leg or body. When the employee separates the pelt from the perineal region, especially the males (penile prepuce and scrotum), and some females, they contact the right inside hind leg with the palm side of their right hand. This is a concern because they have grabbed the outside of the pelt with their right hand and then separate the perineal tissue without dipping in sanitizer, thus contaminating the belly wall and right inside hind leg.[416.1] In the eviscerating room after the ?nal rinse the dirty intact foot is occasionally allowed to contact an adjacent carcass as the carcass is removed from the foot in the booknot functioning and use of the 180 nozzle is required the employee frequently sprays the carcasses as they are bunched together, preventing correct contact of the 180 degree with all carcass parts. When an individual moves back and forth between the pelting room and the eviscerating room they should have a pelting apron and an evisceration apron and change when moving. They should also dip scabbards and knives in sanitizer and change gloves. Contamination and cross-contamination are best avoided! Not planned on being removed later in the process! Food Safety and Inspec?on Service 1400 Independence Avenue. SW. Washington, DC. 20250 USDA From: (b Date: 8/28/2014 Subject: new product labels Meeting Date: 8/26/2014 Meeting Time: 2:00 PM Establishment: - Iowa Rabbit, LLC Reason Code: Other Reason Code: Comments: Memorandum of Interview Awareness Meeting Iowa Rabbit LLC. Date: August 26, 2014 Labeling Topic: Awareness Meeting - Personnel attending: Kim Heiderscheidt Plant Manager Bob Ollinger by phone CFO. (6) Ms. Heiderscheidt informed me they were going to ship some 'bone-in Ioins? and I inquired about labels. She stated they had been approved and we went to lobby to look at them. The only labels besides the DeBruin Rabbit and Whole Foods that we were using routinely were various ?box? labels. She said they had not received the individual package labels but understood that they could place generic labels on the packages and then ship them in cartons containing the approved USDA ?box' labels. instructed her and Mr. Ollinger that is only permissible to further processors or food service vendors and not to retail customers. DVM Acting IIC We agreed that they could keep the seven boxes of packaged Ioins identi?ed and separated and next week under my observation, after receiving the bag labels, would attach the labels to the bags and cartons, and then they could ship them as USDA inspected.