From bacon to jerky, prosciutto and salami, further processed meat products have a strong following. Consumers like the taste, and farmers, butchers, and restaurants like turning lower end cuts into high value specialty meats.
All of these products come with additional regulations and scrutiny if you wish to make them in your processing plant, butcher shop or restaurant. We'll cover the basic regulations here to help you decide if making further processed products is the right move for you (spoiler alert: for some products, it might not be!).
First, you'll want to figure out whether the products you want to make have a standard of identity and what ingredients you can add. Then, you'll need to determine how you are going to control pathogens and keep your product safe. Lastly, make sure what you want to make can be done safely and legally in your facility.
Regulations related to making and selling further processed products can be confusing, because they depend on your specific situation. Here, we help you navigate the process.
Step 1: What do you want to make?
Step 2: How will you control pathogens?
Step 3: Where are you making it?
What exactly are "further processed products"? USDA's Food Safety and Inspection Service (FSIS) defines “further processing” in 9 CFR 301.2 (CFR = the Code of Federal Regulations) as “smoking, cooking, canning, curing, refining, or rendering in an official establishment of product previously prepared in official establishments.” Want to sell salami or bacon to a wholesale client? Thinking of adding deli meats to your retail case? These are all further processed products.
For a lot of these further processed products, FSIS also has a "standard of identity" listed in 9 CFR 319. Be sure to look at the standard of identity for the product you want to make, if one is available. For example, if you are going to make corned beef and call it corned beef, the product needs to meet the corned beef standard of identity. FSIS does not yet have a standard of identity for dry fermented sausages and semi-dry fermented sausages.
FSIS maintains a list of ingredients that may be used in the production of meat and poultry products. Check your recipes against this list to make sure you are using approved ingredients: Safe and Suitable Ingredient Directive.
Food safety is of critical importance throughout the meat processing supply chain. But when it comes to further processed products, particularly dried, cured or fermented products like salumi and coppa, one must be extra careful about controlling pathogens. Eli Cairo owner and operator of Olympic Provisions, a USDA-inspected salumeria in Portland, OR, has a healthy respect for the further processed products “…..for curing, fermenting, and smoking meats… unless you have really good control and knowledge, you should steer clear. It’s a lot of science, a lot of sanitation, and it’s really easy to make people sick.”
Depending on which types of products you are making, there are a variety of steps for controlling pathogens. USDA inspected plants will require a HACCP plan for each product they make to document their pathogen control procedures. State-inspected, custom-exempt, retail-exempt facilities and restaurants may require a similar document or plan for pathogen control. Contact your state department of agriculture, as well as your local health departments or authorities for more information on what is required in your area.
For specific items (such as cooked, ready-to-eat roast beef), FSIS has additional regulations to ensure that products are cooked long enough and at a hot enough temperature and then cooled properly to control Salmonella and other bacteria. Be sure to read the Appendix A and Appendix B compliance guidelines to ensure that your production practices meet the lethality performance standards outlined by FSIS. Sample HACCP plans for cooked, ready-to-eat products can be found here.
By now you know what you want to make, if it meets the standard of identity and what ingredients you can add. Next, you'll need to determine what you can do in your facility. Your ability to sell further processed products is limited by inspection type. Unfamiliar with the types of inspection? Click here to learn more.
A plant operating under USDA inspection has maximum flexibility when it comes to cooked, smoked, dried, cured, rendered or refined products. USDA inspected carcasses may be be further processed for sale on a wholesale basis to hotel, restaurant, retail, or institutional customers as well as direct-to-customer sales. That means a USDA inspected processing facility can make bacon, salami, deli meats, etc. as part of a “fee-for-service” arrangement (i.e., in addition to cut & wrap services, they can offer further processing services) for customers who are turning around and selling those products direct or wholesale. A USDA inspected processing facility can also make further processed products for sale to their own wholesale customers, or at their own retail counter.
In a USDA inspected facility, your inspector will likely be using the Processing Inspectors' Calculations Handbook to determine if your products are in compliance. Reviewing this handbook will help you understand what your inspector is looking for and why.
27 states have state meat inspection programs (check here to see if your state is one of them). The type of processing you can do, and where you can sell the product (wholesale or retail) under state inspection varies from state to state. Check with your state and local authorities to learn more about the regulations in your area.
A custom-exempt plant can only further process meat products for the exclusive use of the owner(s). A custom-exempt plant can make jerky or salami for the owner of the steer or hog, for example, but that product cannot be re-sold and will be stamped “not for sale”. Like a retail exempt plant, the facilities will still be subject to periodic, risk-based inspection by USDA FSIS and/or state authorities.
Retail exemption allows a meat processor to sell meat at its own retail storefront without developing a HACCP plan, and this exemption includes further processed products. The processor is still subject to periodic, risk-based inspection by USDA and/or state authorities, and the meat used to produce retail products must come from carcasses inspected USDA or the state inspection agency in the processor's own state. A retail-exempt processor cannot sell further processed products on a wholesale basis.
Restaurants are regulated by their local environmental health, county health departments or authorities, not USDA. Much like the retail-exempt facilities above, restaurants engaged in direct retail production and sales of meat products do not require USDA-inspection. The regulations that apply to restaurants making further processed products vary from state to state. You’ll need to check with your local authorities and consult your state’s Food Code. In most states, if you plan on making further processed products in a restaurant, you’ll need a variance. A variance is written document that authorizes a modification or a waiver of one or more requirements of the Food Code.
If you make a meat product (for sale) that doesn’t follow Food Code rules, especially temperature, you must apply to county health for a variance. For example, if you’re making dry cured salami, and you dry hang it under refrigeration, you don’t need a variance. But if you dry cure at a temperature higher than 41F, you need a variance. To be granted a variance, you have to have a valid HACCP (Hazard Analysis Critical Control Point) plan that clearly explains your production process, identifies potential hazards, and explains how you will prevent those hazards from occurring.
-Farmers, Chefs and Local Charcuterie, OSU Small Farms Program 2012
As interest rises in cured meats made without synthetic nitrates/nitrites, processors are seeking information on safe and effective methods. On this webinar, meat scientists, a processor, and an organic meats marketer explain ingredients, processes, and challenges to natural curing, as well as product labeling issues. (1 hour long; recorded March 2010.)
There has been significant consumer interest in dry cured charcuterie products, like salumi, in recent years. Consumers love it, chefs want it and it is a good way for producers and processors to get more value out of a carcass and/or really set their brand apart. Yet making dry cured products can be challenging and not always cost effective. On this webinar we'll cover the Business of Dry Curing: we'll hear about the growth of artisan cured meats, the basics of the business and talk to two charcuterie processors about how they got started, their day to day operations and the costs and revenue for dry curing. (1 hour long; recorded June 2014.)
note: This webinar archive includes a spreadsheet developed by Pete Colman at Vermont Salumi to help you determine you product cost on salumi recipes. You can download the spreadsheet here.
Meatingplace.com (free, but a subscription is required) published a short overview of "Equipment factors to consider when making artisan sausages" (7/15/13)
Farmers, Chefs and Local Charcuterie: NMPAN Director Lauren Gwin talks about a workshop in Oregon in 2011 to help farmers sort out some of the regulations around charcuterie products. The workshop slides can be found here: Charcuterie and Food Safety, by Dr.Karen Killinger (WSU).
Thank you to Dr. Karen Killinger at Washington State University for compiling this list!
University of Wisconsin Meat HACCP Website
Validation – Fermentation and Drying, Heat Treatment and Cooking Shelf Stability Predictor using product pH and water activity. Several publications on pathogen survival on processed meats.
USDA website for ham food safety
National Center for Home Food Preservation
Curing and Smoking