Agricultural Quality Assessment Division QAD 538 Procedure 

Marketing 1400 Independence Avenue SW, Stop 0258 August 31, 2018

Service Washington, DC 20250 Page 1 of 4

RETAINED POULTRY PRODUCTS

Purpose

This instruction defines procedures for retaining poultry products.

Procedures

I. General

Retained/Detained: Non-conforming product that may be re worked to be brought into 

compliance and reoffered.

Rejected/Rejected for Use: Non-conforming product that is not eligible to be re worked and 

reoffered.

Product failing to meet official grade requirements shall be placed under retention until the 

product is brought into compliance with grade requirements or until applicable USDA markings 

and official grade identification have been removed or obliterated. Product produced for 

approved specifications or USDA commodity purchases, but failing to meet nongraded 

specification requirements shall be placed under retention until it is either brought into 

compliance, official markings are removed or obliterated, or other acceptable disposition is 

accomplished. For USDA commodity product with USDA labeling, all official markings 

required under the contract shall be removed or obliterated including, but not limited to the 

USDA symbol, legend, and UPC symbol and code. After these markings have been removed or 

obliterated and retained tags removed, graders are no longer responsible for the movement or 

disposition of the product.

Product retained during online examinations may be eligible for stationary lot regrading if the 

requirements outlined in Section II of this document are met and the product is re-examined in 

the same form it was originally examined in. Additional examinations and checks to monitor the 

processing operation may be necessary as determined by the supervisor. Regarding defects, the 

terms “free from” or “free of” used in a specification will not be defined as a zero tolerance 

requiring a rejection when a single defect is detected. Instead, the term will indicate that the 

applicable Sample Plan tolerance will determine lot acceptability. Otherwise, the specification 

will state the action required when a defect is found.

II. Handling Retained Product
Agricultural Quality Assessment Division QAD 538 Procedure 

Marketing 1400 Independence Avenue SW, Stop 0258 August 31, 2018

Service Washington, DC 20250 Page 2 of 4

A. Stationary Lot Re-Examination

When a retention caused by individual sample defects exceeding the maximum tolerance 

level occurs, management may request that the retained product be resampled as a stationary 

lot without reworking. The final accept/retain decision will be determined by this 

resampling. Product retentions resulting from a combination of carryover and individual 

sample defects may not be resampled on a stationary lot basis prior to reworking. The initial 

sample will be considered as failing for individual criteria and, therefore, is eligible for 

stationary lot regrading. The startup tolerance will apply until an acceptable sample is 

graded. For Sample Plan Level 2 only, a stationary lot regrading is allowed on sample 2 

when there is a carryover provided such carryover is a result of the start-up tolerance from 

sample 1 only. If the carryover results from the start-up tolerance and a defect in the first 

sample, lot regrading prior to reworking is not permitted.

Graders may only perform resampling when sufficient time is available and may not 

supersede other grading duties. Optionally, such work may be accomplished by requesting 

additional grading personnel, by stopping other grading activities, or after normal grading 

activities have been completed.

When a re-examination is requested on a stationary lot basis, select the sample based on the 

sample sizes listed in 7 CFR Part 70.80 of the poultry grading regulations. Samples shall be 

predetermined as outlined in QAD 615. With the exception of bulk packed product in large 

containers (combo bins, tanks, etc.), the number of units examined from each sample (case, 

rack, etc.) will be the entire contents of the container, or the sample size for the 

corresponding sample plan (30 or 10), whichever is less. For turkey roasts, the sample size 

shall be 1 roast per container. For bulk-pack carcasses and parts weighing less than 6 pounds 

and packed in large bulk containers (combo bins, tanks, etc.), 100 units shall be sampled 

from each representative sample. For bulk-pack carcasses and parts that weigh over 6 

pounds, the sample size shall be 30 units. For size-reduced product look at QAD 537 

(Section IV – Sampling by Weight).

Upon completing the sample grading, the total percentage of defects shall be calculated. For 

products graded using SPL1 and SPL2 acceptance criteria, the total percentage of 

undergrades cannot exceed 10 percent. However, because the turkey roasts have different 

acceptance criteria, the total percentage of defective roasts cannot exceed 17 percent. Do not 

round off when calculating the percentage of undergrades. If the percentage exceeds the 

applicable tolerance, the product must be retained. For example, if the total percentage of 

undergrades equals 10.33 after conducting a stationary lot regrading on whole carcasses, the 

product must be reworked. Each lot of retained product will be examined for and must meet 

the requirements for all grade factors, including the factor for which retained. See QAD 537
Agricultural Quality Assessment Division QAD 538 Procedure 

Marketing 1400 Independence Avenue SW, Stop 0258 August 31, 2018

Service Washington, DC 20250 Page 3 of 4

for online and lot sampling products by weight according to defect categories (i.e., diced 

chicken).

B. Re-Examination After Reworking

Retained product, other than product eligible for stationary lot regrading, must be reworked 

prior to re-examination by a grader. Reworking is defined as the removal of excessive 

defects from a lot or sublot of retained product. Reworking can be accomplished separately 

as a lot or by removing the product from the primary container and blending the product into 

the production line prior to any authorized grading. If retained product is reworked and 

regraded as a separate lot, select the sample based on the sample sizes listed in CFR Part 

70.80 of the poultry grading regulations. The product must comply with the stationary lot 

tolerances for the applicable sample plan as noted above. When product is reworked into 

current production and regraded by authorized personnel, normal online sampling procedures 

shall be used to determine acceptability.

III.Identification and Tracking Retained Product

A. USDA HOLD Tag – Form LP-36

Each grader is required to have a supply of USDA Hold tags. They shall be used only when 

necessary, and never indiscriminately, to resolve small problems within the plant. It is 

mandatory to tag product that does not meet the grade assigned or mislabeled product before 

the grader leaves the plant at the close of his/her shift.

Most poultry plants are large and many operate more than one shift, packing several brands 

and grades of product. It is extremely difficult for management, the shipping foreman, or the 

loading crew to know the location of a retained lot of packaged product without some form 

of identification. Proper use of the USDA HOLD tags will assist and protect plant 

management as well as the grading service. Each grader shall advise the appropriate plant 

management each time these tags are used to prevent any misunderstanding between 

management and grading personnel. As an additional aid in control of retained product, the 

use of "Product Under USDA Hold" tape is encouraged.

When tags are used for retention purposes on product found unacceptable for various 

reasons, such as, not meeting the marked grade or weight, or being incorrectly labeled, the 

date and appropriate remarks such as "hold for regrading" shall be written on the upper and 

lower portions of each tag used. Attach the upper tag portion to the product under retention 

and use the lower tag portion to maintain inventory control until the product is released. 

Keep the tag attached until the product is regraded and released, the official identification is 
Agricultural Quality Assessment Division QAD 538 Procedure 

Marketing 1400 Independence Avenue SW, Stop 0258 August 31, 2018

Service Washington, DC 20250 Page 4 of 4

removed, or other necessary handling is accomplished. Discard both portions of the tag after 

product has been released from retention and make certain that all tags and hold tape are 

removed from the lot.

When tags are used for rejection purposes such as unsanitary equipment or conditions the 

grader shall, whether acting on behalf of FSIS or not, notify the appropriate FSIS personnel 

and their supervisor. If product is rejected then the grader shall tag the product and state it is 

rejected on the tag. State the reason and whom was notified.

B. Retention Log (QAD 538a)

To assure proper control and disposition of retained lots, graders are required to maintain a 

log for all retained product. The log should include tag numbers, date, amount of product 

retained, reason, final product disposition, date and who released the product. Retention logs 

shall be retained in grader's files for one year after the close of the fiscal year in which the 

logs were completed. Tags used to move product under retention between plants shall be 

returned to the grader issuing them after the product has been satisfactorily handled. Report 

any shipment of retained product immediately to the supervisor.

____________________________

Richard H. Lawson, National Poultry Supervisor

Quality Assessment Division

Livestock and Poultry Program

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