Further Processing and 

Labeling 

Inspection Course 

Student Handout 

April 2024 
 

 

 

 

 

 

 

 

TABLE OF CONTENTS 

MODULE 1 INTRODUCTION TO THE COURSE ......................................................... 3 

MODULE 2 LABELING ........................................................................................... 7 

MODULE 3 NET WEIGHTS .................................................................................... 33 

MODULE 3.5 SOLVING FOR X ................................................................................ 47 

MODULE 4 SAUSAGE OPERATIONS ..................................................................... 51 

MODULE 5 CURED MEAT AND POULTRY PRODUCTS OPERATIONS ........................ 95

MODULE 6 MEAT AND POULTRY WITH ADDED SOLUTIONS ................................. 126 

MODULE 7 INSPECTION RESPONSIBILITIES ........................................................ 142 
 

 

 

 

 

 

 

 

 

01 - Introduction to the Further Processing and Labeling Course 

Objectives 

After completion of this module, the student will be able to: 

1. Explain the purpose of the Non-Food Safety Consumer Protection (NFSCP) 

requirements. 

2. Identify the primary statutes, regulations, directives, and tools that relate to NFSCP 

responsibilities. 

3. Distinguish between the meaning of economic adulteration and misbranding. 

4. Explain the meaning of the terms restricted ingredients and standard of identity. 

5. Describe the requirements being verified when performing the five NFSCP tasks. 

6. Describe the circumstance for conducting a directed NFSCP task. 

7. Describe the IPP actions when product is economically adulterated, when product is 

misbranded, and when there is repetitive noncompliance. 

8. Describe the enforcement action to be taken when repetitive noncompliance is found 

involving the same process or product. 

This module provides the big picture of what will be covered in this course. It will provide the 

basis and general overview touching on statutory authority, definitions, regulatory references 

and a discussion of the inspection verification tasks. 

The mission of the Food Safety and Inspection Service (FSIS) is to assure that meat, meat food, 

poultry, poultry food, and egg products distributed in interstate commerce are safe, wholesome, 

not adulterated, and properly marked, labeled, and packaged (not misbranded). FSIS enforces 

the Federal Meat Inspection Act (FMIA), the Poultry Products Inspection Act (PPIA), Egg 

Products Inspection Act (EPIA) and the regulations implementing these laws. FSIS Directives 

and FSIS Notices provide inspection program personnel (IPP) with specific instructions to help 

them enforce the laws and regulations. 

The highest priority in FSIS is protecting public health and food safety. The Agency directs IPP 

to focus on food safety and food security (when specific heightened security threat condition is 

declared). Nevertheless, FSIS must continue to verify that establishments that produce meat, 

poultry and egg products comply with the statutory and regulatory requirements that do not 

address food safety. These statutory and regulatory requirements are referred to as Non-Food 

Safety Consumer Protection (NFSCP) or Other Consumer Protection (OCP) requirements. 

NFSCP regulatory requirements ensure that meat, poultry and egg products distributed to 

consumers are wholesome and not economically adulterated or misbranded. 

Statutory Authority 

Economic Adulteration 

The term “adulterated” is defined in 21 U.S.C. 601(m) of the FMIA. 601(m)(1) – 601(m)(9) 

identifies nine circumstances in which a carcass, carcass part, meat or meat food product is 

adulterated. The same information appears in 21 U.S.C. 453(g) of the PPIA ((g)(1) – (g)(8)) and 

21 U.S.C. 1033(a) of the EPIA ((a)(1) – (a)(8)). 

Misbranded 

Carcasses, carcass parts, meat, and meat food products distributed to consumers must be 

properly marked, labeled and packaged. When a carcass, carcass part, meat, or meat food 

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product is not properly marked, labeled and packaged, it is misbranded. The term “misbranded” 

is defined in 21 U.S.C. 601(n) of the FMIA. 601(n)(1) – 601(n)(12) identifies twelve 

circumstances in which a carcass, carcass part, meat or meat food product is misbranded. The 

same information appears in 21 U.S.C. 453(h) of the PPIA ((h)(1) – (h)(12)) and 21 U.S.C. 

1033(l) of the EPIA. 

Label/Labeling 

The term “label” means a display of written, printed, or graphic matter upon the immediate 

container of any article. The term “labeling” means all labels and other written, printed, or 

graphic matter upon any article or accompanying the article. These terms can be found in 21 

U.S.C. 601(o) and (p). 

Regulations and Policies 

The regulations that provide non-food safety protection to consumers are extensive and 

detailed. However, the same statutory provisions for adulteration and misbranding, as well as 

the definition of a label and labeling can be found in 9 CFR 301.2 and 9 CFR 381.1. 

Regulations and policies also outline the approved ingredients which can be used in or on food 

products. These documents may dictate the amount of ingredients allowed in or on a product, 

and the purpose for which the ingredient can be used. Food and Drug Administration (FDA) 

regulations, 21 CFR Subchapter B, identifies food fit for human consumption. 21 CFR 

Subchapter B Parts 172-184 address direct and indirect food additives, and Parts 73, 74, 81, 82 

address color additives. These regulations are incorporated into FSIS regulations by reference 

in 9 CFR 424.21(b)(2) and FSIS Directive 7120.1. FSIS determines the suitability of ingredients 

to be added to meat and poultry products, specifically, and they are listed in 9 CFR 424.21 and 

updated quarterly in FSIS Directive 7120.1. While FSIS no longer issues official policy through 

Policy Memos, and many have been cancelled or rescinded, there are Policy Memos that 

remain active and relevant. These have been incorporated into the Food Standards and 

Labeling Policy Book. 

Some products have standards of identity. These regulatory standards in 9 CFR 319 and 381 

Subpart P, dictate the ingredients, preparation and/or processing of the product in order for it to 

bear that name on its label. Product standards are also set by the Food Standards and Labeling 

Policy Book. 

In the regulations, 9 CFR 442.1 prescribes the procedures to be followed for determining net 

weight compliance and prescribes the reasonable variations from the declared net weight on the 

labels of immediate containers of products in accordance with 9 CFR 317.2(c)(4), 317.2(h) and 

381.121. FSIS uses the NIST Handbook 44 and the NIST Handbook 133 standards as the 

basis for verifying net weights and these documents have been incorporated into regulation by 

reference. 

Non-Food Safety Consumer Protection Tasks 

When performing the General Labeling Task, IPP are to verify compliance with the labeling 

regulations, ensuring that the required label 

• Is affixed to the immediate container and contains all the required information 

(mandatory features) 

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---

• Has an accurate ingredients statement 

• Identifies any proteinaceous substances such as allergens 

• Meets requirements for restricted ingredients 

Restricted ingredients (RIs) are non-meat ingredients, such as curing agents or antioxidants. 

They are direct food additives that have a regulatory limit established in 9 CFR 424.21. This 

regulation continues in Directive 7120.1 “Safe and Suitable Ingredients used in the Production 

of Meat, Poultry, and Egg Products,” which is updated quarterly. In general, the establishment 

may add the ingredient to the product’s formula in any amount up to its regulatory limit. We will 

also learn that some products require certain RIs and amounts to meet their standard of identity. 

When performing the Labeling Product Standards Task, IPP are to verify compliance with the 

regulations and standards for products that have a standard of identity. Standards of identity 

are established in FSIS regulations and in the Food Standards and Labeling Policy Book for 

many meat and poultry products. For example, standards of identity for meat products can be 

found in 9 CFR 319 and in 9 CFR 381 Subpart P for poultry products. 

As part of their standard of identity, some products (such as some cured products) have 

established limits for increased weight after processing expressed as gain or yield. Some 

products must decrease in weight after processing, with a minimum shrink requirement (such as 

ham or bacon). These required percentages are verified by calculations when performing the 

Percent Yield/Shrink Task. 

When performing the X Percent Solution Task, IPP are verifying the label truthfulness 

pertaining to the percentage of added solution which has been declared on the label. IPP 

calculate the percentage added by formulation and comparing the result to the amount on the 

label. 

The Net Weights Task is performed to ensure establishments are properly representing on the 

label the amount of product in the container. Net Weight calculations allow for some variation, 

but IPP perform this task to verify regulatory compliance. 

Inspection Responsibilities 

As with other inspection tasks, IPP are to schedule the tasks on the dates most appropriate and 

verify the regulatory requirement using the GAD Thought Process – Gather information, Assess 

the information and Determine compliance. FSIS Directive 7000.1 provides guidance for 

verifying NFSCP regulations. The Public Health Information System (PHIS) assigns NFSCP 

tasks to the establishment’s task lists based on the product information recorded in the 

establishment profile. NFSCP tasks are performed to verify that meat, poultry, and egg products 

distributed to consumers are not economically adulterated or misbranded. 

IPP are not to perform directed NFSCP tasks unless they observe conditions or activities while 

performing a food safety verification task that gives them a reason to suspect that product has 

not met NFSCP regulatory requirements. Laboratory testing is used when it is the only means 

available to determine regulatory compliance. 

Compliance with the NFSCP regulations is on per lot basis and the establishment’s control of 

the process being assessed such as applying accurate labeling to product, applying added 

solutions to product, applying an accurate net weight statement and/or formulating products to 

meet their standard of identities. Notify establishment management orally and then in writing 

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with an NR when there is noncompliance. When uncertain, discuss the situation with your 

supervisor. 

Examples of economic adulteration include meat or poultry components used above the 

maximum limit, water used above the maximum limit, and restricted ingredients used above the 

maximum limit. Examples of misbranding include the minimum amount of meat or poultry 

component not added, a required ingredient not added, and an ingredient that is not allowed is 

added. These lists are not inclusive. 

While performing NFSCP tasks, IPP may uncover concerns related to an establishment’s food 

safety system, such as the Sanitation SOP or the HACCP plan. When this occurs, IPP should 

perform the appropriate food safety inspection task as a directed task following the instructions 

in FSIS Directive 5000.1. For example, if an IPP is performing the general labeling verification 

task and discovers that the establishment has formulated a product with an allergen or other 

ingredient of public health concern without properly declaring the ingredient on the label, the IPP 

should pursue the food safety aspects of this finding by scheduling and performing the 

appropriate directed HACCP Verification Task. 

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02 - General Labeling 

Objectives 

After completing this module, the student will be able to: 

1. Define the following terms: 

a. Immediate container 

b. Generic labeling 

c. Label 

d. Sketch labeling 

e. Principal display panel (PDP) 

f. Shipping container 

2. Identify the eight mandatory features of an immediate container label. 

3. Identify the mandatory features that must be shown on shipping containers. 

4. Identify the two types of labeling approvals granted by the Labeling and Program 

Delivery Staff (LPDS). 

5. Identify the product name labeling requirements for raw meat and poultry products that 

contain added solutions. 

6. Identify the product name and cooking instruction labeling requirements for mechanically 

tenderized raw beef products. 

7. Describe how to perform the General Labeling inspection task. 

Labeling Regulatory Requirements 

Labeling regulatory requirements for meat products appear in Part 317—Labeling, Marking 

Devices, and Containers. Labeling regulatory requirements for poultry products appear in Part 

381 - Poultry Products Inspection Regulations, Subpart N - Labeling and Containers. This 

segment of the module will specifically address the requirements in Subpart A of Part 317 of the 

regulations. The section of the poultry inspection regulations that references the same or similar 

requirements is identified in brackets at the end of pertinent paragraphs. 

§317.2(a) - A label within the meaning of this part shall mean a display of any printing, 

lithographing, embossing, stickers, seals, or other written, printed, or graphic matter upon the 

immediate container (not including package liners) of any product. 

Before use, labels require approval, either generic approval (when applicable) or by LPDS 

(sketch approval for certain products and temporary approval), 9CFR 412. 

§317.1—Labels required; supervision by program employee. 

§317.1(a)—When, in an official establishment, any inspected and passed product is placed in 

any receptacle or covering constituting an immediate container, there shall be affixed to such 

container a label as described in §317.2 [§381.115] 

§301.2 identifies an immediate container as the receptacle or other covering in which any 

product is directly contained or wholly or partially enclosed. 

Products, such as whole or half carcasses or carcass parts, bearing the required, legible marks 

of inspection may be removed from the official establishment without further restriction. Once an 

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official establishment places any inspected and passed product into any receptacle (carton, box, 

etc.) or covering (wrapper, plastic bag, etc.) constituting an immediate container, a label that 

complies with the regulations, must be affixed to it prior to it leaving the establishment. 

Some coverings or immediate containers don’t have to have a label affixed to them. These 

exceptions are identified in §317.1(a)(1) through (6). For example, properly marked products 

enclosed in uncolored, transparent coverings, such as cellophane, do not have to be labeled if 

the markings are clearly legible through the covering. The coverings cannot have any printed or 

graphic material on them. 

Note: In some cases, the shipping container becomes the immediate container (e.g., when 

product units are bulk packed and not individually wrapped and labeled) and must then bear a 

label with all the required features (far left slide). 

§301.2 identifies a shipping container as the outside container (box, bag barrel, crate or other 

receptacle) containing or wholly or partly enclosing any product packed in one or more 

immediate containers. In some cases, the shipping container becomes the immediate container 

(e.g., when product units are bulk packed and not individually wrapped and labeled) and must 

then bear a label with all the required features. 

§317.1(c) - No covering or other container which bears or is to bear a label shall be filled, in 

whole or in part, except with product which has been inspected and passed in compliance with 

the regulations in this subchapter, which is not adulterated and which is strictly in accordance 

with the statements on the label. No such container shall be filled, in whole or in part, and no 

label shall be affixed thereto, except under supervision of a Program employee. [§381.136] 

Only inspected and passed product that meets all regulatory requirements, is unadulterated, 

and has an accurate label may be packaged. Packaging and labeling operations can only be 

performed under the supervision of an IPP. Under the supervision of the IPP only means that 

he or she is on duty. The IPP does not need to continually oversee the filling and labeling of 

packages or containers. 

Unlabeled Protective Coverings 

From the Food Standards and Labeling Policy Book, PROTECTIVE COVERINGS (MEAT): 

Processed or Prepared Product - Immediate containers, e.g., bags, cardboard cartons, tray 

packs, and film bags enclosing processed or prepared product can be considered protective 

coverings and exempt from the marking and labeling requirements if placed in a shipping 

container which meets all mandatory labeling requirements of an immediate container. This 

does not exempt the mandatory identification and marking which is specifically required on the 

immediate container of cooked beef (9 CFR 318.17). In addition, the shipping container must be 

clearly marked “Packed for Institutional Use” or an equally descriptive statement of intended 

limited distribution. Unlabeled product may not be removed from shipping containers for further 

distribution nor displayed or offered for sale. 

Unprocessed Meat Cuts - Transparent film bags enclosing individual meat cuts in an 

unprocessed state can be considered protective coverings and exempt from the marking and 

labeling requirements if placed in a shipping container which meets all mandatory labeling of an 

immediate container. These unlabeled meat cuts may only be removed from the shipping 

container for resale and further distribution to retailers, hotels, restaurants, and similar 

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institutions if the product itself or the film bag bears a clearly legible official mark of inspection 

and the establishment number. 

See: Policy Memo 090B dated December 18, 1990 

PROTECTIVE COVERINGS (POULTRY): Under provision of the Poultry Products Inspection 

Act, protective coverings may be exempt from labeling requirements for immediate containers. 

Under certain circumstances, some protective coverings are considered immediate containers; 

under different circumstances, they are regarded only as protective product coverings. 

When plastic film bags, cardboard cartons, etc., are used for protecting poultry sold for export or 

to institutions, e.g., hotels, restaurants, and hospitals (where the contents are consumed on the 

premises), they are exempt from the mandatory labeling of immediate containers, provided the 

shipping container meets all the labeling requirements for an immediate container. Such product 

may not be diverted to retail channels and displayed for sale or be sold to household consumers 

unless they bear all labeling features required for immediate containers. See: 9 CFR 381.65(p) 

§317.2 - Labels: definition; required features. 

Label Definition 

§317.2(a) - A label within the meaning of this part shall mean a display of any printing, 

lithographing, embossing, stickers, seals, or other written, printed, or graphic matter upon the 

immediate container (not including package liners) of any product. 

§301.2 Label. A display of written, printed, or graphic matter upon the immediate container (not 

including package liners) of any article. and §381.1 Label. This term applies to any display of 

written, printed, or graphic matter upon any article or the immediate container (not including 

package liners) of any article. 

Placement of Mandatory Label Information 

§317.2(b) - Any word, statement, or other information required by this part to appear on the 

label must be prominently placed thereon with such conspicuousness (as compared with other 

words, statements, designs, or devices in the labeling) and in such terms as to render it likely to 

be read and understood by the ordinary individual under customary conditions of purchase and 

use. [§381.116(a)] 

All mandatory information must appear on the label’s principal display panel, except as 

otherwise permitted in 9 CFR 317.2 and 9 CFR 381.116. Except for products exported to foreign 

countries or distributed solely to Puerto Rico, the required information must be printed in the 

English language. 

§317.2(d)—The principal display panel shall be the part of a label that is most likely to be 

displayed, presented, shown, or examined under customary conditions of display for sale. 

Where packages bear alternate principal display panels, information required to be placed on 

the principal display panel shall be duplicated on each principal display panel. The principal 

display panel shall be large enough to accommodate all the mandatory label information 

required to be placed thereon by this part and part 319 of this subchapter with clarity and 

conspicuousness and without obscuring of such information by designs or vignettes or 

crowding. In determining the area of the principal display panel, exclude tops, bottoms, flanges 

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 .. .. .. .. .. .. .. .. .. 

the 

the ingredients statement, signature line, and/or nutritional facts may be placed together to form 

on the principal display panel are identified in 9 CFR 317.2 and 9 CFR 381.116. For example, 

Additional panels where certain mandatory label information may be shown in lieu of showing it 

as sold or as served. 

package label that describes the content of the container or package or represents the product 

information panel. Certain mandatory features may also be displayed on the front riser 

panel of a frozen food cartons and the 20% panel of a cylindrical container. A cylindrical 

container’s 20% panel description and location is identified in 317.2(d)(2)(ii) and 

317.2(d)(2)(ii) and 381.116(b)(2)(ii). 

381.116(b)(2)(ii). This panel is reserved for certain mandatory label information also identified in 

317.2(f)(2) On containers of frozen dinners, entrees, pizzas, 

the front riser panel: 

and similar consumer packaged products in cartons the ingredient statement may be placed on 

Provided, That the words “see ingredients” followed immediately by an 

Information Panel 

without intervening print or designs. 

arrow is placed on the principal display panel immediately above the location of such statement 

PDP Panel 

Information 

20% Panel on a Cylindrical Container 

Panel 

20%

40% 

PDP 

Panel 

20%

Either to the left or right of the PDP 

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Front Riser Panel 

PDP 

Front Riser Panel 

See Ingredients ↓

Information Panel 

According to §317.2(m)(1), the information panel is the first surface to the right of the principal 

display panel (with some exceptions) is a particular location on the package or container other 

than the principal display panel. It may be formed by placing certain mandatory features 

together. The arrangement of these mandatory label features can be on a horizontal plane, 

vertical plane, or a combination of the two. §381.116(c)(1) has a slightly different definition. It is 

that part of the label that is the first surface to the right of the PDP as observed by an individual 

facing the PDP with some exceptions in 9 CFR 381.116(c)(1)(i-iii). 

§317.2(m)(1) The information panel is that part of a label that is the first surface to the right of 

the principal display panel as observed by an individual facing the principal display panel, with 

the following exceptions: (i) If the first surface to the right of the principal display panel is too 

small to accommodate the required information or is otherwise unusable label space, e.g., 

folded flaps, tear strips, opening flaps, heat-sealed flaps, the next panel to the right of this part 

of the label may be used; (ii) If the package has one or more alternate principal display panels, 

the information panel is to the right of any principal display panel; (iii) If the top of the container 

is the principal display panel and the package has no alternate principal display panel, the 

information panel is any panel adjacent to the principal display panel. 

Information panel configurations: Combination plane (e.g., nutrition panel shown vertically with 

the ingredients statement and signature line to the right which is horizontal), Vertical plane 

(e.g., the nutrition panel, ingredients statement, and signature line are all contiguous vertically 

without intervening information). 

Mandatory Features of a Label 

Up to eight features may be required on an immediate container label. The eight mandatory 

features are identified in the table in Attachment 1. 

Quick overview of label features: Required on the PDP: product name, handling statement, 

net weight statement, and the inspection legend. May be on either the PDP or the information 

panel: ingredients statement, signature line, nutrition panel. May be anywhere on package: safe 

handling instructions and the establishment number. See below for more details about each. 

Name of the Product 

§317.2(c)(1)—The name of the product, which in the case of a product which purports to be or 

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is represented as a product which a definition and standard of identity or composition is 

prescribed in part 319...shall be the name of the food specified in the standard, and in the case 

of any other product shall be the common or usual name of the food, if any there be, and if there 

is none, a truthful descriptive designation as prescribe in paragraph (e) of this section... 

[§381.117(a)] 

Fresh pork sausage (§319.141), Italian sausage (§319.145) and frankfurters (319.180(a)) are 

examples of products that have standards of identity we will cover in this course. Ground beef is 

another meat product that has a standard of identity (§319.15(a)). Pork Shoulder and Beef Rib 

Eye Steak are common and usual names. "Sloppy Joe" is a fanciful name and must be 

qualified with the descriptive name "barbecue sauce with (species)". 

Product names must be prominently shown on the principal display panel. 

Raw Meat and Poultry Products Containing Added Solutions Descriptive Designations (if 

applicable) 

§317.2(e)(2) - The product name for a raw meat product that contains added solution and does 

not meet a standard of identity in 9 CFR part 319 must contain a descriptive designation that 

includes: 

(i) The percentage of added solution (total weight of the solution ingredients divided by the 

weight of the raw meat without solution or any other added ingredients multiplied by 100). The 

percentage of added solution must appear as a number (such as, 15, 20, 30) and the percent 

symbol (%). The percentage of added solution may be declared by the words ``containing'' or 

``contains'' (such as, ``contains 15% added solution of water and salt,'' or ``containing 15% 

added solution of water and teriyaki sauce''). 

The word “contain” or “contains” is not required. Other words that may be used in the descriptive 

designation include “added,” “with,” or “up to”, “injected,” or “flavored.” The word “solution” is 

not required in the descriptive designation as long as the added ingredients are included. The 

words “marinated” and “basted” may be used in the descriptive designation without restriction to 

the level of solution. All ingredients that make up the solution, including water if that is the liquid 

used in the formula, must be declared in the descriptive designation. 

(ii) The common or usual name of all individual ingredients or multi-ingredient components in 

the solution listed in descending order of predominance by weight. 

(iii) When the descriptive designation includes all ingredients in the solution, a separate 

ingredients statement is not required on the label. When the descriptive designation includes 

multi-ingredient components and the ingredients of the component are not declared in the 

descriptive designation, all ingredients in the product must be declared in a separate ingredients 

statement on the label as required in Sec. 317.2(c)(2) and (f). 

A multi-ingredient component is an ingredient added to the formula that itself is made up of two 

or more ingredients, for example, seasoning (salt and spices) or soy sauce (water, soybeans, 

wheat). 

(iv) The product name and the descriptive designation must be printed in a single easy-to-read 

type style and color and must appear on a single-color contrasting background. The print may 

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appear in upper and lower case letters, with the lower case letters not smaller than one-third 

(\1/3\) the size of the largest letter. 

(v) The word ``enhanced'' cannot be used in the product name. [381.117(h)] 

This rule applies to: 

• raw meat or poultry products where added solution increases the raw weight of the meat 

or poultry by any amount, for example, chicken with 2% solution of water and potassium 

lactate 

• products where solution has been incorporated into raw meat or poultry through any 

method, for example, marinating, basting, injection, vacuum tumbling, and 

• raw products with added solution going to Food Service, HRI, and retail 

The regulation does not apply to cooked product or products with a standard of identity where 

added liquid ingredients comply with the standard. 

The product name and descriptive designation may appear on more than one line provided 

there is no intervening text or graphics. The font sizes may be different provided they meet the 

1/3rd size requirement. 

Mechanically Tenderized Beef Product Name and Cooking Instructions (if applicable) 

§317.2(e)(3) - Product name and required validated cooking instructions for needle- or bladetenderized beef products. 

(i) Unless the product is destined to be fully cooked or to receive another full lethality treatment 

at an official establishment, the product name for a raw or partially cooked beef product that has 

been mechanically tenderized, whether by needle or by blade, must contain the term 

‘‘mechanically tenderized,’’ ‘‘needle tenderized,’’ or ‘‘blade tenderized,’’ as a descriptive 

designation and an accurate description of the beef component. 

(ii) The product name must appear in a single easy-to-read type style and color and on a 

single-color contrasting background. The print may appear in upper and lower case letters, with 

the lower case letters not smaller than 1⁄3 the size of the largest letter. 

(iii) The labels on raw or partially cooked needle- or blade-tenderized beef products destined 

for household consumers, hotels, restaurants, or similar institutions must contain validated 

cooking instructions, including the cooking method, that inform consumers that these products 

need to be cooked to a specified minimum internal temperature, whether the product needs to 

be held for a specified time at that temperature or higher before consumption to ensure that 

potential pathogens are destroyed throughout the product, and a statement that the internal 

temperature should be measured by a thermometer. These validated cooking instructions may 

appear anywhere on the label. 

Products covered: 

• Needle- or blade-tenderized raw beef products destined for household consumers, 

hotels, restaurants, or similar institutions (HRI) 

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Products not covered: 

• Non-intact beef products that are clearly non-intact (e.g., ground beef patties, hamburger 

patties, beef patties) 

• Beef products tenderized by other than needle/blade, such as pounding or cubing, which 

visibly changes the appearance of the product, e.g., cubed beef steak 

• Fully cooked beef products and those destined to another Federal establishment for a 

full lethality treatment 

• Raw or partially cooked products labeled as “Corned Beef” that have been mechanically 

tenderized (including through injection of a solution) 

• Raw mechanically tenderized beef products that are less than 1/8” thick, such as, beef 

bacon or carne asada, or raw mechanically tenderized beef products that are diced, 

such as stew meat 

Labels must bear: 

• The descriptive designation “mechanically tenderized,” “blade tenderized,” or “needle 

tenderized” and an accurate description of the beef component in the product name; and 

in close proximity; w/o intervening text or graphic 

• All words in the descriptive designation be in the same style, color, and on a single-color 

contrasting background 

• Upper and lower case allowed; however, the smallest letter must be at least 1/3 the size 

of the largest letter 

• Validated cooking instructions for subject products destined for household consumers, 

hotels, restaurants, or similar institutions 

Validated Cooking Instructions would address: 

• A cooking method, (e.g., grill or bake) 

• Usually includes cooking time(s), (e.g., bake 1 hour, grill 5 minutes on each side) 

• That these products need to be cooked to a specified minimum internal temperature, 

• Whether these products need to be held for a specified time at that temperature or 

higher before consumption, i.e., dwell time or rest time, to ensure that potential 

pathogens are destroyed throughout the product, and 

• A statement that the internal temperature should be measured by a thermometer 

14 
Ingredients: Beef flank steak, water, salt, spices

 

 

 

SAFE HANDLING INSTRUCTIONS 

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Nutrition Facts 

Serv~ng Size 1 Piece (142g)/5oz. Servinis Per Container 4 

.AaolnthfSenllg 

Calories 290 Calories from Fat 190 

Total Fat 16g 

'!. Dally Vat•• 

25% 

Saturated Fat 8g 

Trans Fat Og 

40% 

Cholesterol 75mg 25% 

Sodium 440mg 18% 

Total CartiohJdrate 1 g 0% 

Dieta!}'. Fiber Og 0% 

Sugars 1g 

Protein 24i I 

Vitamin A 0% . V-damin C 8% 

Calcium 2% . Iron 15% 

'Pei\ffl [}at,, Values I/! bastdMi Z(Q)Ciln ~~ 

Mechanically Tenderized Beef Labeling Workshop 

You have scheduled a General Labeling task and selected the label for a raw mechanically 

tenderized beef flank steak destined for household consumers, hotels, restaurants, or similar 

institutions. 

Beef Flank Steak 

Smoke Flavor Added 

NET WEIGHT: 20 OZ (1.25 LB) 

KEEP REFRIGERATED 

, sodium phosphate 

Cooking Instructions: 

To ensure adequate cooking, grill 5 minutes 

over medium heat. Then flip over and grill 

an additional 5 minutes. 

Meat Company 501 Main St, 

Beltsville, MD 00000 

Mechanically 

Tenderized 

Containing Up to 15 percent of a Solution 

15 
 

 

 

 

 

 

 

 

 

 

 

 

1. What is your first name? 

2. What is your last name? 

3. Does the label comply with §317.2(e)(3) of the regulations? 

a. Yes 

b. No 

4. Does the designation “Mechanically Tenderized” need to be part of the product name? 

a. Yes 

b. No 

5. What is incorrect regarding the color of the background of the descriptive designation? 

a. Nothing, there is no regulation regarding color of the background 

b. The background is not a single color and contrasting 

c. It should be white. 

6. Does the label comply with the §317.2(e)(2) of the regulations? 

a. Yes 

b. No 

7. Is the product misbranded? 

a. Yes 

b. No 

16 
 

 

 

 

Net weight statement (if needed) 

§317.2(c)(4)—An accurate statement of the net quantity of contents as prescribed in paragraph 

(h) of this section...[§381.121(a)] 

As stated in §317.2(h)(1) through (5), the net weight statement must: 

• Appear on the principal display panel in a conspicuous and easily legible boldface 

print or type in distinct contrast to other material on the container. 

• Not be false or misleading and shall express an accurate statement of the quantity of 

contents exclusive of wrappers and packing materials. 

• Reasonable variations caused by loss or gain of moisture during the course of good 

distribution practices or by unavoidable deviations in good manufacturing practices will 

be recognized. Variations from stated quantity of contents shall be as provided in 

§442.2. The statement shall not include any term qualifying a unit of weight, measure, or 

count such as “jumbo quart,” “full gallon,” “giant quart,” “when packed,” “minimum,” or 

words of similar importance. 

• Appear in the lower 30 percent portion of the principal display panel, unless otherwise 

exempt in the regulations. The statement may appear in more than one 

line. §317.2(h)(3) 

• The term "Net Weight" or "Net Wt." refers to contents in terms of weight. "Net Content" 

refers to fluid measure. 

• The net weight statement shall not include any term qualifying a unit of weight, measure 

or count, e.g., “jumbo quart,” “full gallon,” “when packed,” or “minimum.” 

• Be expressed in terms of Avoirdupois weight (US system) or liquid measure (when 

100% liquid). Per §317.2(h)(4), a 3⁄4 pound retail package would be labeled “Net Wt. 12 

oz.” except for random weight which may use “lb.” as the unit even when the weight is 

less than one pound per §317.2(h)(5). 

• Type size, see §317.2(h)(6), the minimum type size is based on the size of the PDP, 

sizes range from 1/16th inch to 1⁄2 inch. The ratio of the height to the width of the type, 

see §317.2(h)(7). 

• Spacing, see §317.2(h)(8) - Spacing above and below by the height of the letter “N” and 

to the left and right by twice the width of the lettering. 

For Random weight packages, see §317.2(h)(5),(9)&(11). A random weight "consumer size 

package’’ is one of a lot, shipment or delivery of packages of the same product, with varying 

weights and with no fixed weight pattern (381.121(c)(10)). 

Inspection Legend and Establishment Number 

§317.2(c)(5)—An official inspection legend and...the number of the official establishment, in the 

form required by part 312 of this subchapter. [§381.123(a)(b)] 

17 
 

 

 

 

 

 

 

 

 

 

~EC~ ~ 

~ .. ~ ~~\.

BY 

ESOAf/' <"~V~ ~ 

-3us~v * ~ en • • * 

DEPARTM EMT OF 

AGRICULTURE 

P-42 

INSPECTED 

AND PASSED BY 

DEPARTM ENT OF 

AGRICULTURE 

EST. 38 

Labels on all products shall show an official inspection legend as illustrated in §312.2, §352.7, 

or §381.96 of the regulations. The inspection legend shall be in the exact form and arrangement 

as shown in the examples. It may be of any size, provided it is sufficient, and any color as long 

as it is conspicuous and readily legible. The proportions of letter size and boldness must be as 

illustrated in the regulations. 

The legend must be located on the principal display panel or on the 20% panel of a 

cylindrical container. 

As stated in §317.2(i), the establishment number may be located inside or outside of the 

inspection legend. The establishment number may be located anywhere on the exterior of the 

container or its labeling. 

From the Food Standards and Labeling Policy Book, INSPECTION LEGENDS (DUAL) -

Products consisting of mixed meat and poultry ingredients shall bear either the official meat 

inspection legend or poultry legend, depending on which ingredients are present in the greater 

amounts. If meat or poultry ingredients exist in equal proportions, either official legend may be 

used. If meat and poultry ingredients exist in exact proportions and both appear in the product 

name, the official legend must reflect the ingredient appearing first in the product name. 

Containers of products intended for sale to household consumers can bear only the official mark 

of inspection of the product enclosed. Containers of products intended for distribution to other 

than the retail trade may bear both the official meat inspection legend and the official poultry 

products inspection legend. 

Handling Statement (if needed) 

§317.2(k) - Packaged products which require special handling to maintain their wholesome 

condition shall have prominently displayed on the principal display panel of the label the 

statement: “Keep Refrigerated,” “Keep Frozen,” “Perishable Keep Under Refrigeration,” or such 

similar statement as the Administrator may approve in specific cases. Products that are 

distributed frozen during distribution and thawed prior to or during display for sale at retail shall 

bear the statement on the shipping container: “Keep Frozen.” The consumer-size containers for 

such products shall bear the statement “Previously Handled Frozen for Your Protection, 

Refreeze or Keep Refrigerated.” 

Ingredients Statement (if needed) 

§317.2(c)(2) - If a product is fabricated from two or more ingredients, the word "ingredients" 

followed by a list of ingredients as prescribed in paragraph (f) of this section... [§381.118(a)] 

18 
 

 

 

 

 

 

 

 

 

 

 

The word “ingredients” must be spelled out, never abbreviated. The ingredients must be listed 

by their common and usual name in descending order of predominance according to the 

amounts used in the product’s preparation. There are a few exceptions. 

Spices (e.g. mustard, pepper, etc.) and flavorings (e.g., oleoresin of black pepper, garlic oil, 

etc.) as defined in §317.2(f)(i) may be listed as “spice” or “flavoring” as appropriate in the 

ingredients statement. For instance, spices, spice extractives, essential oils, oleoresins, onion 

powder, garlic powder, celery powder, onion juice, and garlic juice may be listed as flavorings 

but flavorings (e.g., oleoresins, essential oils, etc.) cannot be listed as spices in the ingredients 

statement. 

Ingredients present in individual amounts of 2% or less may be listed in other than descending 

order of predominance if: 

• Such ingredients are listed by their common or usual name at the end of the ingredients 

statement; and 

• Such ingredients are preceded by a quantifying statement such as "contains ___ percent 

of ___," or "less than ___ percent of ___." The blank before the word "percent" shall be 

filled with a threshold level of 2% (or less, as appropriate, e.g., 1.5%, 1%, or 0.5%). No 

ingredient subject to the quantifying statement may be present in an amount greater 

than the stated threshold. Such ingredients may be adjusted in the formulation without 

changing the label if the adjusted amount complies with §318.7(c)(4) or §381.147(f)(4) 

and does not exceed the stated threshold level. 

Note: For some products an ingredients statement can be substituted with a “Cured with 

statement.” The label states “Cured with water, salt, sodium phosphate.......” The meat is left 

out and just includes all of the other ingredients. We see this with bacon, corned beef, ham, 

and other cured products. 

The ingredient statement must be located on either the principal display panel,

information panel, 20% panel of a cylindrical container, or the front riser panel of a frozen 

food carton when the phrase “see ingredients ↓” is on the PDP immediately above the

location of the ingredients statement without intervening print or designs. 

Signature Line 

§317.2(c)(3)—The name and place of business of the manufacturer, packer, or distributor for 

whom the product is prepared, as prescribed in paragraph (g) of this section... [§381.122] 

The name and place of business of the product’s manufacturer, packer, or distributor is known 

as the signature line. The place of business shall be shown on the label by city, state, and zip 

code when the business is listed in a telephone or city directory (Note: an online directory does 

not meet this criteria); and if not listed in such a directory, the place of business shall also show 

the street address. The signature line must be located on either the principal display panel, 

information panel, 20% panel of a cylindrical container, or the front riser panel of a frozen food 

carton. When the product is prepared by one company and distributed by a different company, 

phrases like “prepared for...” or “distributed by” must precede the name and business address. 

Safe handling instructions (if needed) 

§317.2(l)—Safe handling instructions shall be provided for: all meat and meat products... or 

that do not meet the requirements contained in §318.17, or that have not undergone other 

19 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

processing that would render them ready-to-eat; and all comminuted meat patties not heat 

processed in a manner that conforms to the time and temperature combinations in the Table for 

Permitted Heat-Processing Temperature/Time Combinations for Fully Cooked Patties in 

§318.23... [§381.125(b)]. 

Product that will be further processed at another official establishment and products that are for 

export only are exempt from the safe handling requirements. 

The safe handling instructions may be located anywhere on the outside of an immediate 

container. 

Nutrition Facts Panel (unless an exemption applies) 

§317.300 - (a) Nutrition labeling must be provided for all meat and meat food products intended 

for human consumption and offered for sale, except single-ingredient, raw meat products that 

are not ground or chopped meat products described in §317.301 and are not major cuts of 

single-ingredient, raw meat products identified in §317.344, unless the product is exempted 

under §317.400. Nutrition labeling must be provided for the major cuts of single-ingredient, raw 

meat products identified in §317.344, either in accordance with the provisions of §317.309 for 

nutrition labels, or in accordance with the provisions of §317.345 for point-of-purchase 

materials, except as exempted under §317.400. For all other products for which nutrition 

labeling is required, including ground or chopped meat products described in §317.301, nutrition 

labeling must be provided in accordance with the provisions of §317.309; except as exempted 

under §317.400. 

FSIS requires nutrition labeling of the top 40 major cuts of single-ingredient, raw meat and 

poultry products (as defined in §317.344 and §381.444). This nutrition labeling must be on 

labels or at point-of-purchase, unless an exemption applies, however, the small business 

exemption specifically is not applicable to these cuts. FSIS also requires nutrition labels on all 

ground or chopped meat and poultry products as defined in §317.301 and §381.401 

respectively, with or without added seasonings, unless an exemption applies. In addition, when 

a ground or chopped product does not meet the regulatory criteria to be labeled “low fat'' 

(317.362(b)), a lean percentage statement may be included on the label or in labeling as long as 

a statement of the fat percentage that meets the specified criteria also is displayed on the label 

or in labeling when in compliance with §317.362(f) or §381.462(f). 

Note: Ground and chopped product does not include products such as sausage, meatballs, 

beef patties. The “ground/chopped” products only includes products named “ground beef,” 

“hamburger,” “ground pork,” “ground chicken,” “ground turkey,” “chopped beef,” etc. 

Nutrition labeling information may be shown on the principal display panel, on the information 

panel, or anywhere on the immediate container. There are exceptions for gift packs or when 

packaging doesn’t allow for sufficient space (§317.302 or §381.402). 

Establishments may voluntarily provide nutrition labeling for single ingredient, raw meat and 

poultry products that are not one of the top 40 major cuts and are encouraged to do so. 

The regulations in §317.302 exempt products produced by small businesses, provided that the 

labels for these products bear no nutrition claims or nutrition information. There are two criteria 

for exemption, 1) less than 500 employees AND 2) less than 100,000 pounds of a specific 

product formula/nutrition profile per year. When calculating the total pounds of a formula, both 

retail and custom exempt with all pack sizes are included. For example, an establishment has a 

ground beef 70/30 formula. This formula is sold in bulk, as patties, in various retail sized 

packages, under various brand names, for HRI, some retail exempt, and some as custom 

20 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

exempt. All of this ground beef 70/30 is counted together for the total pounds per year. Each 

specific product formula/nutrition profile will need to be evaluated for the small business 

exemption and both criteria need to be met for that product labeling to be exempt from bearing 

the nutrition facts panel. It is possible for popular products manufactured in quantities larger 

than 100,000 pounds per year to be exempt but other products with production lower than 

100,000 pounds per year to be exempt even though they are manufactured in the same 

establishment. 

Mandatory Features for Shipping Containers 

Shipping containers must bear the following mandatory features: 

• Inspection legend [316.13(a)] and establishment number [317.2(i)] 

• Handling statement (if needed) [317.2(k)] 

• Net weight statement (if needed) [317.2(h)(9)(i)] 

The establishment number may be located outside the inspection legend or elsewhere on the 

exterior of the container or its labeling if shown in a prominent and legible manner in a size 

sufficient to ensure easy visibility and recognition and accompanied by the prefix “EST.” 

Note: The shipping container must bear a net weight statement per 381.121(a) and the 

following statements: "Tare weight of consumer package ___ oz." (weighed to nearest 1/8 

ounce or less), and the "Net wt.” to be marked on consumer packages prior to display and sale" 

when retail random weight poultry products without the net weight statement are in the shipping 

container. 

§412.1 - Labeling approval. 

§412.1(a) No final label may be used on any product unless the label has been submitted for 

approval to the FSIS Labeling and Program Delivery Staff, accompanied by FSIS Form 7234–1, 

Application for Approval of Labels, Marking, and Devices, and approved by such staff, except 

for generically approved labels authorized for use in §412.2. The management of the official 

establishment or establishment certified under a foreign inspection system, in accordance with 

parts 327 and 381, subpart T, must maintain a copy of all labels used, in accordance with parts 

320 and 381, subpart Q, of this chapter. Such records must be made available to any duly 

authorized representative of the Secretary upon request. 

No final labeling shall be used on any product unless the sketch labeling of such final labeling 

has been submitted for approval to FSIS except for generically approved labels authorized for 

use in 9 CFR 412.2. A sketch label is a printer’s proof or the equivalent which clearly shows all 

labeling features, including the size, and location. 

FSIS requires the submission of labeling applications for the following four categories: 

1. Labels for products produced under religious exemption (9 CFR 412.1(c)(1)) 

2. [Reserved] 

3. Labels with special statements and claims (9 CFR 412.1(c)(3)) 

4. Labels for temporary approval (9 CFR 412.1(c)(4)). Under certain conditions, LPDS may 

grant a temporary approval for the use of a final label that may be deficient in some 

particular requirement for up to 180 calendar days. 

Any label that was previously approved as a sketch by FSIS qualifies to be used without any 

further approval. 

21 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The requirements for generically approved labels is covered in §412.2. IPP do not generically 

approve labels. Establishments do not generically approve labels. Generically approved labels 

are considered to be approved by FSIS provided that the label meets the criteria listed in 

§412.2(b). “Approved by FSIS” refers to compliance with the FSIS 9 CFR regulations, it does 

not mean that the labels have been submitted to Labeling and Program Delivery Staff (LPDS). 

Labeling Record 

The responsibility of ensuring that generic labeling complies with regulatory requirements rests 

with the establishment. The establishment is responsible for creating the generic labeling record 

and is required to keep a copy of all generic labeling and related information in its files. A 

corporate headquarters may create and maintain the labeling files for their associated 

establishments. When labeling records are needed, the IPP may request the labeling records 

from the assigned establishment. The labeling records are required to be made available to the 

requesting IPP within 24 hours (FSIS Directive 7221.1). 

There is no specific format for a generic labeling record, however, it is required to include all 

information in FSIS Form 7234-1 that would be provided to LPDS as if they were submitting for 

sketch approval. Some establishments choose to use the FSIS 7234-1 form since they are 

familiar with the form, and it is a reminder of what information is needed in the labeling record, 

but they could provide all required information in another format. The labeling record should 

also include the final printed labeling that will be used on the finished packaged product and any 

supporting information that may be needed to verify that labeling is truthful and not misleading. 

Some companies choose to number their generic approvals as a way to track them internally, 

but there is no FSIS requirement to do so. 

§317.8 - False or misleading labeling or practices generally; specific prohibitions and 

requirements for labels and containers. 

§317.8(a) - No product or any of its wrappers, packaging, or other containers shall bear any 

false or misleading marking, label, or other labeling and no statement, word, picture, design, or 

device which conveys any false impression or gives any false indication of origin or quality or is 

otherwise false or misleading shall appear in any marking or other labeling. No product shall be 

wholly or partly enclosed in any wrapper, packaging, or other container that is so made, formed, 

or filled as to be misleading. [§381.129(a)(b)] 

The product or its packaging material may not bear any false or misleading label, marking or 

labeling. No written or graphic material on the product label or in its marking or labeling may 

convey a false impression or give a false indication of contents. A product’s packaging material 

color, design or kind may not be misleading. Product that bears false or misleading marking or 

labeling is misbranded. 

§317.8(b)(1)-(40) list requirements that product labels and containers must comply with to 

prevent them from having a false or misleading feature. 

22 
 

General Label Review Workshop 

You are a CSI covering a very small wiener processing establishment located in Cut and Shoot, 

Texas. It employs two people and produces one product (New York Wieners in 1⁄2 lb. packages) 

that conforms to the standard of identity in §319.180. The production volume has averaged 

1,800 pounds per week over the past 2 years. Today, you have scheduled a General Labeling 

task and decide to verify whether the label (below) being applied to a lot of wieners complies 

with regulatory requirements. 

New York Brand 

Wieners 

Net Wt. 1⁄2 lb. Perishable, Store below Room Temperature 

INGRED: BEEF AND PORK, WATER, SALT, DEXTROSE, SUGAR, MUSTARD, PAPRIKA, SPICES, SPICE 

EXTRACTIVES, MONOSODIUM GLUTAMATE, SODIUM ASCORBATE, SODIUM NITRITE. 

WORTHLESS MEATERY 

GIG ‘EM, TX 

Please select the best answer to the questions below. 

1. What is your first name? 

2. What is your last name? 

3. What is incorrect with the Ingredient Statement? 

a. Nothing

b. The word “Ingredients” needs to be spelled out 

c. It is not listed in order of predominance 

4. Of the following choices, what is incorrect with the Net Weight 

Statement? 

a. It should be in ounces 

b. Nothing 

c. It should be written in blue ink

23 
5. Is the Handling Statement correct? 

a. Yes 

b. No

6. What is missing from the Signature Line? (Select all that Apply) 

a. The Zip Code 

b. The name of the firm that produced the product 

c. The state the product was produced in 

d. Either “Prepared for” or “Distributed By” 

e. Establishment Phone Number 

7. Is the Inspection Legend correct? 

a. Yes 

b. No 

24 
 

 

 

 

 

 

§317.16 - Labeling and containers of custom prepared products. 

Products that are custom prepared...must be packaged immediately after preparation and 

must be labeled...with the words “Not for Sale” in lettering not less than three-eighth inch in 

height. 

Custom prepared product must be properly labeled and have a prominent “Not for Sale” 

statement. The establishment may include additional labeling on custom prepared products, or 

their containers provided it is not false or misleading. 

Performing the General Labeling Task 

Inspection program personnel perform this task to verify general labeling regulatory 

requirements and determine if the label accurately reflects the finished product. 

General Labeling Requirements 

Verifying that the general labeling requirements involves: 

• observing the application of the label or labeling, 

• selecting labels and labeling for review, and 

• reviewing the establishment’s labeling records 

When IPP observe the packaging and labeling operations, they ensure that immediate 

containers of meat and poultry products have a label attached to them and that shipping 

containers bear the required information. 

When IPP select and review the label/labeling applied to the container or package, they 

determine if: 

• the label contains the mandatory features and other required information such as a 

qualifying statement or descriptive designation, and 

• any printing or colors on the label and packaging material gives a false impression or 

does not meet specific formatting criteria 

Product is misbranded if its label is missing a required feature, qualifying statement, or 

descriptive designation or is anyway false or misleading. 

When IPP review the establishment’s labeling file, they determine if the: 

• label is on file and either met the generic approval requirements or was sketch approved 

by LPDS, 

• label required sketch approval by LPDS and if so, the sketch is attached to the final 

label, 

• label is being used beyond the expiration date if it has been granted a temporary 

approval by LPDS, and 

• product’s formulation (if applicable) and processing procedures are attached to or 

accompany the label/labeling. 

If IPP find noncompliance, they issue an NR and take the appropriate action necessary to 

ensure misbranded product does not enter commerce. 

25 
 

 

 

 

 

 

 

 

Label Accurately Reflects the Product 

Determining that the label accurately reflects the finished product involves reviewing the 

product’s formulation record and observing its actual preparation and, in some cases, 

performing formula calculations. 

When IPP perform this task, they should select one or more batches of product at formulation 

and verify ingredient amounts comply with the formula on file and that no undeclared ingredients 

are added or declared ingredients are omitted. 

The verification may involve: 

• observing pre-weighed ingredients for proper identification and weights, or 

• observing establishment employees weighing ingredients or 

• actually, weighing pre-weighed ingredients to determine if the weight on the container is 

accurate. 

An ingredient added at a different level than indicated in the product formula could affect the 

ingredient order of predominance on the label. The product is misbranded if a declared 

ingredient is omitted, an ingredient is added but not declared on the label, or the ingredient 

order of predominance is not accurate. Depending on the type of undeclared ingredient (e.g., an 

allergen) that is added to the product, it may be either adulterated or misbranded or both. 

The regulations and many product standards of identity allow the establishment to add various 

ingredients to the formula of certain meat and poultry products. 

Some meat and poultry components used in the formulation may have regulatory limits. Some 

nonmeat ingredients have a specified maximum amount or percentage allowed in the product. 

These nonmeat ingredients are called restricted ingredients. The establishment MAY add the 

component or ingredient in any amount up to its permitted limit. 

If the product is formulated with a meat or poultry component with a regulatory limit or with a 

restricted ingredient, the IPP should select one or more batches of product during formulation. 

They should determine the amount or percentage of the meat or poultry component and/or the 

amount of one or more restricted ingredients used in the formula. The IPP verifies that the: 

• percentage of meat or poultry component meets the regulatory limit, 

• restricted ingredient is allowed in the product, and 

• the amount of the restricted ingredient added to the product does not exceed the 

regulatory limit. 

Verifying meat and poultry components or restricted ingredients are in compliance with 

regulatory limits usually requires the IPP to perform a formula calculation. 

When meat or poultry components or restricted ingredients are added at levels in excess of their 

maximum regulatory limit, they become economic adulterants. 

If IPP find noncompliance, they issue an NR and take the appropriate action necessary to 

ensure adulterated or misbranded product does not enter commerce. 

26 
 

 

 

 

 

 

 

 

 

 

 

 

Labeling Summary Workshop 

You are a CSI with a small raw ground beef product establishment on your assignment. The 

establishment produces ground beef, hamburger, and beef patties. The standards of identity for 

these products are provided at the end of the workshop. 

The establishment has one HACCP plan under the Raw Product Non-Intact HACCP category. 

The company has 50 employees and produces about 50,000 lbs. of raw ground beef products a 

week. It operates two continuous production lines 8 hours a day, 5 days a week. The 

establishment has determined one day’s production of a raw beef product is a lot. 

The ground beef patties are 100% beef and produced using a two-step grinding method. The 

hamburger patties and beef patties have non-meat ingredients added at the blending step. The 

process of producing these patties involves a coarse grind, mixing and blending the meat and 

ingredients, and a final grind. Ingredients added to the hamburger patties include salt, 

seasonings and corn syrup. Ingredients added to the beef patties include salt, dried onions, 

flavorings, soy flour and water. The company does not rework broken or misshaped patties and 

it does not accept returned products. The patties are distributed in shelf ready 36-ounce trays or 

bulk packed in 20 lb. boxes. 

The General Labeling task appears on your task schedule today. 

You make your way to the production floor and ask the production supervisor what raw beef 

products are being produced. She states that tray packed beef patties are being produced on 

both lines. You review the labels, product formulation, and production procedures for the beef 

patties on file in the production supervisor’s office. 

You decide to verify product formulation. You observe the following ingredients added to the 

large blender on line 1 and line 2. 

300.0 lbs. 60/40 Beef Trimmings 

85.0 lbs. Water 

60.0 lbs. Soy Flour 

25.0 lbs. Flavorings 

17.5 lbs. Dried Onions 

12.5 lbs. Salt 

You follow the product through the process. At the packaging step for line one, you observe the 

label/labeling being placed on the trays (immediate container) and the shipping container 

markings. 

The label below is being placed on the top of the tray and the safe handing instructions below 

are placed on the bottom of the tray. This is the only labeling applied to the trays. 

27 
 

 

.... ~ 

---

Homestyle Beef Patties 

Ingredients: Beef, Soy Flour, Water, Flavorings, Dried 

Onions and Salt. 

Packed by: ABC Packing House 

Anytown NC, 12345 

Keep Frozen 

UPC 

Safe Handling Instructions 

This product was prepared from inspected and passed meat 

and/or poultry. Some food products may contain bacteria that 

could cause illness if the product is mishandled or cooked 

improperly. For your protection, follow these safe handling 

instructions. 

Keep refrigerated or frozen. Thaw in refrigerator or 

microwave. 

Keep raw meat and poultry separate from other foods. 

Wash working surfaces (including cutting boards), 

utensils, and hands after touching raw meat or poultry. 

Cook thoroughly. 

Keep hot foods hot. Refrigerate leftovers immediately 

or discard. 28 
 

 

 

The shipping container has the inspection legend on it in the upper right corner. This is the only 

printed information on the outside of the box. 

At the packaging step for line two, you observe the following label/labeling being placed on the 

trays (immediate container) and the shipping container markings. 

The label below is being placed on the top of the tray and the safe handing instructions 

illustrated above are placed on the bottom of the tray. This is the only labeling applied to the 

trays. The shipping container for these trays has the inspection legend on it in the upper right 

corner. This is the only printed information on the outside of the box. 

Blue Ribbon Ground Beef Patties 

100% Beef 

Packed by: ABC Packing House 

Anytown NC, 12345 

Keep Frozen 

UPC 

Net Wt. 36 oz. (2.25 Lb.) 

29 
1. What is your first name? 

2. What is your last name? 

3. Based on the review of the product formulation and the labeling applied to the immediate 

containers and shipping containers, has the establishment produced misbranded 

product? 

a. Yes 

b. No 

4. Based on the review of the product formulation and the labeling applied to the immediate 

containers and shipping containers, has the establishment produced adulterated 

product? 

a. Yes 

b. No 

5. Is there a food safety hazard associated with the production of the product? 

a. Yes 

b. No 

30 
 

 

 

 

Workshop Reference Materials 

Product Standards 

FSIS regulations prescribe standards of identity, or composition, for many meat and poultry 

products. Standards of identity set specific requirements for a product's make-up. For instance, 

a product standard may identify: 

• the kind and percentage of meat or poultry required in the product, 

• the maximum percentage of a non-meat/non-poultry ingredient allowed in the product, 

• the maximum percentage of a specific meat or poultry ingredient such as beef cheek 

meat or Mechanically Separated (Species) 

• ingredients that are allowed or expected in the product, and 

• any ingredient that is not allowed in the product. 

• Non-meat ingredients that have a maximum percentage allowed in the finished product 

are called restricted ingredients. The establishment MAY add the ingredient in any 

amount up to its permitted limit. When restricted ingredients are added at levels in 

excess of the regulatory limit, they become adulterants. 

319.15 Miscellaneous beef products. 

(a) Chopped beef, ground beef.‘‘ Chopped Beef’’ or ‘‘Ground Beef’’ shall consist of chopped 

fresh and/or frozen beef with or without seasoning and without the addition of beef fat as such, 

shall not contain more than 30 percent fat, and shall not contain added water, phosphates, 

binders, or extenders. When beef cheek meat (trimmed beef cheeks) is used in the preparation 

of chopped or ground beef, the amount of such cheek meat shall be limited to 25 percent; and if 

in excess of natural proportions, its presence shall be declared on the label, in the ingredient 

statement required by § 317.2 of this subchapter, if any, and otherwise contiguous to the name 

of the product. 

(b) Hamburger. ‘‘Hamburger’’ shall consist of chopped fresh and/or frozen beef with or without 

the addition of beef fat as such and/or seasoning, shall not contain more than 30 percent fat, 

and shall not contain added water, phosphates, binders, or extenders. Beef cheek meat 

(trimmed beef cheeks) may be used in the preparation of hamburger only in accordance with 

the conditions prescribed in paragraph (a) of this section. 

(c) Beef patties. ‘‘Beef Patties’’ shall consist of chopped fresh and/or frozen beef with or without 

the addition of beef fat as such and/or seasonings. Binders or extenders, mechanically 

Separated (Species) used in accordance with § 319.6, and/or partially defatted beef fatty tissue 

may be used without added water or with added water only in amounts such that the product 

characteristics are essentially that of a meat patty. 

31 
 

Attachment 1: FSIS Directive 7221.1 Table 1 Required Label Features 

Feature Reference Location Applies to 

Product Name 9 CFR 317.2(c)(1) or 

381.117 

Principal display panel All products 

Inspection Legend and 

Establishment Number* 

9 CFR 317.2(c)(5) or 

381.123 

Principal display panel, 

or 20% panel of a 

cylindrical container 

All products 

Handling Statement (e.g. 

“Keep Frozen”) 

9 CFR 317.2(k) or 

381.125(a) 

Principal display panel Products requiring 

special handling to 

maintain 

wholesomeness 

Net Weight Statement 9 CFR 317.2(h) or 

381.121 

Principal display panel Product sold at retail, 

unless the net weight is 

applied at retail 

Ingredients Statement** 9 CFR 317.2(f) or 

381.118 

Principal display panel, 

Information panel, 

20% panel of a 

cylindrical container, or 

Front riser panel of a 

frozen food carton 

Products with multiple 

ingredients 

Name and 

Place of Business of the 

Manufacturer, Packer, 

or Distributor 

9 CFR 317.2(g) or 

381.122 

Principal display panel, 

Information panel, 

20% panel of a 

cylindrical container, or 

Front riser panel of a 

frozen food carton 

All products 

Nutrition Facts Panel by 9 CFR 317.300 or 

381.400 

Principal display panel 

or Information panel 

Products not exempted 

by 9 CFR 317.400 or 

381.500 

Safe Handling Instructions 9 CFR 317.2(l) or 

381.125(b) 

Anywhere on the 

immediate container 

Products with a notready-to-eat meat or 

poultry component 

*NOTE: As stated in §317.2(i), the establishment number may be located inside or outside of 

the inspection legend. The establishment number may be located anywhere on the exterior of 

the container or its labeling; for example, it may be located on the end of a can if it is prominent, 

legible, and accompanied by the prefix “Est”. The establishment number may be located off the 

exterior of the container when there is a statement identifying the location of the number; for 

example, "Est. No. on clip" is printed on a bag containing product. 

**NOTE: All ingredients used in the product must be listed in the ingredients statement. Product 

is considered adulterated if an allergen is not listed in the ingredients statement. IPP are to 

contact their supervisor for guidance if at any time they have reason to believe that product 

failing to declare one of the “big 8” allergens [wheat, crustacean shellfish (e.g. crab, lobster, 

shrimp), eggs, fish, peanuts, milk, tree nuts (e.g. almonds, pecans, walnuts), and soybeans] or 

other ingredients of public health concern has entered commerce. FSIS ingredient and allergen 

compliance guidelines are available online. 

32 
 

 

 

 

 

03 - Net Weight 

Objectives 

After completing this module, the student will be able to: 

1. Define the following terms: 

• Net Weight 

• Drained Weight 

• Tare Weight 

• Labeled Weight 

• Standard Weight 

• Gross Weight 

• Random Weight 

• Inspection Lot 

• Package Error 

• Total Package Error 

• Maximum Allowable Variation (MAV) 

2. Describe the steps for verifying net weight. 

3. Describe the criteria for passing an inspection lot. 

4. Determine whether an inspection lot passes or fails. 

Introduction 

Meat and poultry establishments must assure that the net weight statement on a label is not 

false or misleading and expresses an accurate statement of the quantity of contents. Since 

absolute accuracy is virtually impossible, FSIS net weight regulations allow “reasonable” 

variations from labeled weight. 

Terminology 

Net weight -The weight of the packaged product remaining after the deduction for tare weight. It 

is the weight of the nutritious content in the container suitable for food. For added solution 

products, e.g., chicken with X% solution of, the solution is part of the nutritious content. 

Drained weight -The weight of the solids in the container when packed in non-nutritious media. 

Tare weight -The weight of the container, box, wrapper or other packaging material. It is always 

excluded from gross weight when determining the actual net weight. 

Gross weight - the total weight of the nutritious substance (the food) inside the packaging 

(which is the “net weight”) plus the weight of all the packaging (the tare weight). 

Labeled weight - The net weight declared on the label. 

Standard weight packages - Packages or containers that contain a predetermined amount of 

product and have identical net weight declarations, e.g., the full net weight statement is preprinted on labeling, such as, Net Wt. 8 oz. 

Random weight packages - Packages or containers that contain a varying amount of product 

and will not have identical net weight declarations, e.g., each package is weighed, and the 

specific net weight is written into a printed open net weight statement, such as, Net Wt. 

_____LBS, another example is when a scale generates an individual price/weight sticker to 

33 
 

 

 

 

 

 

 

 

apply to the package. Note: the unit of measure for random weight packages may be in pounds 

(lbs.) even when the weight of the package is less than one pound, §317.2(h)(5). 

Directive 7000.1, Verification of Non-Food Safety Consumer Protection Regulatory 

Requirements, identifies the regulations, references, and verification activities for performing 

the Net Weight task. 

Net Weight Inspection Verification Task 

Prior to performing a net weight verification activity, IPP should review the requirements in NIST 

Handbook 44 and then will verify net weight following the procedures in NIST Handbook 133. 

Task Name 9 CFR 

References 

FSIS Issuance 

References 

Inspection Personnel Verification 

Activities 

Labeling - Net 9 CFR NIST Handbook Select an appropriate retail-sized 

Weights §442.1, §442.2, 133 product and 

§442.3, §442.4, NIST Handbook 44 1. Verify net weight regulatory 

§442.5 * FSIS inspectors 

are to use these 

handbooks as the 

definitive references 

for determinations 

of net weight 

compliance. 

Sections identified 

in §442.2(b) of 

NIST Handbook 

133 should Not be 

used. 

requirements by reviewing 

establishment records and 

conducting net weight/drained 

weight, scale calibration, or tare 

weight checks. 

2. Follow the QC program 

requirements after evaluating the 

program to ensure that following 

the program results in 

compliance with net weight 

regulatory requirements. 

NIST Handbooks 44 and 133 are the definitive references for determinations of net wet 

compliance that IPP are to use. 

Scales 

IPP must ensure the scales are of sufficient size, solidly supported, level and accurate. The 

scales are to be certified by the state or local government’s weights and measures authority or 

from a registered or licensed individual at least once per calendar year. The valid certification is 

to be displayed on or near the scale. 

NOTE: Sections identified in §442.2(b) of NIST Handbook 133 should NOT be used. 

Steps to Determine Net Weight 

1. Determine the number of containers or packages in the inspection lot. 

Inspection lot - A collection of identically labeled packages or containers from the same 

production shift available for inspection at one time. The IPP determines the inspection lot. The 

inspection lot passes or fails as a result of net weight testing. 

IPP should define which packages are to be tested as well as determine the size of the 

inspection lot. An inspection lot is defined as a collection of identically labeled packages or 

containers from the same production shift available for inspection at one time. Enforcement 

action can only be taken on the packages contained in the lot that has been defined. 

34 
 

 

 

 

 

 

 

 

Lots may be made up of either standard or random weight packages. “Standard packages” are 

those with identical net content declarations such as containers of meat sauce in 2 L bottles and 

5 lb2.26 kg packages of chicken breasts. “Random packages” are those with differing or no 

fixed pattern of weight, such as packages of meat, poultry or cat. 

2. Select a Sampling Plan. 

Table 2-2. Sampling Plans for Category B 

(for Use in USDA-Inspected Meat and Poultry Plants Only) 

1 2 3 4 

Inspection Lot Size Sample Size Initial Tare 

Sample Size 

Number of Packages

Allowed to Exceed the 

MAVs in Table 2-9 

250 or Fewer 10 2 0 

251 or More 30 5 0 

IPP should use “Category B” sampling plans only to test meat and poultry products that are 

subject to USDA/FSIS regulatory requirements at the point-of-pack locations. Refer to second 

column of Table 2-2 Sampling Plans for Category B from NIST Handbook 133. 

3. Record the inspection data. 

All information collected should be recorded. There is no regulation or policy stating that there 

is a specific type of form that should be utilized to document the inspection data. It may be more 

practical to write the information in a notebook vs a form. See Attachment 2. 

IPP must become familiar with the required information needed to officially determine if net 

weight is in compliance. There are minimum requirements for the information that should be 

collected to verify net weight compliance. Each state may alter the forms slightly as long as the 

minimum NIST criteria are met. The IPP should attach any additional notes, worksheets, etc. as 

needed. 

4. Select the random sample. 

Testing a “sample” of packages from a lot instead of every package in a shipment is efficient, 

but the test results have a “sampling variability” that must be corrected before determining if the 

lot passes or fails. A randomly selected sample is necessary to ensure statistical validity and 

reliable data. This is accomplished by using random numbers to determine which packages are 

chosen for inspection. Improper collection of sample packages can lead to bias and unreliable 

results. Appendix B of NIST Handbook 133 provides Random Number Tables and describes 

various ways to use the tables to randomly select packages within the inspection lot. 

5. Randomly collect a tare sample and determine the average tare weight. 

• See Column 3 of NIST Handbook 133 Table 2-2 Sampling Plan for Category B to 

determine the Initial Tare Sample Size based on the Inspection Lot Size 

• If available, unused dry packaging may be used to determine the tare weight 

• When packages are opened to determine the tare weight, use the first 2 (or 5) randomly 

selected packages of the Inspection Lot in order that they were selected to determine the 

dry tare weight. 

• Weigh each set of packaging materials in the tare sample 

• Add the weights together 

• Divide the total tare weight by the sets of packaging material in the tare sample 

35 
 

 

 

 

 

 

 

 

 

 

 

 

NOTE: When the average tare weight is exactly half of a scale division, round the value up to 

the next scale division (e.g. If the scale units are 1 gram and tare 1=19 g and tare 2=20 g, 

round the 19.5 g average up to 20g). Additional rounding examples are in Attachment 1 at the 

end of the module. 

6. Determine 

Nominal Gross Weight: Add the Average Tare Weight (as determined in step 5 above) to the 

labeled weight to determine the Nominal Gross Weight. Make sure you use the same units of 

measure for both values and that matches the units of measure of the scale being used. 

(average tare weight + labeled weight) = nominal gross weight 

Package error: The difference between the gross weight (the weight of each individual sample 

package that includes the food product and the packaging weight) and the nominal gross 

weight. 

(gross weight of the sample – nominal gross weight) = package error 

-/+ Package error: When the nominal gross weight weighs more than the gross weight the 

sample package weighs less than what the label declares and is recorded as a negative (-) 

package error under the - column. When the nominal gross weight weighs less than the gross 

weight the sample package weighs more than what the label declares and is recorded as a 

positive (+) package error under the + column. 

Dimensionless Units 

If desired, the package error may be expressed as “plus” or “minus” dimensionless unit by 

dividing the package error by the scale graduation. This method eliminates leading zeros and 

the units of measure and results in whole numbers. In the slide example, we were weighing in 

0.001 lb increments, so the unit of measure is 0.001 lb. By dividing + 0.038 lb by .001 lbs, 

instead of recording 0.038 lb in the plus column, record the error as “38” in the plus 

column. The second package error is -0.003 lb and would be recorded as “3” in the negative 

column, and so on. 

− + 

1. 38 

2. 12 

3. 8 

4. 4 

5. 3 

6. 2 

7. 12 

8. 3 

9. 4 

10. 1 

Total: 

9 

Total: 

78 

Total Package Error: +69 

Total Package Error: The sum of all of the individual package errors. 

36 
 

 

 

 

 

 

Maximum Allowable Variation (MAV): The maximum amount the actual net weight of an 

individual package or container may be under its labeled weight. It represents the maximum 

underweight or short weight a package can be and still be considered “reasonable” under good 

manufacturing processes. The MAV is provided in NIST Handbook 133 Table 2-9. 

Table 2-9. U.S. Department of Agriculture, Meat and Poultry Groups and Lower Limits for

Individual Packages (Maximum Allowable Variations) 

Definition of Group and Labeled Quantity Lower Limit for Individual 

Weights 

(MAVs) 

Homogenous Fluid When 

Filled 

(e.g., baby food or 

containers of lard) 

All Other Products 

Less than 85 g or 3 oz 10% of labeled quantity 

85 g or more to 453 g 

3 oz or more to 16 oz 

7.1 g 

0.016 lb (0.25 oz) 

More than 453 g 

More than 16 oz 

85 g or more to 198 g 

3 oz to 7 oz 

14.2 g 

0.031 lb (0.5 oz) 

More than 198 g to 1.36 kg 

7 oz to 48 oz 

28.3 g 

0.062 lb (1 oz) 

More than 1.36 kg to 4.53 kg 

More than 48 oz to 160 oz 

42.5 g 

0.094 lb (1.5 oz) 

More than 4.53 kg 

More than 160 oz 

1 % of labeled quantity 

7. Apply the decision criteria to determine net weight compliance. 

Decision criteria: The rules for determining whether the inspection lot complies with the net 

weight requirements. The net weight test results must meet BOTH criteria. 

• The total package error (sum of the individual package errors) is equal to or greater than 

zero; 

AND 

• No individual minus package error can exceed the MAV. 

8. Take appropriate action based on net weight testing results. 

9 CFR 442.5 specifies that a lot tested in an official establishment and found not to comply with 

net weight requirements may be reprocessed and must be reweighed and remarked. A lot 

tested outside an official establishment must be reweighed and remarked with a proper weight 

statement. 

37 
Attachment 1: 

Tare Rounding Examples 

Tare Weights Scale Graduation Average Tare 

Weight 

Rounded Tare 

Value 

0.14 & 0.17 lb. 0.01 lb. 0.155 lb. 0.16 lb. 

5/32 & 8/32 oz 1/32 oz 6.5/32 oz 7/32 oz 

0.20 & 0.25 lb. 0.05 lb. 0.225 lb. 0.25 lb. 

5.06 & 5.15 g 0.01 g 5.105 g 5.11 g 

38 
WEIGHT WORKSHEET 

DATE ESTABLISHMENT NO. SCALE DIVISION I AVERAGE TARE WT. I GROUP NO. MAV (Lo...,er Limit) 

LOT SIZE SAMPLE SIZE PRODUCT AND CONTAINER CODE: LABELED WEIGHT 

STANDARD WEIGHTS (IOor 30umple size) CATCH WEIGHTS (IOor30samplesize) 

UNIT + - UNIT LABEL WEIGHT ACTUAL WEIGHT + - 1 1 

2 2 

3 3 

4 4 

5 5 

6 6 

7 7 

8 8 

9 9 

10 10 

TOTAL + ·s AND -·s 

(IO weights) TOTAL + ·s AND -·s rro weights) 

TOTAL ERROR 

+ ·s AND -·s oo wts.J TOTAL ERROR + ·s AND -·s (IOweights) 

11 11 

12 12 

13 13 

14 14 

15 15 

16 16 

17 17 

18 18 

19 19 

20 20 

21 21 

22 22 

23 23 

24 24 

25 25 

26 26 

27 27 

28 28 

29 29 

30 30 

TOTAL + 'S AND -·s 

(30 weights) TOTAL + ·s AND -·s (30 weights) 

TOTAL ERROR 

+ ·s AND -·s (30wts.J TOTAL ERROR + ·s ANO • 'S (30 weights) 

PASS / FAIL DECISION CRITERIA 

MAV CRITERIA: Is any song le minus H unit greater than the MAV? TOTAL ERROR CRITERIA: Is the total error equal to or greater than zero· 

□ YES . Lot Fails □ NO . Check Total Error □ YES. Lot IS Acceptable □ NO . lot Fails 

FSIS FORM 7240-1 (7191) REPLACES FSIS FORM 7240-1 (3186). WHICH IS OBSOLETE. 

ATTACHMENT 2: 

39 
ate: Random Package Report - Example IY'JA O B Report Number: 

anuary 20, 2010 Sampling Plan: 17 

I ocation (name, address): Product/Brand Identity: Manufacturer: Container Description: 

l &O Market Ground Chuck Meat Dept. - L&O Marker 2S Tray wlsoaker and 

1 1acCorkle Ave. Lot Codes: plastic wrap 

( harleslon, WV 25171 I, 19, 99 

1 Labeled Quantity: 2. Unit of Measure: 3. MA V: (Look up the MA V for each package 5. Inspection Lot Size: 6. Sample Size (n): 

( :nter weight for each with a minus error (-), convert it to dimensionless 23 

r ackage in Column 1 0.001 lb units and enter this value in the Box 4 column 12 

t elow.) below.) 

Initial Tare 8. Number of MA Vs 9. Range of Package 10. Range of Tare 11. Re/Rt: 12. Total No. of Tar e 

~ ample Size: Allowed: Errors (Re): Weights (Rt): (Box 9 + Box 10 = ) Samples: 

2 0 JO I JO 2 

13. Avg. Tare Wt: 13a. □ Tare Correction 14. Nominal Gross \Vt: 

0.020 lb □ Moisture Allowance (Libeloo Wt+ Box 13 - Box 

I i'.J Used Dry Tare □ D Unused Dry Tare 0 ot Applicable 13a=) 

\Vet Tare Label Wt + 0.020 lb 

I Pk!! 1 Pk!! 2 Pk!! 3 Pki!4 Pk!! 5 Pk!! 6 Pk!! 7 Pk!! 8 Pk!! 9 Pk!! 10 

' Gross Wt 1.852 lb 1.223 lb 

I Tare Wt 0.020 lb 0.021 lb 

C Net Wt 1.832 lb 1.202 lb 

C Package Error - 18 - 8 

Money Errors Column 1 Package Errors 4. MAV 

Product Description, Lot Code, Unit Price Labeled et Dimension-

- + Weight - + less 

Units 

1. GroundChuck-1, 19, 99-$1.79perlb 1.85 lb 18 

' . 1.21 lb 7 

1.56 lb 8 

~ 1.98 lb 14 

' $ 0.04 I. 07 lb 23 44 

I . 1.55 lb 16 

1. 02 lb 2 

L $ 0.04 1.44 lb 25 56 

I. 1.33 lb 16 

10. 2.03 lb 20 70 

11. l. 73 lb 14 

12. I. I 6 lb fl 

13. 

14. 

b . 

16. 

I Totals -174 

JS. Total Error: 16. Number of unreasonable 17. Is Box 16 greater than Box 8'? 18. Avg. e1Tor in 19. Avg. error in labeled 

minus (-) errors: (Compare each □ Yes, lot fai Is dimensionless units: units: (Box 18 x Box 2 =) 

- 174 package error with the MA V in 0 No, go to Box 18 (Box 15 + Box 6 =) 

Column 4.) - 14.5 - 0.014 lb 

0 

, 0. Does Box 18 = Zero (0) or Plus 21. Compute 22. Sample Correction Factor: 23. Compute Sample E rror Limit: (Box 2 1 x Box 22 =) 

( )? Sample Standard 

[ J Yes, lot passes, go to Box 25 Deviation: 0.635 4.267 

rn No, go to Box 2 l 6.721 

'4. Disregarding the signs, is Box 18 larger than Box 23'! 25. Disposition of Inspection Lot: 

0 Yes, lot fails, go to Box 25 D No, lot passes, go lo Box 25 D Approved 0 Rejected 

< omments Official's Signature: 

Acknowledgement of Report: 

I 

40 
 

 

Net Weight Workshop 

Table 2-2. Sampling Plans for Category B 

(for Use in USDA-Inspected Meat and Poultry Plants Only) 

1 2 3 4 

Inspection Lot Size Sample Size Initial Tare Sample Size Number of Packages 

Allowed to Exceed the 

MAVs in Table 2-9 

250 or Fewer 10 2 0 

251 or More 30 5 0 

Table 2-9. U. S. Department of Agriculture, Meat and Poultry Groups and Lower Limits for

Individual Packages (Maximum Allowable Variations) 

Definition of Group and Labeled Quantity Lower Limit for Individual Weights 

Homogenous Fluid When (MAVs) 

Filled 

(e.g., baby food or 

containers of lard) 

All Other Products 

Less than 85 g or 3 oz 10% of labeled quantity 

85 g or more to 453 g 

3 oz or more to 16oz 

7.1 g 

0.016 lb (0.25 oz) 

More than 453 g 

More than 16 oz 

85g or more to 198 g 

3 oz to 7 oz 

14.2 g 

0.031 lb (0.5 oz) 

More than 198 g to 1.36 kg 

7 oz to 48 oz 

28.3 g 

0.062 lb (1 oz) 

More than 1.36 kg to 4.53 kg 

More than 48 oz to 160 oz 

42.5 g 

0.094 lb (1.5 oz) 

More than 4.53 kg 

More than 160 oz 

1 % of labeled quantity 

Scenario 1: You are in an establishment producing raw, non-intact beef product producing 

packages of ground chuck. You decide your inspection lot is 237 packages. The unit of 

measure for the certified scale being used is 0.001 lb. 

1. What is your first name? 

2. What is your last name? 

3. What is the sample size of the packages that you should examine? 

a. 30 

b. 10 

c. 2 

d. 5 

4. What is the initial tare sample size? 

a. 30 

b. 10 

c. 2 

d. 5 

41 
 

5. The sample tare weights were 0.020 lb. and 0.021 lb. What is the Average Tare Weight? 

a. 0.022 lb. 

b. 0.21 lb. 

c. 02 lb. 

d. 0.021 lb. 

Scenario 2: You are in an establishment producing 5 lb. packages of raw, frozen chicken 

breasts. There are 243 packages in the inspection lot. The unit of measure for the certified 

scale being used is 0.001 lb. 

Gross weight (lb.) Labeled Net Weight (lb.) Nominal Gross Weight (lb.) Package Error 

5.098 5.000 5.073 25 

5.095 5.000 5.073 22 

5.079 5.000 5.073 6 

4.998 5.000 5.073 -75 

5.088 5.000 5.073 15 

5.083 5.000 5.073 10 

5.071 5.000 5.073 -2 

5.089 5.000 5.073 16 

5.092 5.000 5.073 19 

5.067 5.000 5.073 -6 

6. What is the sample size of the packages that you should examine? 

a. 30 

b. 10 

c. 2 

d. 5 

7. What is the initial tare sample size? 

a. 30 

b. 10 

c. 2 

d. 5 

8. Tare weights sampled 0.072 and 0.073. What is the average tare weight? 

a. 0.73 

b. 0.073 

c. 0.72 

d. 0.072 

9. What was the total package error? 

a. 30 

b. 10 

c. 2 

d. 5 

42 
 

 

 

 

10. Did the lot meet the MAV criteria? 

a. Yes 

b. No 

11. Did the lot pass? 

a. Yes 

b. No 

Scenario 3: You are in an establishment producing 8 oz. (226 g) individually packaged frozen 

beef burritos. Your inspection lot is 1600 packages. The unit of measure for the certified scale 

in use is .1 grams. You weigh two complete sets of the packaging material. One set weighs 2.2 

g and the other set weighs 2.2 g. The scale graduation is 0.1g. You then complete your task, 

converting to dimensionless units. 

Gross Weight (g) Labeled Net Weight (g) Nominal Gorss Weight Package Error 

238.6 226 228.2 104 

234.4 226 228.2 62 

228.8 226 228.2 6 

245 226 228.2 168 

231.1 226 228.2 29 

236.2 226 228.2 80 

224.4 226 228.2 -38 

232.7 226 228.2 45 

238.5 226 228.2 103 

220.4 226 228.2 -78 

241.1 226 228.2 129 

232.5 226 228.2 43 

234.6 226 228.2 64 

232.2 226 228.2 40 

232.6 226 228.2 44 

230.9 226 228.2 27 

236.8 226 228.2 86 

240.5 226 228.2 123 

242.2 226 228.2 140 

233 226 228.2 48 

234.4 226 228.2 62 

200.2 226 228.2 -280 

242.9 226 228.2 147 

238.8 226 228.2 106 

244.2 226 228.2 160 

235.1 226 228.2 69 

198.4 226 228.2 -298 

238.2 226 228.2 100 

230.7 226 228.2 25 

236.3 226 228.2 81 

43 
12. What is the sample size of the packages you should examine? 

a. 30 

b. 10 

c. 2 

d. 5 

13. What was the total package error? 

a. - 1388 

b. + 1388 

c. - 1269 

d. + 1269 

14. Did the lot meet the MAV criteria? 

a. Yes 

b. No 

15. Did the lot pass? 

a. Yes 

b. No 

44 
Weights 

scale graduation 

Step 1: Calculate Average Tare Weight .001 

tare 1 tare 2 

~-·_02_s_~I + l~_-_02_s_~ 

= 

average tare 

0.025 

2 

Calculate 

Step 2: Calculate the MAV 

lower limit 

.062 MAV 

= -62 

.001 

scale graduation Calculate 

Example Using the Calculation Aid 

Access the Calculation Aid as follows: Start Menu > FSIS Applications > Calculation Aid > 

Select Net Weights 

45 
Net Weights 

Step 3: Enter sample weights 

Reset 

sample gross weight sample labeled weight 

~-1_.0_63_~1 1~_1_.0_00_~ 

Calculate 

and Save 

individual package error 

38 

Total Samples Saved: 1 

Step 4: Determine lot pass/fail 

individual package errors 

38 

12 

8 

4 

-3.001 

-2.001 

12 

-3.001 

4 

-1.001 

Net Weights 

MAV 

-62 

Make Determination 

total package error 

68.996 

I Lot passed. 

46 
 

 

 

 

 

 

 

 

 

 

 

 

 

3.5 - Solving for an Unknown Value 

Introduction 

This section gives a simplified explanation of how to solve the basic equations used to 

determine the amount of restricted ingredients permitted in federally inspected product. 

Occasionally, there may be an equation in which you have one unknown value. We will show 

you how to mathematically solve these equations. 

Generic Model 

To algebraically isolate an unknown value to one side of the equation and have all the known 

values or constants on the other, identical functions need to be performed on both sides of the 

equation. 

The following ppm formula will be used to illustrate the generic model. 

ppm (parts per million) = lbs. Restricted Ingredient (RI) × % Pump × 1,000,000 

lbs. Pickle 

If all the values in the equation are known except the pounds of RI, isolate the pounds of RI 

(which is X) on one side of the equation and solve for it. 

X × % Pump ×1,000,000 = ppm 

lbs. Pickle 

Solving for an unknown value is also called solving for X. When you have an unknown value, it 

is assigned a letter, generally X. So, Solving for an Unknown value and solving for X are used 

interchangeably. 

When solving for X, the goal is to isolate it or get it by itself on one side of an equation. 

There are a couple things to note. 

1. In order to cancel a constant or known value from one side the of the equation, you 

perform what is known as an inverse operation. Which means you do the opposite. For 

example, if one side of an equation divides by 3, you would have to multiply by 3 to 

cancel out the division. 

2. Equations are equal on both sides, so the value on one side of the equal sign (=) is the 

same value that is on the other side. So, if you do something to one side of the 

equation, you need to do it to the other side. Continuing with the previous example, if 

we multiply by 3 on one side of the equation, you will also need to multiply by 3 on the 

other side. 

Using our example equation, our unknown value or X is the lbs. of Restricted Ingredients (RI). 

ppm = X x % Pump x 1,000,000 

lbs. Pickle 

Our new equation has X in the place of lbs. of RI. 

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We ultimately need to isolate X, but there are several steps we need to take in order to do that. 

First, we need to dispense with the denominator in the equation or the lbs. of pickle. It is a 

division, so we need to multiply by lbs. of pickle. Remember, what we do to one side of an 

equation, we also must do on the other side. 

(lbs. Pickle x) ppm = X x % Pump x 1,000,000 (x lbs. Pickle) 

lbs. Pickle 

When you multiply and divide by the same value of one side of an equation, they cancel each 

other out. 

(lbs. Pickle x) ppm = X x % Pump x 1,000,000 (x lbs. Pickle) 

lbs. Pickle 

And that gives us a new equation. 

ppm x lbs. Pickle = X x % Pump x 1,000,000 

We still do not have X isolated. In order to do that we now need to divide by (% Pump x 

1,000,000) to cancel out the multiplication. Remembering what you do on one side of an 

equation, you have to do on the other side, so we need to do this on both sides. 

ppm x lbs. Pickle = X x % Pump x 1,000,000 

(% Pump x 1,000,000) (% Pump x 1,000,000) 

Again, when you multiply and divide by the same value on one side of an equation, they cancel 

each other out. 

ppm x lbs. Pickle = X x % Pump x 1,000,000 

(% Pump x 1,000,000) (% Pump x 1,000,000) 

Which gives us another new equation. 

X = ppm x lbs. Pickle 

% Pump x 1,000,000 

Then you plug and play. Otherwise known as solving the equation or solving for X. This same 

procedure is used to isolate X to one side of any equation. 

Example 1 

There is a pickle solution that weighs 1000 lbs. and 1.75 lbs. of nitrite was added to the solution. 

If we plug those numbers into our equation, we find the only value we do not have is the 

maximum % pump. So, we need to solve for maximum % pump or X is maximum % pump 

allowed. 

200 ppm nitrite = 1.75 lbs. x X x 1,000,000 

1000 lbs. 

First, we will need to alleviate the denominator or 1000 lbs. We do this by multiplying by 1000 

lbs. on both sides of the equation because, once again, what we do on one side of an equation, 

we need to do to the other. 

1000lbs. x 200 ppm nitrite = 1.75 lbs. x X x 1,000,000 x 1000 lbs. 

1000 lbs. 

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Again, when you multiply and divide by the same value on one side of an equation, they cancel 

each other out. 

1000lbs. x 200 ppm nitrite = 1.75 lbs. x X x 1,000,000 x 1000 lbs. 

1000 lbs. 

Which gives us a new equation. 

1000 lbs. x 200 ppm nitrite = 1.75 lbs. x X x 1,000,000 

We still do not have X isolated. In order to do that we now need to divide by (1.75 lbs. x 

1,000,000) to cancel out the multiplication. Keeping in mind, what you do on one side of an 

equation, you have to do on the other side, so we need to do this on both sides. 

1000lbs. x 200 ppm nitrite = 1.75 lbs. x X x 1,000,000 

(1.75 lbs. x 1,000,000) (1.75 lbs. x 1,000,000) 

Again, when you multiply and divide by the same value on one side of an equation, they cancel 

each other out. 

1000lbs. x 200 ppm nitrite = 1.75 lbs. x X x 1,000,000 

(1.75 lbs. x 1,000,000) (1.75 lbs. x 1,000,000) 

Which gives us another new equation. 

1000lbs. x 200 ppm nitrite = X 

(1.75 lbs. x 1,000,000) 

Then you solve the equation or Solve for X. 

200 × 1,000 = X 

1.75 × 1,000,000 

200,000 = X 

1,750,000 

0.1142 = X 

Finally, multiply 0.1142 by 100 to convert to a percent and 11.42% is the maximum percent 

pump. 

Example 2 

The establishment has a written procedure that calls for 12% pump and has a pickle solution 

weighing 950 lbs. They use a cure mix that is 6.25% nitrite added to the solution. We need to 

solve for maximum amount of cure mix allowed. 

200 ppm nitrite = X x 0.12 x 1,000,000 

950 lbs. 

First, we need to alleviate the denominator, so we multiply by 950 lbs., keeping in mind, what 

we do on one side of an equation, we need to do on the other side. 

950 lbs. x 200 ppm nitrite = X x 0.12 x 1,000,000 x 950 lbs. 

950 lbs. 

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And again, when you multiply and divide by the same value on one side of an equation, they 

cancel each other out. 

950 lbs. x 200 ppm nitrite = X x 0.12 x 1,000,000 x 950 lbs. 

950 lbs. 

Which gives us a new equation. 

200 ppm nitrite x 950 lbs. = X x 0.12 x 1,000,000 

We still do not have X isolated. In order to do that we now need to divide by (0.12 x 1,000,000) 

to cancel out the multiplication. Remember, what you do on one side of an equation, you have 

to do on the other side, so we need to do this on both sides. 

950 lbs. x 200 ppm nitrite = X x 0.12 x 1,000,000 

(0.12 x 1,000,000) (0.12 x 1,000,000) 

Again, when you multiply and divide by the same value on one side of an equation, they cancel 

each other out. 

950 lbs. x 200 ppm nitrite = X x 0.12 x 1,000,000 

(0.12 x 1,000,000) (0.12 x 1,000,000) 

Which gives us another new equation. 

950 lbs. x 200 ppm nitrite = X 

(0.12 x 1,000,000) 

We now need to simplify the numbers, so we perform the multiplication in the numerator and the 

denominator. 

X = 190,000 

120,000 

Then we divide the numerator by the denominator. 

X = 1.58 lbs. 

We have solved for X, but we are not finished. We found out that 1.58 lbs. of nitrite are allowed, 

but the cure mix is only 6.25% nitrite, so we now need to figure out how much mix can be used. 

We do this by dividing lbs. of nitrite by 6.25% or .0625 (which is 6.25% written as a decimal). 

1.58 lbs. nitrite ÷ 0.0625 = lbs. of cure mix allowed 

OR 

1.58 lbs. nitrite 

6.25 % 

= 25.28 lbs. of cure mix allowed in the pickle solution 

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04 - Sausage Operations 

Objectives 

1. Define terminology used in sausage operations. 

2. Identify four criteria required of a sausage product additive. 

3. Understand how restricted ingredients are classified, their minimum or maximum 

permitted limits, and conditions of use. 

4. Identify the four classes of sausage products and two types of loaf. 

5. Understand the sausage production process. 

6. Understand the significance of emulsion development in cooked sausage products. 

7. Identify the types and characteristics of sausage product casings. 

8. Verify non-food safety consumer protection (NFSCP) by: 

9. Conducting General Product Labeling tasks for all sausage products. 

• Conducting Labeling - Product Standards tasks for sausage products with a standard 

of identity or required product ingredients. 

• Performing accurate calculations to determine amounts of restricted ingredients and 

any meat or poultry components required in sausage products. 

• Understanding FSIS procedures for scheduling NFSCP product samples. 

Sausage is one of the world’s oldest forms of processed food. The word “sausage” is derived 

from the Latin word "salsus," which means to salt or to preserve meat. Along with unique 

customs, skills, and recipes, immigrants from diverse regions brought to America many different 

sausage flavors, textures, and shapes. Certain types of sausages (e.g., wiener from Vienna, 

Austria; frankfurter from Frankfurt, Germany; Genoa salami from Genoa, Italy) are allowed 

under 9 CFR 317.8(b)(1) to use geographic names based on their origin. 

Sausage (9 CFR Part 319, Subparts E, F, G, I, J, L; Part 381, Subpart N, P) is defined as 

a coarse or finely comminuted (i.e., reduced in size by grinding and/or chopping) meat 

food product. Sausage is prepared from one or more kinds of raw or frozen meat, meat and 

meat byproducts, and may contain poultry, poultry byproducts, and/or mechanically separated 

meat or poultry. Sausages may be raw or cooked, contain various amounts of water, are 

typically seasoned with condimental substances, and may be fresh (i.e., uncured) or cured. 

9 CFR 319.140 addresses sausage in general and includes fresh sausage prepared from one or 

more kinds of meat or meat byproducts. Meat (§301.2) is defined as the part of the muscle of 

any cattle, sheep, swine, or goats which is skeletal or which is found in the tongue, diaphragm, 

heart, or esophagus, with or without the accompanying and overlying fat. Meat includes beef 

cheek and head meat, beef heart meat, exclusive of the heart cap (i.e., cardiac muscle trimmed 

from the ventricular wall), and skinned pork jowls. Meat also includes skeletal muscle tissue 

from advanced meat recovery (AMR) systems if specific §318.24 requirements are met. Meat 

does not include muscle found in the lips, snout, or ears. Meat byproduct (§301.2) is any part 

capable of use as human food, other than meat, which has been derived from one or more 

cattle, sheep, swine, or goats. Examples of meat byproducts, also referred to as “variety meat,” 

include livers, stomachs and tripe (i.e., first or second stomach of a cow); pork snouts; whole 

livestock hearts, tongues, lips, weasands, and spleens; ear muscle tissue; partially defatted pork 

fatty tissue (PDPFT); partially defatted beef fatty tissue (PDBFT), and fat. Meat byproducts must 

be declared in the product label ingredients statement by common or usual name. For example, 

if livestock blood is used in a sausage product, 9 CFR 317.8(b)(31) requires the ingredients 

statement to declare the specific kind of blood used (e.g., “swine blood”) in addition to including 

the term “blood” in the product name. 

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Poultry (§381.118) is the deboned white and dark meat, including other edible parts such as 

skin and fat not to exceed natural proportions as defined in 9 CFR 381.168). For cooked 

sausages, poultry meat (§319.180(g)) is deboned chicken and/or turkey meat without skin or 

added fat, while poultry byproduct (§381.2(c)) is any poultry skin, fat, gizzard, heart, or liver. 

Poultry byproducts must be declared in the product label ingredients statement by common or 

usual name. 

Mechanically separated species (MSS) identified in §319.5 refers to the skeletal muscle that 

has been mechanically separated and removed from the bones of livestock carcasses and 

parts, excluding beef. Mechanically separated kind of poultry (MSK or MSKP) is any product 

resulting from the mechanical separation and removal of most of the bone from the attached 

skeletal tissue of poultry carcasses and parts, that may or may not contain skin with attached fat 

(§381.173 - 174). The result of mechanical separation is a finely comminuted product with 

paste-like form and consistency (“batter”). Certain standardized products in 9 CFR Part 319 that 

have a maximum fat content limit may use MSS up to 20% of the meat and poultry product 

portion of the product’s meat block. All of the meat, poultry, and/or meat or poultry byproduct 

components in the product formulation comprise the meat block. 

Additives 

9 CFR 320.1(b)(10) and 9 CFR 381.175(b)(6) requires establishments to maintain sausage 

formula records to help document compliance with meat and poultry regulations. This includes 

the use of ingredients which are commonly referred to as additives. In sausage, an additive is 

any safe ingredient other than the meat or poultry components. An acceptable food additive 

must be: 

1. Safe and suitable. 

2. Not detract from the product or promote deception. 

3. Serve a useful purpose or benefit the consumer. 

4. Lend itself to inspectional and/or analytical control. 

FSIS and FDA share responsibility for ensuring food additive safety while the industry supports 

and controls the use of additives. For example, water and/or ice, one of the most common 

ingredients added to a sausage product formulation, helps control product temperature, aids in 

mixing or blending other additives, facilitates casing stuffing, and improves product texture and 

yield. Water/ice used in food formulas must meet the Environmental Protection Agency’s 

National Primary Drinking Water regulations (40 CFR Part 141) to be considered safe and 

suitable. To prevent economic deception, water is limited in certain standardized products. 

Added water is limited to 3% of the total ingredients (excluding the weight of water or ice 

added to the formulation) in raw fresh (i.e., uncured) or cured meat sausage (9 CFR 319.140), 

uncooked smoked pork sausage (§319.160), and when certain standardized names used on the 

label of raw or cooked products are required to meet a standard of identity prior to cooking (e.g., 

“pork sausage” (§319.141), “beef sausage” (§319.142), “breakfast sausage” (§319.143), “whole 

hog sausage” (§319.144), and “Italian sausage” (§319.145)). For cooked meat sausage 

products subject to 9 CFR 319.140, added water is limited to 10% of the finished product 

weight unless other stated. Hotdogs, franks, etc. subject to 9 CFR 319.180 and cheesefurters 

in §319.181 are limited to no more than a 40% combination of water and fat, provided that the 

fat content does not exceed 30%. Poultry sausages bearing the poultry mark of inspection have 

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no added water limits. If necessary, compliance with added water regulatory limits in cooked 

sausages is verified through FSIS laboratory analysis and with supervisory approval for 

sampling; otherwise, the amount of water added during formulation is monitored and measured 

by meter, weight, or volume, then the water content is determined through formula calculations. 

Seasoning is a general term used to describe ingredients that give food products their unique 

tastes and flavors. Seasonings are considered to be condimental ingredients that must always 

be sublisted in the ingredients statement. Seasoning often make up less than 2% of the total 

product formulation, are usually self-limiting (i.e., adding too much ingredient is not a food safety 

concern but makes the product unpalatable), and may have bacteriostatic properties. 

Seasonings include salt, spices, flavorings, sweeteners, and other ingredients such as lactic 

acid starter cultures, which give many types of sausages their characteristic tangy taste. 

Salt contributes to flavor, solubilizes, and releases muscle fiber proteins, prevents fat separation 

during cooking, binds water to improve product yield, texture, and palatability, suppresses 

bacterial growth, and extends product shelf-life. 1 

Spice, which functions primarily as seasoning rather that nutrition, refers to any aromatic 

vegetable substance in whole, broken, or ground form, other than onions, garlic, and celery, 

where no portion of the volatile or flavoring principle has been removed (§317.2(f)(1)(i)(A) and 

§381.118(c)(1)). As examples, black pepper, nutmeg, dry mustard, and sage could each be 

identified by their common or usual name or referred to collectively in the ingredients statement 

as “spices,” “flavoring,” “flavor,” “natural flavor,” or “natural flavoring.” Paprika, which adds color 

and makes meat look brighter red, may not be permitted in many raw sausage products unless 

an exception has been made in the regulations or FSLPB. When paprika is used in a sausage 

product formulation, it must be listed in the ingredients statement as paprika, “spices and color,” 

“spices and color (includes paprika),” “flavoring and color” or “flavoring and color (includes 

paprika),” or similar language that addresses natural flavoring and color versions of these 

options. When paprika is permitted, the product name may also require a qualifier (e.g., “coated 

with paprika,” “artificially colored,” or “colored with paprika”). Annatto and turmeric are also 

coloring ingredients that have similar requirements as paprika. 

Flavoring, whose primary function is taste rather than nutrition, include essential oils, 

oleoresins, (a mixture of resin and essential or fatty oil), and other flavoring constituents derived 

from a spice, any other edible portion of a plant, meat, seafood, poultry, eggs, dairy products, or 

fermentation products. Flavorings in §317.2(f)(1)(i)(B) and §381.118(c)(2) include powdered 

garlic, powdered onion, celery powder, oleoresin of black pepper, rosemary extract, and spices 

which may be identified in the ingredients statement by their common or usual name or 

collectively as “flavor”, “flavoring”, “flavor”, “natural flavor” or “natural flavoring.” Oleoresin of 

paprika, turmeric extract, and annatto extract may be identified by their common or usual name 

or as “flavoring and color” or “flavoring and color (includes..),” or similar statement addressing 

natural flavoring and color versions of these options. 

NOTE: A frequently asked question is the difference between a spice and a flavoring? A spice is 

a seasoning agent obtained from whole, broken, or ground vegetable substances other than 

onions, garlic, and celery. A flavoring adds taste or flavor and is derived from a spice or other 

edible parts of plants, animals, eggs, dairy products, or fermented products. While all spices 

may be called natural flavoring, not all natural flavoring can be called spices. 

Sweeteners and sugars (e.g., sugar (sucrose), dextrose) are the primary food source for the 

lactic acid- producing bacteria starter cultures that drive the fermentation process and contribute 

53 
 

 

 

 

 

 

 

 

 

 

 

 

to a characteristic tangy flavor in sausage. Malt syrup and sorbitol, which are not as sweet as 

sugar, are restricted in cured meat sausages and not permitted in poultry products. Sweeteners 

add flavor, counteract the harshness of salt, increase water retention, and improve casing 

peelability. 

Restricted Ingredients 

Restricted ingredients are approved for use in sausage products for the purposes indicated, 

within the stated limits, and under other conditions specified in 9 CFR Parts 318, 319, 381, and 

§424.21(c). Restricted ingredients, other than flavorings designated in §381.118(c)(1) and (2), 

must be declared in the ingredient statement by the common or usual name. 

Some sausages have a standard of identity that usually include regulatory limits on restricted 

ingredients, such as ≤35% fat content in Italian sausage or ≤3% water in raw sausage at the 

time of formulation. In such cases, the establishment must have some means of measuring and 

calculating the actual amount of restricted ingredient added to the formulation in order to 

determine if the product meets its standard of identity. Establishments that do not measure the 

amount of restricted ingredient added using their instrumentation (e.g., fat content) must have 

some other supportable method for verifying the product meets the regulatory standards. Failure 

to meet the standard of identity is a noncompliance in addition to the label being false and 

misleading. 

Antioxidants are food additives that prevent oxidative rancidity by inhibiting the development of 

undesirable chemical compounds that contribute to "off" odors and flavors. The most common 

antioxidants used in sausages are BHA (butylated hydroxyanisole), BHT (butylated 

hydroxytoluene), propyl gallate, tocopherol, and tertiary butylhydroquinone (TBHQ). 

Antioxidants in fresh sausage are limited to = 0.01% individually and 0.02% in combination on 

the basis of the actual product fat content at the time of formulation. If permitted, tocopherol is 

limited to 0.03% and may not be used in combination with other antioxidants. The maximum 

level of antioxidant is different for dry sausage, e.g., BHA is limited to 0.006% in combination 

with other antioxidants for use in meat. The amount of antioxidants permitted in sausage 

products is based on the fat content at the time of formulation. 

To ensure the amount of added antioxidants do not exceed regulatory limits, many 

establishments identify a product’s formulation target fat that may be used for antioxidant 

calculations. Since the target fat limit should not exceed any maximum regulatory fat limits 

required by an applicable standard of identity (e.g., Italian sausage, pork sausage, etc.), the 

amount of antioxidants and synergist added to the formulation based on the target fat content 

would be in compliance. Even if the incoming meat ingredients varied in actual fat content, the 

target fat level is likely to be met during product formulation as long as the establishment does 

not exceed the regulatory limit. However, if less fat is used in the actual formula than indicated 

by the target fat content, Inspection Program Personnel (IPP) would need to take steps to verify 

that the actual amount of fat added to the product at the time of formulation did not exceed the 

fat content regulatory limit. 

NOTE: An antioxidant (e.g., BHA, BHT, or TBHQ) can never be added to a product in an 

amount greater than its individual limit, even in combination with other antioxidants. 

Synergists are used to increase antioxidant effectiveness. Most antioxidants used are in a mix 

or compound containing a carrier, two or more individual antioxidants, and possibly a synergist. 

Any meat sausage product that is permitted to contain antioxidants may contain citric acid as a 

54 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

synergist in amounts not to exceed 0.01% based on fat content. Fresh pork sausage products 

may contain no more than 0.02% monoglyceride citrate or monoisopropyl citrate as synergists. 

NOTE: It is not necessary to calculate for each antioxidant that is part of a mixture. Only one 

antioxidant calculation is necessary when the following rules are applied: 

1. If no individual antioxidant or synergist is 50% or more of the total antioxidants in the 

mix, calculate the total of all antioxidants using the .02% limit. 

2. If one individual antioxidant or synergist is 50% or more of the total antioxidants, 

calculate for that individual antioxidant or synergist using the .01% limit. 

Binders and extenders may be used individually or collectively in certain sausages to improve 

product sensory characteristics (e.g., texture, juiciness, flavor), sliceability, and yield. Most 

binders and extenders permitted in sausage are allowed at a maximum level of 3.5% of the 

finished product weight. However, isolated soy protein and sodium caseinate are limited to 2% 

due to a high protein content. Some binders, such as sodium caseinate, nonfat dry milk, soy 

flour, isolated soy protein, and soy protein concentrate, are allergenic. 

NOTE: Only untextured soy products are approved for use sausages. Textured soy products 

are highly processed and not approved for use in sausage products. 

Phosphates, which are not permitted in raw sausage products, increase water retention (i.e., 

water binding capacity) and reduce shrinkage by controlling moisture loss in cooked sausages 

during further processing. Comminuted meat and poultry products may contain 0.5% 

phosphates in the total or final product. 

Antimicrobial agents (e.g., sodium lactate/diacetate or other organic salts) may be added to 

sausage formulations as either flavoring agents or to inhibit microbial growth. When these 

ingredients are added to sausage formulas, the establishment is responsible for identifying in 

the labeling records their intended purpose and IPP would verify this information. 

Cures and curing agents, which will be discussed in more detail in the Cured Meat and Poultry 

Product training module, are added to develop the flavor, color, and extend the shelf life of 

sausages such as semi-dry and dry sausages. Cure agents such as sodium or potassium 

nitrite, and less commonly sodium or potassium nitrate, have bacteriostatic properties that 

inhibit or suppress the growth of Clostridia spp. and other spoilage microorganisms in addition 

to antioxidant effects. The amount of cure permitted in sausage products is based on the meat 

block green weight (i.e., the weight of the meat and/or poultry components prior to processing). 

Cured bacon is not included in the sausage product meat block when calculating curing agent or 

cure accelerator ingredient regulatory limits. 

The nitrites in curing agents combine with the muscle pigment myoglobin, an iron- and oxygenbinding protein, to form the characteristic pink-red color and develop the cured meat sausage 

flavor that cannot be reproduced with other ingredients. Nitrite is actually converted (“reduced”) 

by bacteria in the meat or poultry to form nitric oxide, which reacts with the myoglobin. If nitrate 

is used as source for nitrite, it must first be reduced to nitrite, which is then further reduced to 

nitric oxide. This nitrate reduction process is very difficult to control and slows the development 

of the cured color because the nitrate conversion rate and amount of nitrite formed is dependent 

on environmental factors (e.g., temperature, moisture content, salt content, pH) and the 

numbers of nitrate-reducing bacteria present in the sausage mixture. 

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Curing agents are typically added in very low concentrations to sausage products through a 

cure mix or curing compound that is pre-mixed with other ingredients (e.g., salt, sugar, corn 

syrup solids, monosodium glutamate, etc.). The use of nitrites and nitrates must be carefully 

controlled because these ingredients can be toxic to humans at very high levels. Nitrites and 

mixtures containing them must be kept securely under the care of a responsible establishment 

employee. Containers containing a cure mix (e.g., Prague powder) must indicate the percentage 

of nitrite and/or nitrate in the mixture. Most curing compounds are tinted with FD&C Red #3 dye 

as an identification aid. Such compounds must be labeled to identify the dye, but no reference 

to the coloring is required on a sausage product label because the small amount used would not 

affect product color. 

Many establishments now add naturally occurring sources of sodium nitrate and nitrite (e.g., 

celery powder, beet juice, sea salt) to cooked sausage formulations. Natural sources of nitrite 

and nitrate are not approved as curing agents but are sufficient to develop and maintain the pink 

coloring. FSIS has determined that using natural sources of nitrite along with a natural source 

of ascorbate (e.g., cherry powder, beet juice) is approved for antimicrobial use because this 

combination has been determined to control C. botulinum growth. To control the growth of 

Clostridia spp., establishments should add at least 100 ppm ingoing nitrite from the natural 

source along with at least 250 ppm of ingoing ascorbate from a natural source at safe and 

suitable levels as outlined in §424.21(c) and FSIS Directive 7120.1. Natural sources of 

nitrite/nitrate combined with a natural source of ascorbate are not currently approved for use 

with a cure accelerator. Additional information for natural sources of nitrite can be found by 

reviewing AskFSIS questions “Use of celery powder and other natural sources of nitrite as 

curing agents” and “Appendix B: Stabilization Option 3 for products containing celery powder 

and other natural sources of nitrite.” 

Certain sausage products that are required or expected to be cured (e.g., hot dogs or 

pepperoni) but are formulated with natural sources of nitrite instead of synthetic curing agents 

identified in §424.21(c) must be labeled as "uncured." In addition, the label must contain the 

statement "no nitrates or nitrites added" qualified by the statement "except for those naturally 

occurring in [name of natural source of nitrite such as celery powder]." Unless the pH is 4.6 or 

below or the water activity is .92 or less, these sausage products must also bear “Not 

Preserved— Keep Refrigerated Below 40°F at All Times” in easy to read lettering adjacent to 

and at least one-half the size of the product name. 

Cure accelerators (e.g., sodium ascorbate, sodium erythorbate) increase the effectiveness of 

nitrite, help speed up color development, and stabilize cure color. Cure accelerators may only 

be used in association with approved curing agents. 

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FOOD INGREDIENTS EXERCISE 

Answer the following questions using Module 4 Sausage Operations information in the student 

notebook. 

1. What is your first name? 

2. What is your last name? 

3. What are the four criteria required for an additive to be allowed in a sausage product? 

a. Safe and suitable 

b. Does not detract from the product or promote deception 

c. Cost effective 

d. Serves a useful purpose or benefits the consumer 

e. No regulatory limit 

f. Lends itself to inspectional and/or analytical control 

4. A spice may be listed in a label ingredients statement as spice, flavor, flavoring, or by 

common or usual name, and a flavoring may be listed in an ingredients statement as 

flavor or flavoring, by common and usual name, but cannot be listed as spice. True or 

False? 

a. True 

b. False 

5. When an antioxidant is permitted in a fresh sausage, the percentage allowed is based 

on the weight of the . 

a. meat block 

b. fat content 

c. finished product 

d. entire weight of the ingredients, excluding the weight of water or ice used 

6. Water or ice may be used in the preparation of raw sausage products in an amount not 

to exceed what percentage of the total ingredients? 

a. 1 % 

b. 3 % 

c. 10 % 

d. 15 % 

7. For most cooked sausages, added water may be no more than what percentage of the 

finished product? 

a. 1 % 

b. 3 % 

c. 10 % 

d. 15 % 

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Sausage Classes and Types 

Fresh sausage (§319.141-145) does not contain curing agents unless otherwise permitted 

(e.g., Italian sausage). 9 CFR 317.8(b)(6) does not permit the term “fresh” to be used on a 

sausage product label if it contains any sodium nitrate/nitrite, potassium nitrate/nitrite, or has 

been salted for preservation. Uncooked, smoked pork sausage (§319.160) is also not cured 

and obtains its distinct flavors and aromas from the smoking process. Cooked sausages such 

as frankfurters, franks, hotdogs, weiners, viennas, bologna, knockwurst, and similar products 

(§319.180-182) are cured, semisolid sausages prepared from one or more kinds of comminuted 

meat or poultry. Cooked sausages are permitted to contain phosphates and may gain distinct 

flavors from added nitrite curing agents and aromas if smoked. Cooked sausages are typically 

stuffed into a semi-permeable or impermeable casing or stainless-steel mold, then cooked in 

either a heating unit or hot water bath. 

Semidry and dry sausages (FSLPB) are fermented by lactic acid-producing bacteria or directly 

acidified. Semi-dry (e.g., summer, Genoa) and dry sausages (e.g., salami, pepperoni) may be 

uncooked, cooked, or smoked. All semidry and dry sausages undergo a controlled air drying 

process (“product stabilization”). Sausages with a standard of identity for which nitrate or nitrite 

is permitted may also be prepared without nitrate or nitrite. Such sausage products (§319.2) 

must be labeled with the term ‘‘uncured’’ as part of the product name. 

Many establishments that produce cooked sausages also produce specific loaf (§319, Subpart 

K) and nonspecific loaf (§319, Subpart L), which are addressed in this training module. 

Specific and nonspecific loaf, which are not sausage products, are similarly processed 

comminuted, emulsified, semisolid products made from seasoned and cured raw or cooked 

meat or poultry. 

Sausage Standard of Identity 

Some sausage products are produced under a specified name or standard of identity

identified in 9 CFR Part 319 and the Food Standards Labeling and Policy Book (FSLPB). Be 

aware when working with sausage products that the specific order of the product name is critical 

in determining which standard of identity may be applicable. For example, “uncooked smoked 

pork sausage” follows §319.160, but “uncooked pork smoked sausage” follows §319.140, and 

“uncooked pork sausage” follows §319.141. Additional requirements for sausage product 

labeling are identified in §317.8. 

Fresh pork sausage (§319.141) only contains fresh or frozen pork and no byproducts. Fresh 

pork sausage may contain mechanically separated pork up to 20% of the meat block, no more 

than 50% fat content in the finished product, and 3% or less added water. Antioxidants are 

allowed, but binders and extenders are not permitted. 

The term “country style” may be used for fresh country style pork sausage when labeled in 

accordance with 9 CFR 317.8(b)(2). In addition to following the basic §319.140 requirements for 

fresh pork sausage, sausage labeled “country” or “farm” style are only permitted to contain 

sugar as the sweetening agent and natural spices (i.e., no oleoresins, spice extractives, or 

essential oils). Any sausage product labeled “country” or “farm” style must be prepared in the 

same way and have the same characteristics as in the country or farm. 

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Fresh beef sausage (§319.142) may contain fresh or frozen beef with no byproducts, binders, 

and extenders, no more than 30% fat content in finished product, and up to 3% added water. 

Antioxidants are permitted, but mechanically separated beef is inedible and not allowed. 

Breakfast sausage (§319.143) may contain fresh or frozen meat, fresh or frozen meat and 

meat byproducts, binders, and extenders up to 3.5% (or 2%), up to 50% fat content in finished 

product, and no more than 3% added water. Mechanically separated species up to 20% of the 

meat block and antioxidants are also permitted. 

Whole hog sausage (§319.144, FSLPB) is prepared fresh and/or frozen meat from swine in 

proportions normal to a single carcass (i.e., two hams, two shoulders, one heart, one belly, one 

tongue, two cheeks, etc. per carcass). Mechanically separated pork produced in natural 

proportions from a single hog is allowed. Whole hog sausage may contain added water not to 

exceed 3% of the total ingredients and no more than 50% fat content in the finished product. 

Antioxidants are permitted but binders and extenders are not. 

Italian sausage (§319.145) is fresh, uncured raw sausage that has a standard of identity. Italian 

sausage must contain at least 85% meat or meat and fat, no more than 35% fat in the finished 

product, and no more than 3% added water. Products named “Italian sausage” must be 

prepared from pork, or pork and pork fat. Required ingredients that characterize the flavor of 

Italian sausage includes fennel and/or anise, salt, and dry pepper (e.g., black pepper, red 

pepper, white pepper, etc.). It is permitted to contain paprika under its standard of identity. While 

Italian sausage is classified as a fresh sausage, regulations allow for product name alternatives 

to be used when the product is cooked and/or cured (e.g., raw and cured product would be 

named “cured Italian sausage;’ cooked product would be named “cooked Italian sausage”). 

When beef or veal are used with pork, the pork must make up the majority of the meat block 

and the product name would be changed accordingly (e.g., “Italian sausage with beef”). If beef 

or veal with or without beef fat or veal fat replaced all of the pork and pork fat in the meat block, 

that product name would also change accordingly (e.g., “Beef Italian sausage”) 

Bratwurst, chorizo, and linguica are other fresh sausages identified by standards of identity in 

the FSLPB. When Bratwurst and Linguica are cured the term “cured” is required in the product 

name on the label (i.e., “Cured Bratwurst,” “cured Linguica”). Chorizo sausage may be fresh, 

cured, cooked, dried or semi dry but does not require changes to the product name, i.e., all red 

meat versions may be called “chorizo.” Fresh and/or raw chorizo and linguica are permitted to 

contain paprika as an ingredient per the FSLPB and also §424.23(a)(2). All three of these 

sausages follow basic requirements in §319.140 with additional requirements in the FSLPB. 

NOTE: Although the FSLPB states that wine is credited as added water, FSIS considers that 

less than 2% wine and vinegar added to chorizo as flavoring and does not include either 

ingredient in added water calculations. When wine or vinegar are added at 2% or more of the 

total formula, the characterizing ingredient must be included in the product name (e.g., “chorizo 

with wine” or “chorizo with vinegar”) and the sausage standard would need to be met. 

NOTE: Sausages with vegetables/fruits and sausages with cheese are addressed in the FSLPB 

(“SAUSAGE TYPE PRODUCTS WITH FRUITS AND VEGETABLES” and “SAUSAGE 

CONTAINING CHEESE”). When unexpected characterizing ingredients are used in the 

formula, the product name will need to identify such ingredient (e.g., “Bratwurst with Cheese”) 

and the formula will need to meet the applicable sausage standard, excluding the identified 

characterizing ingredient. 

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Fresh poultry sausage must be labeled to indicate the kind of poultry (e.g., “Turkey Sausage”) 

and meet other regulatory requirements in §319.140, except that added water and fat content 

limits are not applied to fresh poultry sausage. If red meat ingredients are added to poultry 

sausage, the red meat ingredient needs to be included in the product name, e.g., “chicken 

sausage with pork fat added” when the red meat ingredient is 20% or less of the total meat 

block or e.g., “chicken and pork sausage” when the red meat ingredient is more than 20% of the 

total meat block. Products labeled “Italian Turkey Sausage” must have a meat block with only 

the kind of poultry identified in the product name and must also meet the basic regulatory 

requirements in §319.145, excluding the fat and water limitations. 

Cooked and/or smoked sausage products are produced under a standard of identity. 9 CFR 

319.140 includes Polish sausage and cotto salami. These sausages are usually coarsely 

ground, may contain no more than 10% water based on the finished cooked weight, have no 

regulatory limit for fat, may contain binders/extenders up to 3.5% (or 2%) as permitted in 

§424.21(c) and the FSLPB, and may contain MSS. 

Frankfurters, franks, furters, hotdogs, weiners, viennas, bologna, garlic bologna, 

knockwurst, and similar products such as mettwurst and teawurst are identified in §319.180. 

Cheesefurters and similar products are addressed in §319.181. The cooked meat sausages 

listed in §319.180 may contain raw or cooked poultry meat and/or mechanically separated 

poultry without skin, kidneys, and sex glands up to 15% of the total ingredients, excluding water. 

These products are limited to no more than 30% fat and may contain up to 40% fat in 

combination with added water. They may contain binders/extenders up to 3.5% (or 2%) as 

permitted in §424.21(c). Comminuted, semisolid, seasoned, and cured sausages containing raw 

meat byproducts, or raw or cooked poultry products, must be labeled with the phrase ‘‘with 

byproducts’’ or ‘‘with variety meats’’ in the product name. 

Braunschweiger (§319.182(a)) is a type of sausage that may be made from fresh, cured, 

and/or frozen pork, beef, and/or veal, and at least 30% pork, beef, and/or veal liver computed on 

the fresh weight of the liver. It may also include pork and/or beef fat. Binders/extenders and 

MSS are permitted, and the product may be smoked. Water is limited to 10% or less in the 

finished product. When made from a single species, the product name may reflect the species 

(e.g., if only beef, beef fat, and beef liver were used, the name would be “beef 

Braunschweiger”). Liverwurst (§319.182(b)) is a type of sausage made from fresh, cured, 

and/or frozen pork, beef, and/or veal and at least 30% liver from any amenable species (pork, 

beef, veal, sheep, goat) computed on the fresh weight of the liver. It may also include pork 

and/or beef byproducts. Binders/extenders and MSS are permitted but the product cannot be 

smoked. When made from a single species, the product name may reflect the species (e.g., if 

only pork, pork byproducts, and pork liver were used, the name would be “pork liverwurst”). 

Sausage Products Containing Both Livestock and Poultry Ingredients (FSLPB) - The 

labeling of non-standardized cooked sausage products must comply with 9 CFR 319.180. Meat 

food products are those in which more than 50% of the livestock and poultry product portion 

consists of livestock ingredients. Cooked meat and poultry sausage products in which poultry 

ingredients constitute more than 15% of the total ingredients (excluding water) must have 

product names that indicate the species of livestock and kind(s) of poultry ingredients (e.g., 

example, “Beef and Turkey Frankfurter” or “Frankfurter Made From Beef and Turkey”). 

Poultry sausage products contain more than 50% poultry of the livestock and poultry portions. If 

more than 20% of the total poultry and livestock ingredients consists of livestock, the product 

name must indicate the kind(s) of poultry and livestock species ingredients (e.g., “Turkey and 

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Beef Frankfurter,” “Frankfurter Made From Turkey and Beef”). Cooked sausage products that 

contain livestock ingredients at 20% or less of the total poultry and livestock ingredients must 

have product names that are appropriately qualified to indicate the inclusion of livestock 

ingredients (e.g., “Turkey Frankfurter - Pork Added or - With Pork”). The product names of 

cooked sausage products containing no livestock ingredients must designate the kind(s) of 

poultry ingredients (e.g., “Turkey Frankfurter”). Cooked sausage products containing more than 

50% meat ingredients would carry the red meat legend, while those containing more than 50% 

poultry ingredients would carry the poultry legend. 

Specific loaf (§319.260-261 and FSLPB) and nonspecific loaf (§319.280-281 and FSLPB) are 

formulated similar to sausage. These products are made with comminuted meat, meat and meat 

byproducts or poultry components (including MSKP), and nonmeat ingredients such as added 

water, various spices, and flavorings. Binders and extenders are permitted in specific and nonspecific loaf unless otherwise indicated in §424.21(c) or the FSLPB. Specific and nonspecific 

loaf may contain ingredients such as pickles, olives, or pimentos, are stuffed into a casing or 

mold, then cooked. Specific loaf has a standard of identity and must include the meat and 

poultry species in the product name (e.g., corned beef loaf, baked pork and chicken loaf, pork 

olive loaf, etc.). If poultry specific loaf contains more than 20% total livestock ingredients, the 

product name must be descriptively labeled to indicate the presence of the livestock ingredients 

(e.g., “Olive Loaf made with Chicken and Pork”). Nonspecific loaf has no standard of identity 

and may be labeled with either a descriptive name that identifies characterizing components 

and/or ingredients, or a fanciful or coined name with the ingredients statement contiguous to the 

product name. Examples of nonspecific loaf include “Olive Loaf” and “Pickle Loaf.” 

Sausage Preparation 

Meat and poultry used in fresh sausage may be produced within the establishment during deboning operations (e.g., whole hog pork sausage producers) or come from outside suppliers. 

Non-meat ingredients and packaging materials are almost always outsourced. Many processors 

rely on formal agreements with suppliers to ensure consistent product is received, including 

written purchase specifications that include quality aspects, such as the lean-to-fat ration in 

trimmings. For preblended or proprietary mixes, the establishment must provide an explicit 

breakdown of the ingredients and ensure that the ingredients are declared on the fresh sausage 

finished label. 

Establishments are required under §320.1(b)(10) and §381.175(b)(6) to have on file any 

labeling records, product formulas, processing procedures, and additional documentation to 

support that products meet §412.1 labeling requirements. Establishments should weigh and 

identify individual ingredients according to the formula to create a consistent product batch and 

also ensure that the ingredients are accurately represented on the fresh sausage product 

finished label. Labels of spice or seasoning blends typically provide instructions for how much 

mixture to use for a specific amount of meat or poultry (e.g., one package seasoning mix per 

100 lb. of meat). Restricted ingredients, some of which are allergenic, should be stored in 

separate containers for single batch formulas. 

Meat and poultry components used in the formulation of raw and fresh sausages are 

comminuted through chopping, grinding, flaking, or a combination of methods. The 

comminuted meat and poultry is then mixed or blended with additives to achieve a uniform 

distribution of meat particles, fat, spices, flavorings, antioxidants, water, and other ingredients. 

The comminuted mixture may be stuffed into casings or chubs, shaped into skinless links, or 

formed into patties. The finished raw or cooked and/or smoked sausage products are packaged, 

labeled, and typically passed through metal detection before storage and distribution. 

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Establishments must ensure that all ingredients, including those in proprietary mixtures, are 

properly used and accurately declared on the finished product label by common or usual name. 

Cooked Sausage Preparation 

Cooked sausage products, which may or may not be cured, may combine meat and poultry 

components, mechanically separated species, water, and nonmeat ingredients to form a paste 

or emulsion. A mix of raw meat and/or poultry with appropriate water binding characteristics and 

nonmeat ingredients is essential to forming an emulsion. Emulsions may breakdown from too 

much added fat, over chopping of the meat and/or poultry mixture, increased mixture 

temperature, high acid content, low pH, or too rapid heating to a high temperature. 

The emulsified sausage mixture may be stuffed into one of three types of casings. Natural, 

artificial, or collagen casings can be used to hold the semisolid meat and/or poultry sausage 

batter until the proteins can coagulate and harden during cooking to form the sausage. A 

natural casing is an animal casing derived from various sections of viscera. These must be 

inspected for condition and nodules, then thoroughly flushed and rinsed before use. For 

sausages encased in natural casings made from a different species than the encased meat or 

poultry, 9 CFR §317.8(b)(37) requires the casing type be listed on the product label. Fibrous, 

saran, and hydrocellulose artificial casings are strong, easy to handle, permeable to smoke 

and moisture, storable in a dry nonrefrigerated area, and are available in various sizes and 

shapes. Most artificial casings are typically inedible and must be removed prior to consumption. 

However, many establishments now use alginate film, which is applied as a liquid to the formed 

sausage batter. When placed in a calcium bath, the alginate forms a solid structure to produce a 

stable and edible artificial sausage casing. Collagen casings are derived or “regenerated” from 

a natural constituent of hides that has been chemically processed and extruded to form an 

edible protein casing. If the species of meat in the collagen casing is different than the species 

of meat in the sausage, §317.8(b)(38) requires the product label to identify the species used for 

the casing. 

Rework is the re-routing of partially or fully processed product into a new batch or formulation 

with the same or similar ingredients. Product may be reworked due to emulsion residue, product 

breakage (“blow outs”), broken, irregular, or end slices, smoked meats, returns, etc. Rework 

must be wholesome, unadulterated, and not violate a standard of identity, change the order of 

predominance of ingredients, or perceptibly affect normal product characteristics. Rework may 

be used in cooked sausage and meat loaf without limitation, but establishments typically limit 

rework to 10% or less because it has no binding capabilities. Sausage products in edible 

collagen casings may be used in similar finely comminuted products without need for peeling. 

Finished cooked sausage in natural casings made from bungs, middles, beef rounds, bladders, 

or stomachs must be stripped of the casings before use. Also, natural casings of any type that 

break during stuffing operations should not be included in emulsions. The new product may 

have similar but different ingredients, but all ingredients in the rework must be declared in the 

new product’s ingredients statement. For the purpose of calculating restricted ingredients, IPP 

must not include the weight of the rework product since it has already met the requirements for 

restricted amounts at the time of its formulation and is only used as a filler product. 

Stuffed sausage products are typically produced by stuffing the raw sausage emulsion into a 

casing, then pinching or twisting the casing to create a link. Some stuffed sausage products 

may be smoked with non-resinous hardwoods, which has been shown to inhibit bacterial 

growth, enhance flavor, and increase shelf life. Other stuffed sausage products may be 

subjected to a lethality process. Whether stuffed sausage products are fully cooked, fermented, 

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and/or smoked, the establishment must monitor and control time and temperature lethality 

parameters to ensure microorganisms of concern are either eliminated or reduced to acceptable 

levels. Humidity may also need to be controlled, but the heat resistance of pathogens is not 

affected when sausages are cooked in casings because almost all semi-permeable or 

impermeable product casings will prevent or inhibit moisture loss. Following the cooking and/or 

smoking lethality step, the cooling process (i.e., stabilization) begins. Rapidly cooling the 

cooked sausages to an internal temperature of ≤40°F will control the outgrowth of spore-forming 

pathogens that may have survived the lethality process. The chilled cooked sausage product 

may have casings removed in a machine called a peeler. After peeling, the cooked sausage 

product may be sliced and is often packaged in labeled plastic packaging for distribution to 

retail stores, hotels, and restaurants. 

NOTE: Refer to FSIS Appendix A for product lethality guidelines and FSIS Appendix B for 

product stabilization guidelines. 

PHIS Labeling Verification Tasks 

IPP are to verify establishment compliance with non-food safety regulatory requirements and 

ensure that product labels accurately reflect the finished product. A meat or poultry product is 

considered misbranded when its label is false or misleading, or the label is missing a required 

feature, qualifying statement, descriptive designation, or if it contains special statements or 

claims without LPDS approval. IPP should only perform unscheduled non-food safety consumer 

protection verification tasks if conditions or activities observed cause them to suspect that the 

establishment is not meeting non-food safety regulatory requirements. Conversely, if IPP 

identify a food safety concern while conducting a non-food safety consumer protection 

verification task, they should first perform the food safety procedure as an unscheduled 

procedure, taking any enforcement actions necessary, then complete the non-food safety 

verification activity. IPP perform labeling verification tasks as instructed in FSIS Directive 

7000.1, with FSIS Directive 7620.3 and the FSLPB available as additional resources. 

NOTE: Labels with special statements and claims may require sketch approval by LPDS as 

required in 9 CFR 412.1(c)(3). Labels with claims that designate an ingredient as certified 

“organic” under the Agricultural Marketing Service (AMS) National Organic Program, geographic 

landmarks displayed on a product label (e.g., foreign country flag, monument, or map), and 

negative claims that identify the absence of certain ingredients or types of ingredients (e.g., “No 

MSG Added”, “Gluten Free”) are acceptable under generic label approval. 

The General Labeling task is performed in establishments that prepare meat or poultry 

products, including sausages that bear a label. The Labeling-Products Standards task is 

performed for sausage products with a standard of identity (i.e., sausage products required to 

have minimum amounts of meat or edible portion of the animal (e.g., liver), or when specific 

ingredients are required. 

Labeling Compliance 

IPP will schedule and perform the General Labeling and Labeling-Products Standards tasks on 

the dates most appropriate. IPP will gather and assess the necessary information to determine 

that product label approvals are on file and accurately reflect the finished product, all required 

label information and graphics are represented, no declared ingredients are omitted or 

undeclared ingredients added, and the establishment’s labeling procedures are adequate. 

Compliance verification activities include observing establishment product formulations, 

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verifying label accuracy, observing preparation or processing procedures; reviewing 

establishment records; examining product; checking product identification, condition, and 

temperature; or performing a variety of other in-plant measurements, testing, and calculations 

to verify that restricted ingredients in product formulations do not exceed regulatory limits. 

Using the GAD Thought Process, IPP are to consider all relevant factors when determining if a 

product fails to meet a non-food safety regulatory requirement. Activities to be considered 

include reviewing establishment records and labels, lot identification procedures, receiving 

records, production records, and any details that can reasonably be determined based on 

average production parameters. When verifying or ingredient statement compliance, IPP should 

observe product preparation and compare these findings to their review information and the 

approved label. IPP with any questions or concerns should consult their supervisor for 

assistance. 

General Labeling Task 

IPP are to conduct the General Labeling Task to the verify that the establishment is producing 

product in compliance with 9 CFR. This task is performed by comparing the product to the 

relevant regulatory requirements and determining whether: 

1. The finished product label contains all required information. 

2. The ingredients statement is accurate and all ingredients are listed in descending order 

of predominance. 

3. The label ingredients statement declares any allergenic or proteinaceous substances 

used. 

4. The label is used on appropriate product. 

5. A label approval is on file. 

6. The product defect levels are consistent with applicable standards. 

Labeling - Product Standards Task 

IPP are to use the Labeling - Product Standards task to determine whether some sausage 

products with specific standards meet regulatory compliance. IPP perform the Labeling -

Product standards tasks by comparing an appropriate product to its regulatory relevant 

requirements. This will likely include performing calculations to determine the amounts of 

specific ingredients added (e.g., percent fat, percent water, curing agents, etc.). IPP should 

verify that the product selected for Labeling - Product Standards task: 

1. Meets product requirements specified in the applicable standard of identity. 

2. Contains restricted ingredients used only in accordance with regulatory requirements. 

3. Has ingredients accurately declared on the product label in descending order of 

predominance. 

4. Product net weight is accurately reflected on its label. 

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Labeling Noncompliance 

IPP will examine products to determine if product standards, net weight standards, 

ingredient or component regulatory minimum or maximum limits, or product defects meet 

regulatory requirements. There is regulatory noncompliance when a product exceeds any of 

the maximum limits, falls below the minimum requirements, or fails to meet any of the other 

non-food safety regulatory requirements. However, IPP should only examine product when 

assigned the task or if there is reason to believe that product regulatory requirements are 

not met. In addition, IPP are not required to verify all products and there are no designated 

sampling plans or sample sizes used in examining products to assure that non-food safety 

regulatory requirements are met. Instead, IPP will determine whether a product complies 

with regulations based on production lots or process controls rather than on individual units 

of product. 

For example, if one package of product exceeds its net weight, IPP should investigate 

whether issues in the process will cause all packages to exceed the net weight 

requirements rather than issuing the establishment an NR. Similarly, if the product is 

economically adulterated or misbranded, IPP may withhold production (e.g., withhold use of the 

product label) until ingredient suitability and the product’s label accuracy can be determined. 

IPP are to issue the establishment an NR only if they determine the processes are out of 

control, resulting in economically adulterated or misbranded product. If IPP are unable to verify 

finished product formulation and composition without laboratory testing, they should inform 

establishment management when samples are collected for FSIS analysis and the reason 

why in order to give the establishment the option to hold all product represented by the 

sample pending sample results. IPP would issue the establishment an NR only if the 

sample results indicated that the product did not meet regulatory compliance. 

Fresh Sausage Verification Task Examples 

Calculations frequently used to verify compliance for limited and restricted ingredients in fresh 

sausage product formulas include added water, fat content, antioxidants, synergists, binders 

and extenders, mechanically separated species, cure agents, and cure accelerators. 

Calculation Considerations 

The calculation methods taught in this course have been used for years and are supported by 

Directive 7620.3, “Processing Inspectors’ Calculations Handbook.” IPP may use other methods 

as long as it will return the correct answer. For calculations, it is acceptable to round the final 

answer to 2 decimal points. Decimals from 0.1 - 0.4 are rounded down while 0.5 -0.9 are 

rounded up. The one exception to this rounding rule is to always round down limited and 

restricted ingredients to avoid adding too much of that ingredient. 

Added Water Verification Calculations 

Step 1) Using information from the formula, on the left side of the equations below, subtract the 

weight of added water in the batch from the total weight of the batch. This determines the actual 

amount of water used. On the right side, subtract the regulatory maximum percent of water 

allowed – this is the ‘perfect’ amount of water. The right and left side calculations are 

independent calculations, do not try to force or manipulate the values to equal each other since 

that is not the purpose of each side of the calculation. The result on the left tells us the weight 

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of the actual formula without any added water, while the result on the right tells us that the 

‘perfect’ formula would have 97% ingredients left over that are not water. 

lb. batch weight [100% batch weight] 

- lb. added water [- 3% water regulatory limit] 

lb. formula weight [97% batch weight, w/o 3% added water] 

NOTE: In many of these added ingredient calculations, the percentage of ingredients remaining 

in the formula must be determined. In addition to subtracting the weight of the ingredient to be 

verified from the product’s total batch weight, some restricted ingredient verification calculations 

will also subtract the percent regulatory limit of that restricted ingredient from 100% of the total 

batch weight or applicable component. Th resulting value provides the percentage of other 

ingredients remaining in the product formulation, which can then be used as a variable factor in 

calculating regulatory limits for some restricted ingredients. 

Step 2) Divide the formula weight (without added water) by the percent of the ingredients 

remaining in the batch (i.e., 97%). The result is how much the fresh sausage batch would 

‘ideally’ or ‘perfectly’ weigh (i.e., 100% calculated weight) if all other ingredients were the same 

and exactly 3% maximum water was added to the product formulation. 

___ lb. formula wt. ÷ .97 [97% batch weight] = ____ lb. [100% calculated weight w/3% water] 

NOTE: The term “per cent” means for one part out of every hundred, on the basis of a whole 

divided into 100 equal parts. When dividing by a percentage, the percent value is expressed as 

a decimal that represents the number of parts per 100 (e.g., 97% = .97; 93.5% = .935). 

Step 3) To determine the maximum amount of water permitted, subtract the formula weight from 

the calculated weight, which represents the product batch weight with exactly 3% added water. 

___ lb. 100% calculated weight [97% ingredients with exactly 3% added water] 

- lb. formula weight [97% ingredients without added water] 

___ lb. maximum water permitted [3% regulatory limit] 

If the amount of added water documented in Step 1 is greater than the maximum permitted 

water calculated in Step 3, the amount of added water would not be in compliance. 

Antioxidant Verification Calculations 

Antioxidants are permitted for use in some fresh sausage products based on that product’s fat 

content. If known, the establishment’s target fat content should be used to calculate the 

maximum amount of antioxidants allowed in sausage products. This fat target would be such 

that if it was exceeded, the antioxidant regulatory limit would still be met. In other words, the 

establishment could add more fat to the formula with less than the maximum amount of 

antioxidant, but adding less fat to the formula would result in too antioxidant for the amount of 

target fat. If the establishment has not identified a target fat, IPP must calculate the fat content 

based on the meat or poultry ingredients used in the product's formulation. Regardless, 

establishments must have some means to verify they meet or exceed the target, such as a 

measurement derived from a laboratory fat analysis. 

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The following antioxidant example demonstrates how to calculate the fat content based on the 

actual amount of meat or poultry ingredients used or if the establishment has not identified a 

target fat content. 

Step 1) Determine the total amount of fat in the formulation by multiplying the weight of each 

meat and poultry component by its percent fat. 

____ lb. meat/poultry component 

× % fat 

____ lb. added fat 

[may be multiple components] 

[% fat content supported by establishment] 

[total added fat in meat/poultry component] 

Step 2) (optional) If there are multiple meat and poultry components, repeat Step 1 to total the 

amount of added fat in each meat and/or poultry component to determine the total fat content in 

the product formulation. 

lb. Component 1 fat + lb. Component 2 fat + lb. Component 3 ... = lb. total added fat 

Step 3) Add all the percentages of antioxidants (and synergists if necessary) to determine if the 

percent of any one antioxidant is 50% or more of the total combined antioxidants in the mix or 

compound. 

____ % Antioxidant A 

____ % Antioxidant B 

+ % Antioxidant C (if necessary) 

____ % total antioxidants x 0.50 = 50% calculated total of antioxidants 

Next, compare the calculated 50% total antioxidants to the individual amounts of each 

antioxidant and synergist in the product formulation to determine if any of those ingredients is 

equal to or more than 50% of the total. 

Step 4) Determine the antioxidant regulatory limit by multiplying the weight of total fat by the 

percent of antioxidant permitted in the formulation using the following rules from Directive 

7620.3: 

- If no antioxidant or synergist is 50% or more of the total antioxidants, multiply the total fat 

by .02% to solve for the total of all antioxidants permitted in the mix. 

- If one antioxidant or synergist is 50% or more of the total antioxidants, multiply by .01% to 

solve for that individual antioxidant or synergist. 

___ lb. total fat 

x .0001 (or .0002) [.01% if one antiox./syn. ≥50%; .02% if no antiox./syn.≥50% combined]

___ lb. [individual antioxidant/synergist or total antioxidants regulatory limit] 

NOTE: The amount of each antioxidant or synergist in a compound or mix is to be considered 

when determining if one of these ingredients constitutes 50% or more of the total antioxidants 

and synergists. If an individual synergist makes up 50% or more of the total, its regulatory limit 

is determined by multiplying the amount of that synergist by .01%. However, synergists 

determined to be less than 50% of the total antioxidants and synergists are not included in total 

antioxidant calculations. If no antioxidant or synergist is 50% or more of the total, then the 

regulatory limit for total antioxidants is determined by multiplying the total amount of antioxidants 

by .02%. 

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Step 5) Determine the amount of antioxidants permitted in the formula by dividing the weight of 

individual or total antioxidants by the percent of antioxidant or total antioxidants in the 

compound or mix. 

When using the limit of 0.01% in Step 4, solve for individual antioxidant or synergist using the 

50% total antioxidants calculated in Step 3): 

____ lb. antiox./syn. ÷ ____ % individual antiox./syn. = ____ lb. max. antiox./syn. permitted 

NOTE: If Step 4 required the limit of 0.02%, the calculation to solve for total antioxidants is 

lb. total antioxidants ÷ % total antioxidants = lb. max. antioxidant mix permitted. 

To convert pounds of antioxidant mix to ounces: 

____ lb. maximum antioxidant mix × 16 [ounces] = oz. max. antioxidant mix permitted 

Water, Binder, and Extender Verification Calculations 

Step 1) Using information from the raw product formula, on the left side subtract the actual 

amounts of water, binders and extenders from the total batch weight. On the right side, subtract 

the percent regulatory limits of 3% for added water (from §319.140) and 3.5% for binders and 

extenders (§424.21(c). The left side calculation in this example will display the weight of the 

actual batch without any water or binders/extenders. The right side calculation will show what 

the remaining 93.5% ingredients in this example’s ‘ideal’ or ‘perfect’ formula would weigh 

without any added water or binders and extenders. 

-

___ lb. batch weight 

___ lb. added water 

[100% batch weight] 

[- 3% water regulatory limit] 

- lb. binders and extenders [- 3.5% added binder regulatory limit] 

___ lb. formula weight [93.5% batch weight, less water and binder] 

Step 2) Divide the formula weight from the left side calculation by the percent of the ingredients 

remaining in the ‘ideal’ or ‘perfect’ batch (e.g., 93.5%) to determine the 100% calculated weight. 

The 100% calculated weight is the weight the batch would weigh if, all other ingredients 

remaining the same, it contained exactly 3% added water and exactly 3.5% binders and 

extenders. 

___ lb. formula wt. ÷ .935 [93.5%] = ___ lb. [100% calculated wt. with 3% water, 3.5% B&E] 

Step 3) Multiply the 100% calculated weight by the 3% regulatory limit for added to determine 

the maximum amount of added water allowed in the product formula. 

___ lb. 100% calculated weight 

× .03 [3% water regulatory limit] 

lb. maximum added water permitted 

Step 4) Multiply the calculated weight by the 3.5% regulatory limit for binders and extenders to 

determine the maximum amount of binders and extenders permitted in the product formula. 

___ lb. 100% calculated weight 

× .035 [3.5% binders and extenders regulatory limit] 

____ lb. maximum binders and extenders permitted 

68 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Mechanically Separated Species Verification Calculations 

Sausage products may be permitted under 9 CFR Part 319, Subparts E and G, to contain no 

more than 20% mechanically separate species (MSS) in the total meat block. 

Step 1) Use the information from the formula, on the left side subtract the weight of the MSS 

from the total meat block. On the right, subtract the regulatory limit for the percent of MSS 

permitted. The left side calculation shows the weight of the meat block without any MSS. The 

right side displays what the ‘ideal’ or ‘perfect’ formula would weigh with 80% of the meat block 

and no MSS. 

___ lb. batch meat block [100% batch meat block] 

- lb. added MSS [- 20% MSS regulatory limit] 

___ lb. meat components [80% meat block formula, less 20% MSS] 

Step 2) Divide the meat components weight (from the left side calculation) by the percentage of 

meat block remaining from the ‘ideal’ or ‘perfect’ batch (from the right side calculation) to 

determine the 100% calculated meat block weight with exactly 20% MSS. 

____ lb. meat components ÷ .80 [80% MB] = ____ lb. [100% calculated MB w/20% MSS] 

Step 3) Multiply the weight of the 100% calculated meat block by the 20% MSS regulatory limit 

to determine the amount of MSS permitted in the formula without including a qualifying 

statement in the product label’s standard of identity name. 

____ lb. [100% calculated meat block] 

× .20 [20% MSS regulatory limit] 

____ lb. maximum MSS permitted 

Another way to determine the amount of MSS permitted is to subtract the weight of the meat 

components (left side calculation, Step 1) from the 100% calculated meat block (in Step 2). 

____ lb. calculated meat block [100% calculated MB in Step 2] 

- lb. meat components [left side of calculation, Step 1] 

____ lb. maximum MSS permitted 

69 
 

 

 

 

 

 

 

 

 

 

 

 

 

SAUSAGE PATTIES 

BHA, BHT, Citric Acid added to protect 

flavor 

Includes: Pork Hams, 

Shoulders, Loins, and Sides 

PREVIOUSLY HANDLED FROZEN FOR YOUR PROTECTION RE FREEZE OR KEEP REFRIGERATED 

NET WT. 10 OZ. (283g) 

COUNTRY SAUSAGE PATTIES 

INGREDIENTS: Pork, Water, Salt, Dextrose, Flavorings, Sugar, 

Monosodium Glutamate, Sodium Acetate, BHA, BHT, Citric 

Nutrition 

Facts 

Sorvr,g s... 2 p 

a>obd(Slg) 

Sorw,gs• 

Calorin 150 FalCl,l.120 

lNoSfalOg 

CtloMst. olOmg 

Sodlulll olOOnw;i 

COOKING INSTRUCTIONS 

Pantry: Preheat skillet to 350°F. Cook approximately 4 

minutes on each side until center is no longer pink. Cook to 

an internal temperature of 160°F checked by a thermometer. 

Fresh Sausage Verification Calculations: Example 1 - Fresh Country Sausage Patties 

A CSI has the General Labeling task on the schedule today. The establishment is making fresh 

country sausage patties and tray packing them. The CSI observes the label below being applied 

to the film wrapped trays. 

They observe the following sausage patty formula posted near the blenders in the processing 

room. They also observes the pre-weighed ingredients for one batch. The ingredient weights 

and names agree with the posted formula. The labeling record does not indicate a minimum 

target fat level. 

Country Sausage Formula 

Regular pork trimmings (60% fat) 280 lb. 

Pork hams, loins, shoulders, sides (30% fat) 160 lb. 

Water 18 lb. 

Hunts Fresh Sausage Seasoning Mix 10 lb. 

Sugar 2 lb. 

Total batch weight 470 lb. 

In the production office, the CSI finds the same label and formula in the establishment’s label 

file as above. She also finds attached to the formula the following additional information for the 

seasoning mix: 

“Directions: Use one bag seasoning mix for each 470 pound batch of sausage patties.” 

Salt 5 lb. 

Dextrose 2 lb. 

Black pepper 1 lb. 

Sage 12 oz. 

Nutmeg 9 oz. 

MSG 7 oz. 

Sodium Acetate 3 oz. 

Antioxidant Mix 1 oz. 

Total seasoning mix 10 lb. 

70 
 

 

 

 

 

 

 

 

 

 

 

 

The establishment has a Letter of Guarantee from the seasoning mix manufacturer stating that 

an antioxidant mix included in the seasoning mix contains BHA, BHT, and citric acid. It lists the 

following ingredients and percentages: BHA (butylated hydroxyl anisole; antioxidant) = 30%; 

BHT (butylated hydroxytoluene; antioxidant) = 10%; citric acid (synergist) = 10%; and a salt 

carrier = 50%. When used according to directions, the seasoning mix complies with antioxidant 

regulatory requirements. 

The CSI needs to verify the following requirements in this product formula: 

1. Does the added water comply with the added water limit for this type of product? 

2. What is the amount of total fat in the product formulation? 

3. Is the antioxidant in compliance with the regulatory limit in this type of product? 

Added Water Verification Calculations 

Given: Total amount of the ingredients = 470 pounds. 

Step 1) On the left side, using the values from the formula, subtract the percentage of water 

permitted from the formula batch weight. On the right side, subtract the regulatory maximum 

percent of water allowed. The left side calculation determines the weight of the batch without 

any water added. The right side calculation shows what the ‘ideal’ or ‘perfect’ formula weight 

would be for the remaining 97% of the ingredients with no added water. 

470 lb. [100% batch weight] 

- 18 lb. [- 3% water limitation] 

452 lb. [97% formula weight, less added water] 

Step 2) Divide the 97% formula weight without any water (answer from the left side calculation 

in Step 1) by the percent remaining in the ‘perfect’ formula (the answer from the right side 

calculation in Step 1) after the ingredient in question is removed (e.g., 97% with 3% water 

removed). The answer to Step 2 tells us how much the ‘perfect’ batch would weigh if it 

contained exactly 3% added water at the regulatory maximum, i.e., the 100% calculated weight. 

452 lb. ÷ 0.97 = 465.97 lb. [100% calculated weight with 3% water regulatory limit] 

Step 3) Subtract the formula weight less added water (the answer from the left side calculation 

in Step 1) from the 100% calculated weight (with 3% maximum water at the regulatory limit – the 

answer from Step 2). 

465.97 lb. [100% calculated weight] 

- 452.00 lb. [formula weight without any water added] 

13.97 lb. [3% water regulatory limit] 

Added water is not in compliance because the 18 lbs. of water added to the formula exceeds 

13.97 lbs., which is the 3% regulatory limit for added water permitted for the fresh sausage 

patties. The CSI should retain all sausage patties produced from the beginning of the shift and 

any other lots of sausage patties produced using the same formula that are still in the 

establishment. 

71 
 

 

 

 

 

 

 

 

 

 

 

 

 

Fat Content / Antioxidant Verification Calculations 

Review the contents of the antioxidant/synergist mixture and verify the percentage of each 

ingredient. Information attached to the label in the establishment’s labeling file states that BHA = 

30%, BHT = 10%, citric acid = 10%, and salt carrier = 50%. 

NOTE: Antioxidants (e.g., BHA, BHT, and propyl gallate) and synergists (e.g., citric acid) 

limitations in raw sausage are 0.01% individually or 0.02% in combination based on total fat 

content. Tocopherols are limited to 0.03% and may not be used in combination with other 

antioxidants. 

Given: Fat content = 280 lb. regular pork trimmings containing 60% fat and 160 lb. pork hams, 

shoulders, loins, and sides containing 30% fat. 

Step 1) Determine the amount of fat added in the meat portion of the formula. A target fat 

content is not provided. 

280 lb. [pork trimmings] 

× 0.60 [60% fat content] 

168 lb. [total fat] 

160 lb. [pork hams, shoulders, loins, sides] 

× 0.30 [30% fat content] 

48 lb. [total fat] 

Step 2) Determine the total fat content in the product formula. 

168 lb. + 48 lb. = 216 lb. total fat added 

Given: The amount of antioxidant compound in the seasoning mix = 1.0 oz. 

Step 3) Determine the total percentage of antioxidants in the antioxidant compound or mix that 

has the antioxidants, synergist, and a carrier). 

30% BHA 

+ 10% BHT 

40% total antioxidants X 0.50 = 20% [50% of the antioxidant total; BHA = 30%] 

Step 4) If one antioxidant or synergist in the mix is 50% or more of the total antioxidants, 

multiply total added fat by 0.0001 (0.01%) to determine the maximum permitted amount of that 

individual antioxidant or synergist. If no antioxidant or synergist is 50% or more of the total 

antioxidants, multiply total added fat by 0.0002 (0.02%) to determine the total combined amount 

of antioxidants permitted. 

In this example, the antioxidant total is 40% of the compound, and 50% of that total is 20%. The 

BHA at 30% of the antioxidant compound/mix is more than 50% of the total antioxidants, so the 

regulatory limit of 0.01% is used to solve for the amount of the BHA alone. 

216 lb. [total fat added] 

× 0.0001 [0.01% - 30% BHA >50% of total antioxidants] 

0.0216 lb. [maximum BHA antioxidant permitted] 

72 
 

 

Step 5) To determine the maximum amount of antioxidant compound permitted, divide the 

maximum amount of antioxidant permitted by the percentage of that specific antioxidant in the 

mix. Then, convert pounds into ounces since the formula in this example stated the ounces of 

antioxidant mix used. 

0.0216 lb. [BHA permitted] ÷ .30 [30% BHA] = 0.072 lb. maximum antioxidant mix permitted 

Converting to ounces: 

0.072 lb. × 16 [oz. per lb.] = 1.15 oz. maximum antioxidant mix permitted 

The antioxidant compound is in compliance because 1 oz. is used in the product formulation 

and 1.15 oz. is the maximum amount permitted. 

73 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Fresh Sausage Verification Calculations: Example 2 - Breakfast Sausage 

A CSI has the General Labeling task scheduled today. The establishment is making fresh 

breakfast sausage links and packaging them in trays with label below being applied to the trays. 

Ingredients: Pork, mechanically separated pork, water, soy flour, salt, natural flavorings, sugar. Stuffed in 

collagen casings. Contains soy. 

The CSI observes the following breakfast sausage formula posted near the blenders in the 

processing room. 

Breakfast Sausage Formula 

Pork (30% fat) 210 lb. (Fat target = 50%) 

Skinned pork jowls (88% fat) 187 lb. 

Mechanically separated pork (30% fat) 50 lb. 

Water and ice 20 lb. 

Soy flour 15 lb. 

Salt 8 lb. 

Sugar 5 lb. 

Natural Flavorings 5 lb. 

Total batch weight 500 lb. 

NOTE: When verifying total fat content, some establishments identify a “fat target” in the product 

formulation that is more restrictive than the total fat regulatory limit. If the actual amount of total 

fat added to the product batch is calculated to be more than the fat target but does not exceed 

the total added fat regulatory limit, there would be no noncompliance for fat content. 

The CSI wants to verify compliance for: 

1. Water – 3% maximum in the total formula at the time of formulation 

2. Extenders and binders – soy flour is limited to 3.5% of the total formulation 

3. Mechanically separated pork (MSS) – is limited to 20% of the total meat block 

74 
 

 

 

 

 

 

 

 

Water, Binder and Extender Verification Calculations 

Added water is limited to 3% and binders and extenders used in this formula are limited to 3.5% 

of total ingredients. 

Step 1) On the left side, using the values from the formula, subtract the pounds of the water and 

binder that were added from the batch weight. On the right side, subtract the regulatory 

maximum for water (which is 3%) and subtract the regulatory maximum for the binders and 

extenders (which for soy flour is 3.5%). The answer to the left side calculation tells us the 

weight of the formula without and water or binders/extenders added. The answer on the right 

side tells us that the ‘perfect’ formula without any water or binders would have 93.5% 

ingredients left over. 

500 lb. [100% batch weight] 

- 20 lb. [3% added water regulatory limit] 

- 15 lb. [3.5% binder regulatory limit] 

465 lb. [93.5% formula weight, less water and soy flour] 

Step 2) Divide the formula weight without any water or binders and extenders (the answer to the 

left side calculation) by the percentage of the ‘perfect’ batch remaining (i.e., 93.5%) (the answer 

to the right side calculation). The answer to Step 2 tells us how much the ‘perfect’ batch would 

weigh if exactly 3% maximum of water and exactly 3.5% binders and extenders (3.5% for soy 

flour) were added, i.e., the 100% calculated weight. 

465 lb. ÷ 0.935 [93.5%] = 497.32 lb. [100% calculated weight w/3% added water, 3.5% binder] 

Step 3) Multiply the 100% calculated weight (the answer in Step 2) by the maximum water 

regulatory percentage limit to determine the maximum amount permitted. 

497.3 lb. [100% calculated weight] 

× 0.03 [3% water permitted] 

14.9 lb. [water regulatory limit] 

Added water is not in compliance because the maximum amount of water permitted is 14.9 lb. 

but 20 lb. was added. 

Step 4) Multiply the 100% calculated weight by the binder regulatory percentage limit to 

determine the maximum amount permitted. 

497.3 lb. [100% calculated weight] 

× 0.035 [3.5% binder and extenders permitted] 

17.4 lb. [soy flour regulatory limit] 

Soy flour is in compliance because 15 lb. was added and 17.4 lbs. is maximum amount 

permitted. 

Mechanically Separated Pork Verification Calculations 

20% MSS is permitted based on the total meat and meat byproduct portion (meat block) of the 

formula. 

75 
 

 

 

 

 

 

 

 

 

Step 1) Determine the weight of the meat block in the formula. On the left side calculation, 

subtract the amount of MSS (pork) from the total meat block used in the formula, then subtract 

the regulatory maximum percent of MSS permitted from the right side calculation. 

210 lb. Pork 

187 lb. 

50 lb. 

Pork jowls 

MSS (pork) 

447 lb. Total 

447 lb. 

- 50 lb. 

397 lb. 

[100% meat block] 

[MSS (pork)] 

[80% of meat block, without 20% regulatory limit for MSS] 

The left side calculation shows that the meat block weighs 397 pounds without any MSS. The 

right side calculation tells us that the ‘perfect’ meat block without any MSS at all would have 

80% of the meat block left over. 

Step 2) Divide the meat block weight with no MSS by the percentage of the meat block 

remaining (i.e., 80%). The result is a 100% calculated meat block, which is what the ‘perfect’ 

meat block would weigh with exactly 20% MSS. 

397 lb. ÷ 0.80 [80%] = 496.25 lb. [100% calculated meat block weight with 20% MSS added] 

Step 3) Multiply the 100% calculated meat block weight by the regulatory limit for MSS (i.e., 

20%) to determine the maximum amount of MSS permitted in the formula. 

496.25 lb. [100% calculated meat block weight] 

x 0.2 [20% MSS limit] 

99.25 lb. [MSS permitted] 

MSS (pork) is in compliance because 50 lb. is being used in the formula and 99.25 lb. is the 

maximum amount permitted. 

76 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

FRESH SAUSAGE WORKSHOP 

Using the methods outlined in this handout, answer the questions related to the following fresh 

sausage formula and perform the required calculations. If you need help, contact your instructor. 

A CSI is assigned to an establishment that produces several types of pork sausage and Italian 

sausage. The Labeling - Products Standards and General Labeling tasks are on the PHIS task 

calendar for today. They assign the tasks, then proceed to the processing room and observe 

that both processing lines are in operation today. At the end of line one, Italian sausage stuffed 

into natural casings is being tray packed and placed in cardboard shipping containers. The CSI 

verifies that the shipping containers have an inspection legend and handling statement (“keep 

refrigerated”). The label below is being applied to the film wrapped trays. 

Ingredients: Pork, water, corn syrup, green peppers, and less than 2% of the following: salt, spices, paprika, 

dextrose, monosodium glutamate, flavoring, BHA, propyl gallate, citric acid 

The CSI takes one label from the roll of labels and asks the production supervisor to show then 

the formula for the Italian sausage. The supervisor opens a binder at his work bench and shows 

the following formula. 

Italian Sausage Batch Formula 

Pork trimmings (20% fat) 285 lb. (Fat content target = 34%) 

Pork jowls, skinned (85% fat) 

Spice and Seasoning mix* 

155 lb. 

14 lb. 

Water 13 lb. 

Corn syrup 

Green peppers 

10 lb. 

10 lb. 

Salt 6 lb. 

Paprika 4 lb. 

Dehydrated parsley 

Total batch weight 

3 lb. 

500 lb. 

*Spice and Seasoning Mix - 14 lb. 

Fennel = 3 lb. 

MSG = 3 lb. 

Dextrose = 3 lb. 

Cumin = 2 lb. 7.75 oz. 

Black pepper = 2 lb. 7.0 oz. 

Antioxidant mix = 1.25 oz. (20% BHA, 15% propyl gallate, 15% citric acid, 50% salt) 

77 
 

 

alculate 

04B01 - % Meat or Poultry 

(single component product) 

meat/poultry in the formula 

X 100 = 

% meat/poultry in the formula 

batch weight 

Reset 

The CSI writes down the meat block, water, antioxidant mix weights, and fat percentages for the 

meat ingredients from the formula in their field notebook and takes the label to the government 

office. There they review the standard of identity for Italian sausage in §319.145. 

For the Labeling - Product Standards task, the CSI performs the necessary calculations to 

answer the following questions. 

1. What is your first name? 

2. What is your last name? 

3. Do the seasoning ingredients in the product meet the standard of identity for Italian 

sausage? 

a. Yes 

b. No 

4. Does the product contain the required amount of meat or meat and fat combination? 

a. Yes 

b. No 

As part of the General Labeling task, the CSI compared the ingredients statement on the label 

brought from the packaging area to the formula in the binder. The CSI verifies that all 

ingredients were listed by their common and usual name in descending order of predominance 

and the label contained all of the mandatory features and required information. Next, the CSI 

proceeds to the QC office and verifies that the selected label is on file with the establishment 

and the processing procedures and formula are attached. The CSI determines that formula in 

the file is the same formula they observed on the processing floor. The CSI proceeds to the 

spice room, where they observe pre-weighed non-meat ingredients in plastic bags for 2 batches 

of the Italian sausage. The CSI asks establishment personnel to weigh the spice and seasoning 

78 
 

 

 

X 

04B04 - Percentage of Fat in a Formula 

lb batch weight lb fat from ingredients 

X target fat percentage -----X 100 = 

% fat on product 

lb fat in product lb batch weight 

meaVpoultry/byproduct % fat lb fat 

Calculate 

X = 

X = 

X = + 

lb fat from 

ingredients 

Reset 

04B04 - Maximum Antioxidant Mix Allowed 

(raw product e.g., meatballs) 

lb batch weight 

percentage fat in product, e.g. 25% 

lb fat 

antioxidant restricted limit 

maximum lb antioxidant allowed 

= 

Add-up antioxidants 

Example: BHA 25% 

BHT 20% 

+ Propyl gallate 10% 

Total Percent 55% 

When no individual antioxidant or 

synergist is more than half of the 

total antioxidant percentage, use 

.0002 (.02%) as the restricted 

limit. 

lb antioxidant mix allowed 

total antioxidant percent, e.g. 55% 

X 16 = lb antioxidant mix allowed oz antioxidant mix allowed 

Calculate Reset 

mixture, salt, and paprika for one of the batches. The CSI verifies the weights recorded on the 

bags are accurate and agrees with the product formula. The CSI looks at the label on the 

container of antioxidant mix, documents the ingredients and percentages, and returns to the 

government office to perform the calculations necessary to answer the following questions. 

5. What is the fat content of the Italian sausage formula? 

a. 30.8% 

b. 35% 

c. 37.75% 

d. 54.65% 

6. Is the fat content in the Italian sausage in compliance with the standard of identity? 

a. Yes 

b. No 

7. Is the antioxidant mix in compliance with the actual product formulation for Italian 

sausage? 

a. Yes 

b. No 

79 
 

 

 

 

 

 

 

 

 

 

Cooked Sausage Verification Task Examples 

Calculations frequently used to verify compliance for limited and restricted ingredients in cooked 

sausage product formulas includes binders and extenders, phosphates, mechanically separated 

kind of poultry, and fresh liver. 

Projected Finished Weight Verification Calculations 

Projected finished weight (PFW) can be used to verify phosphates, binders and extenders 

compliance in cooked sausage products. The PFW is more accurate than measuring the 

amount of water added to the sausage formulation. 

Step 1) On the left side, using values from the formula, subtract from the raw sausage 

formulation batch weight any rework and the respective weights of added water, binders and 

extenders, and phosphates. On the right side, subtract the percent regulatory limits for the 

water, binders and extenders, and phosphates. 

____ lb. batch weight [100% batch weight] 

- ____ lb. rework [rework] 

- ____ lb. water [- 10% water regulatory limit] 

- ____ lb. binders and extenders [- 3.5% B&E regulatory limit] 

- lb. phosphates [- 0.5% phosphate regulatory limit] 

____ lb. formula weight [86% formula weight] 

Step 2) Divide the formula weight (from the left side in Step 1) by the percent of ingredients 

remaining in the ‘ideal’ or ‘perfect’ formula (from the right side in Step 1) to determine the 

projected finished weight. 

____ lb. formula wt. ÷ .86 [86% formula wt.] = ___ lb. [projected finished weight (PFW)] 

Step 3) Multiply the PFW by the 3.5% (or 2%) regulatory limit for binders and extenders to 

determine the maximum amount of binders and extenders permitted in the batch. 

____ lb. PFW 

× .035 [3.5% (or 2%) binders and extenders regulatory limit] 

____ lb. maximum binders and extenders permitted 

Step 4) Multiply the PFW by the 0.5% regulatory limit for phosphates to determine the maximum 

amount of phosphates permitted in the batch. 

____ lb. PFW 

× .005 [0.5% phosphate regulatory limit] 

____ lb. maximum phosphate permitted 

NOTE: The percent water or fat content in a finished cooked sausage can only be verified for 

noncompliance based on laboratory analysis. 

80 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Mechanically Separated Kind of Poultry (MSKP) Verification Calculations 

If permitted, the meat block of cooked sausage products under §319.180(a) may contain no 

more than 15% mechanically separated kind of poultry of the total ingredients, excluding water, 

without including a qualifying statement on the finished product label. 

Step 1) On the left side, deduct the added water weight and the MSKP from the batch weight. 

On the right side, subtract the 15% regulatory limit from the batch weight. DO NOT ASSIGN OR 

SUBTRACT A PERCENTAGE OF WATER IN THIS CALCULATION! 

____ lb. batch weight [100% batch weight] 

- ____ lb. added water [exclude added water, do not assign a %] 

- lb. MSKP [-15% MSKP regulatory limit] 

____ lb. formula weight [85% formula weight, less water and MSKP] 

Step 2) Divide the formula weight (left side calculation) by the precent of ingredients remaining 

in the formula weight (right side calculation). 

____ lb. formula weight ÷ .85 = ____ lb. 100% calculated weight [w/ 15% MSKP] 

Step 3) Subtract the formula weight without MSKP (left side answer in Step 1) from the 100% 

calculated weight with MSKP (answer in Step 2) to determine the amount of mechanically 

separated chicken permitted in the batch. 

____ lb. 100% calculated weight 

- lb. formula weight 

____ lb. MSKP permitted 

Fresh Liver Verification Calculations 

Cooked liver sausage products produced under §319.182 must contain a minimum of 30% fresh 

liver computed on the weight of the fresh livers. 

Step 1) On the left side, deduct the weight of the fresh livers from the batch weight. On the right 

side, deduct the minimum percentage of liver required by the regulations. 

____ lb. batch weight. [100% batch weight] 

- lb. fresh liver [- 30% fresh liver regulatory minimum] 

- ____ lb. formula weight [70% formula weight, less 30% livers] 

Step 2) Divide the formula weight (left side in Step 1) by the percent of the remaining 

ingredients in the batch (right side in Step 1). 

____ lb. formula weight ÷ .70 = ____ lb. [100% calculated weight w/ 30% minimum fresh livers] 

Step 3) Subtract the formula weight from the formulated weight to determine the minimum 

amount of fresh livers required in this batch. 

____ lb. [100% calculated weight with 30% fresh liver] 

- lb. formula weight without fresh liver 

____ lb. minimum liver required 

81 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

NOTE: There is no calculation aid for liver. 

Cooked Sausage Verification Example 

The establishment has the following bologna formula on file. The Projected Finished Weight 

(PFW), also known as the Calculated Finished Weight (CFW), must be determined in order to 

verify that binders, extenders, and phosphates are in compliance. 

Bolonga Formula 

Beef 250 lb. 

Pork 250 lb. 

Water and ice 

Rework 

70 lb. 

50 lb. 

(Finished Product Target = 10% Water, 30% Fat) 

NFDM (nonfat dry milk) 

Salt 

18 lb. 

5 lb. 

Flavorings 

Sodium phosphates 

Sodium erythorbate 

4 lb. 

2 lb. 10.5 oz. 

4.25 oz. 

Sodium nitrite 1.25 oz. 

Total batch weight 650 lb. 

The amount of nonfat dry milk (NFDM) binder and the amount of sodium phosphate 

documented in the formula must be calculated to determine if they are in compliance. 

Binders and Phosphates Verification Calculations 

NOTE: The PFW (or CFW) or always includes the maximum targeted water. Once the CSI 

determines a product’s PFW, the weight can be used to calculate the maximum amount of 

phosphates, binders and extenders permitted in each formula. REMEMBER TO ALWAYS 

REMOVE REWORK FROM INGREDIENT VERIFICATION CALCULATIONS! 

Step 1) Subtract from the batch weight any rework, the weight and percentage of the targeted 

added water, and restricted ingredient(s) that have regulatory limits based on the PFW. 

650 lb. [batch weight] 

- 50 lb. [rework] 

600 lb. [100% batch weight, less rework] 

600 lb. [100% batch weight] 

- 70 lb. [- 10% water] 

530 lb. [90% batch weight] 

530 lb. [90% batch weight] 

- 18 lb. [- 3.5% NFDM] 

512 lb. [86.5% batch weight] 

512 lb. [86.5% batch weight] 

- 2.65 lb. [- 0.5% phosphate] 

509.35 lb. [86.0% formula weight] 

82 
 

 

 

 

 

 

 

 

 

 

 

Step 2) Divide the formula weight (from the left side calculation) by the percentage of the total 

remaining batch (from the right side calculation) to determine the projected finished weight 

(PFW). 

509.35 lb. ÷ 0.86 [86.0%] = 592.26 lb. PFW [with 10% water, 3.5% NFDM, 0.5% phosphate] 

Step 3) Multiply the PFW by binders and extenders regulatory limit of 3.5% to determine the 

maximum amount of NFDM permitted. 

592.26 lb. [PFW] 

× 0.035 [3.5% binder limit] 

20.72 lb. [NFDM permitted] 

The binders and extenders are in compliance because 18 lb. of NFDM was added and 20.72 lb. 

is permitted. 

Step 4) Multiply the PFW by the phosphates regulatory limit of 0.5% to determine the maximum 

amount of sodium phosphate permitted. 

592.26 lb. [PFW] 

× 0.005 [0.5% phosphate limit] 

2.96 lb. [sodium phosphate permitted] 

Sodium phosphate is in compliance because the 2.65 lb. used is less than the maximum 

permitted amount of 2.96 lb. 

Cooked Sausage Example - Mechanically Separated Kind of Poultry 

An establishment processes a cooked meat and poultry sausage product that is labeled as 

“Frank’s Furters.” A CSI assigned a Labeling - Product Standards Task has reviewed the 

product formulation on file. The CSI observed that the batch weight is 800 lb., which includes 

115 lb. of added water and 90 lb. of mechanically separated chicken. The CSI obtained a 

product label and observed that poultry is declared on the label as an ingredient in the correct 

order of predominance. The CSI wants to verify that the amount of MSKP in the product 

formulation is in compliance with product labeled as “Frank’s Furters.” 

9 CFR 319.180(a) states that cooked poultry meat and/or mechanically separated kind of 

poultry in product labeled as furter is permitted if it does not exceed 15% of the total ingredients, 

excluding water. The FSLPB states for non-standardized cooked sausage products containing 

both livestock and poultry ingredients that cooked sausage product containing more than 15% 

poultry in the total ingredients (excluding water) must indicate in the product name the species 

of livestock and kind(s) of poultry ingredients (e.g., “Beef and Turkey Furter,” “Furter Made from 

Beef and Turkey”). 

The CSI uses the following calculations to verify compliance with the amount of mechanically 

separated chicken in a cooked furter product formulation that does not include a qualifying 

statement on the label. 

Step 1) Exclude the added water and subtract the MSKP from the batch weight to determine the 

formula weight. 

83 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

800 lb. [100% batch weight] 

- 115 lb. [- exclude water - DO NOT SUBTRACT A PERCENTAGE] 

- 90 lb. [- 15% MSKP regulatory limit] 

595 lb. [85% formula weight] 

Step 2) Divide the formula weight (in Step 1) by the percent of the batch weight remaining (in 

Step 1). 

595 lb. ÷ .85 = 700 lb. [100% calculated weight, with 15% MSKP regulatory limit] 

Step 3) Subtract the formula weight (in Step 1) from the 100% calculated weight to determine 

the amount of MSKP permitted without a qualifying statement included on the product label. 

700 lb. [100% formulated weight] 

- 595 lb. [85% formula weight] 

105 lb. [MSKP permitted] 

The “Frank’s Furters” label is in compliance because 105 lb. of MSKP is the 15% regulatory limit 

permitted without including a qualifying statement and 90 lb. is added. 

Liver Sausage Verification Example (§319.182) 

After reviewing the following liver sausage product formula, the CSI wants to determine if the 

amount of fresh liver in the product formulation meets the 30% minimum regulatory limit. 

Braunschweiger Formula 

Skinless pork jowls 250 b. 

Pork livers 100 lb. 

Water 17 lb. 

Salt 8 lb. 

Corn syrup 4 lb. 

Sodium lactate 3 lb. 

Dried onions 3 lb. 

Sodium diacetate 2 lb. 

Dextrose 1 lb. 7.6 oz. 

Flavorings 1 lb. 7.6 oz. 

Sodium nitrite 0.80 oz. 

Total batch weight 390 lb. 

Step 1) Using values from the formula, on the left side subtract the liver weight from the batch 

weight. On the right side, subtract the minimum percentage of liver required. 

390 lb. batch [100% batch weight] 

- 100 lb. liver [- 30% minimum liver required] 

290 lb. formula weight [70% formula weight, less fresh liver] 

Step 2) Divide the formula weight (left side in Step 1) by the percent of the batch weight 

remaining (right side in Step 1). 

290 lb. ÷ 0.70 [70%] = 414.28 lb. [100% calculated wt. w/30% minimum liver regulatory limit] 

84 
 

 

 

 

 

Step 3) Subtract the formula weight (left side in Step 1) from the 100% calculated weight (in 

Step 2). 

414.28 lb. [100% calculated weight] 

- 290 lb. [70% formula weight without fresh liver] 

124.28 lb. [minimum fresh liver regulatory limit] 

This Braunschweiger formula is not in compliance because a minimum of 124.28 lb. of fresh 

liver is required to meet the product standard of identify but only 100 lb. was added in the 

formula. 

NOTE: Be aware that simply adding additional liver to this formula may not be adequate to 

ensure compliance with other ingredients. Additional ingredient calculations may be necessary. 

85 
 

 

 

 

PORK LIVERS, PORK FAT, PORK, BACON (CURED WITH 

WATER, SALT, SUGAR, SODIUM PHOSPHATES, SODIUM ASCORBATE, 

SODIUM NITRITE), WATER, NONFAT DRY MILK, CORN SYRUP, 

CONTAINS 2% OR LESS SALT, FLAVORINGS, DEXTROSE, DEH'tO 

ONION, SODIUM LACTATE, POTASSIU LJ\CTATE, SODIUM D 

SODUIM ASCORBATE, SUGAR, SODIU Nl1'RITE, SODIUM PH 

COOKED SAUSAGE WORKSHOP 

Using the methods outlined in this handout, answer the questions related to the following 

cooked sausage formulas and perform the required calculations. If you need help, contact your 

instructor. 

Example 1 

A CSI is assigned to an establishment that produces several types of cooked and smoked 

sausages, cooked sausages, and non-specific loaf. The General Labeling and Labeling -

Products Standards tasks are on the PHIS task calendar for today. They assign the tasks, then 

proceed to the processing room. 

The establishment is stuffing Braunschweiger sausage into impervious saran casings (sticks) 

and cooking them in water. The CSI observes notice staged, properly identified, pre-weighed 

ingredients for a batch of the Braunschweiger sausage in plastic totes and brown bags on a 

rack next to the large blender. They have the production supervisor weigh the sodium nitrite, 

sodium ascorbate, and nonfat dry milk (NFDM), then record the weights in their field notebook. 

The CSI proceeds to the grinding area and observes the meat components staged in stainless 

steel totes for a batch of the Braunschweiger sausage. They have the production supervisor 

weigh the pork livers, then record the weight of the livers in their notebook. 

The CSI enters the ready-to-eat product packaging room and observes that the establishment is 

slicing the Braunschweiger sticks into 1 lb. portions and shrink wrapping the portions in plastic 

film that has the labeling printed on it. They take a piece of plastic film with the following labeling 

on it from the end of the packaging line. 

86 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The CSI proceeds to the production office and asks the production supervisor to show them the 

formula for the Braunschweiger sausage being produced today. The supervisor shows the 

following formula. 

Braunschweiger Formula 

Pork livers 150 lb. 

Pork fat 150 lb. 

Skinned pork jowls 75 lb. 

Bacon (cured) 53 lb. 

Rework 25 lb. 

Water 20 lb. 

Nonfat dry milk (NFDM) 16 lb. 

Corn syrup 11 lb. 

Salt 7 lb. 14 oz. 

Flavorings* 6 lb. 

Potassium lactate 3 lb. 

Sodium lactate 2 lb. 

Dehydrated onion 2 lb. 

Dextrose 1 lb. 12 oz. 

Sodium diacetate 1 lb. 

Sugar 14 oz. 

Sodium ascorbate 4 oz. 

Sodium nitrite 2 oz. 

Sodium phosphate 2 oz. 

Total Batch 525 lb. batch weight 

*Flavorings (6 lb.) 

White pepper = 2 lb. 

Marjoram = 2 lb. 

Mace = 1 lb. 12 oz. 

Ground cloves = 4 oz. 

The CSI reviews the labeling on the plastic film wrap and verifies that all mandatory labeling 

features and required information are on it. They compare the sodium nitrite, sodium ascorbate, 

and liver weights documented in their notebook with the weights in the formula. They determine 

the ingredient weights recorded in their notebook are the same as the ingredient weights in the 

formula. The CSI compares the ingredients statement on the plastic film wrap with the product 

formula to answer the following questions. 

1. What is your first name? 

2. What is your last name? 

3. Identify the meat byproduct(s) used in the formula. 

a. Pork livers 

b. Pork fat 

c. Skinned pork jowls 

d. Bacon 

87 
 

 

- Percent Binder/Extender 

lb of binder used 

X 100 = 

lbPFW 

percent binder in the finished product 

Calculate Reset 

4. Is the ingredients statement in compliance with the standard of identity for 

Braunschweiger? 

a. Yes 

b. No 

The CSI proceeds to the government office to perform the calculations necessary to answer the 

following Labeling - Product Standards task questions. 

5. Does the Braunschweiger formula contain the required amount of fresh liver? 

a. Yes 

b. No 

The CSI continues performing the calculations necessary to answer the following General 

Labeling task questions. 

NOTE: For the following calculation only, determine binder and extender compliance by 

using the formula batch weight, less rework, instead of calculating the PFW. Since this product 

is cooked in an impervious casing, less than 10% added water would normally be included 

because there would be no cook shrink expected. If the 10% added water regulatory limit was 

used in determining the PFW for this product, the calculated PFW would actually be greater 

than the batch weight. 

6. Is the amount of nonfat dry milk (NFDM) added to the formulation in compliance? 

a. Yes 

b. No 

88 
 

 

Quality 

Franks 

KEEP REFRIGERATED 

INGREDIENTS: Beef, Pork, Water, Mechanically Separated Chicken, 

Soy Flour, Salt, Contains 2% or Less Corn Syrup, Dextrose, 

Potassium Lactate, Flavorings, Sodium Phosphates, 

Sodium Diacetate, Paprika, Ascorbic Acid (Vitamin C), 

Sodium Nitrite Contains Soy 

Nutritional Am~!Jnl ~~~ilJB; ~'2~* 

Facts Total Fat 11 17% 

Serv. Size 1 Frank Sat. Fat 4g 21% 

Servings 8 Trans Fat Og 

Calories 120 Cholest. 15mg 8% 

Fat Cal. 100 Sodium 480mG 20% 

• Percent Daily Values (DV) are Vitamin A 0% • Vitamin C O.S% • 

Based on a 2,CXXJ calorie diet 

ABC PACKING, P.O. BOX 0000 

ANYWHERE, USA 00000 

tlcurncl ~~~ic11: ~DV* 

Total Carb. 2 1% 

Fiber 1 3% 

Sugars Og 

Protein Sg 

Calcium 0% • Iron 2% 

NETWT. 

1602. 

(1 LB.) 

7. Is the product name “Braunschweiger” in compliance with the standard of identity for a 

liver sausage based on the ingredients used in the formula? 

a. Yes 

b. No 

Example 2 

A CSI is assigned to an establishment that produces several types of cooked and smoked 

sausages, cooked sausages, and non-specific loaf. They assign the General Labeling task on 

the PHIS task calendar for today. The CSI begins start the task by proceeding to the packaging 

room. The establishment is packaging 8 per lb. franks in pre-labeled plastic film in the ready-toeat (RTE) product packaging room. 

The CSI collects from the end the packaging line a discarded film with the pre-printed label 

shown below. 

The CSI proceeds to the production office and verifies label on the plastic film is on file and the 

processing procedures and formula are attached to it. They record the ingredients and weights 

from the formula in their field notebook, then proceed to the production room. 

The establishment has a continuous system for producing small diameter cooked sausages. 

The raw sausages in casings are on loaded on metal trees, moved to a cooking and chilling 

tunnel for processing, and the finished sausage are taken to the RTE product packaging room. 

89 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The CSI observes the staged, properly identified, pre-weighed ingredients for a batch of franks 

in plastic totes and brown bags on a rack next to the large blender. They have the production 

supervisor weigh the sodium nitrite, ascorbic acid, and soy flour. They then compare the 

weights to the weights from the formula recorded in their field notebook and verify the weights 

are the same. The CSI proceeds to the grinding area and observes the meat and poultry 

components are staged in stainless steel totes for a batch of frankfurters. They have the 

production supervisor weigh the mechanically separated chicken and compare the weight on 

the scale to the weight of the mechanically separated chicken in their notebook. They verify the 

weights are the same. 

The CSI asks the sausage foreman to show the formula for the frank. He opens a binder at his 

work bench and shows the CSI the following formula. 

Quality Franks Formula 

Beef (boneless cow meat) 250 lb. 

Pork trimmings 

MS chicken 

200 lb. 

100 lb. 

(Finished Product Target = 30% fat) 

Water and ice 

Frank rework (like product) 

Soy flour 

120 lb. 

50 lb. 

22 lb. 

(Finished Product Target = 10% water) 

Salt 15 lb. 

Corn syrup 11 lb. 12 oz. 

Dextrose 8 lb. 

Potassium lactate 7 lb. 

Flavorings 

Sodium diacetate 

7 lb. 

4 lb. 

Sodium phosphates 3 lb. 

Curing mix 

Paprika 

1 lb. 6 oz. (6.25% nitrite salt carrier) 

10 oz. 

Ascorbic acid 4 oz. 

Total Batch Weight 800 lb. 

The CSI compares the weights recorded in their field notebook with the weights in the above 

formula and verified the ingredients and weights used in production are the same as the 

ingredients and weights in the formula on file. The CSI then compares the ingredients statement 

on the frank label being applied to product to the frank formula on file. The CSI verifies that the 

ingredients were listed by their common and usual name in descending order of predominance. 

They also verified that the mandatory features and required information were on the label. 

The CSI proceeds to the government office and performs the calculations necessary to answer 

the following questions. 

8. Is the amount of binder added in compliance? 

a. Yes 

b. No 

90 
Calculate 

04B04 - Projected Finished Weight (PFW) 

lb batch weight 

lb rework 

lb 

lb water 

lb 

lb binder(s) 

lb 

lb phosphate(s) 

lb 

= 

100% 

-10% 

90% 

3.5% 

86.5% 

-0.5% 

86% 

lbPFW 

% of formula remaining 

04804 • Maximum Amount of Poultry 

lb batch weight 

lb water and ice 

mlnlmum lb (85'l4) 

minimum lb (85%) 

= lb 

0.85 

lb 

minimum lb (85%) 

maxim um amount of poullry 

Cakulate 

Reset 

100% 

- 85% 

15% 

Reset 

9. Is the amount of sodium phosphate added in compliance? 

a. Yes 

b. No 

10. Is the amount of mechanically separated chicken in compliance? 

a. Yes 

b. No 

91 
 

 

 

9 CFR 424.21(c) Excerpt 

Antioxidants and 

oxygen 

interceptors 

Ascorbyl palmitate To retard rancidity Margarine or 

oleomargarine 

0.02 percent (by wt. of 

finished product) 

individually or in 

combination with other 

antioxidants approved for 

use in margarine. 

......do Dry sausage 0.003 based on total 

weight 

0.006 percent in 

combination with other 

antioxidants for use in 

meat. 

......do Fresh pork, sausage, 

brown and serve 

sausages, fresh Italian 

sausage products, 

pregrilled beef patties, 

fresh sausage made 

from beef or beef and 

pork, cooked or raw 

pizza topping and 

cooked or raw 

meatballs 

0.01 percent based on 

fat content 

0.02 percent in 

combination with other 

antioxidants for use in 

meat, based on fat 

content. 

......do Various poultry 

products 

0.01 percent based on 

fat content (0.02 percent 

in combination with any 

other antioxidant for use 

in poultry) based on fat 

content. 

BHT (butylated 

hydroxytoluene) 

......do Dry sausage 0.003 percent based on 

total weight 0.006 

percent in combination 

with other antioxidants 

for use in meat. 

......do Fresh pork, sausage, 

brown and serve 

sausages, fresh Italian 

sausage products, 

pregrilled beef patties, 

fresh sausage made 

from beef or beef and 

pork, cooked or raw 

pizza topping and 

cooked or raw 

meatballs 

0.01 percent based on 

fat content 

0.02 percent in 

combination with other 

antioxidants for use in 

meat, based on fat 

content. 

......do Various poultry 

products 

0.01 percent based on 

fat content (0.02 percent 

in combination with any 

other antioxidant for use 

in poultry) based on fat 

content. 

Propyl gallate ......do Dry sausage 0.003 percent based on 

total weight 0.006 

92 
 

 

 

 

 

 

percent in combination 

with other antioxidants 

for use in meat. 

......do Fresh pork, sausage, 

brown and serve 

sausages, fresh Italian 

sausage products, 

pregrilled beef patties, 

fresh sausage made 

from beef or beef and 

pork, cooked or raw 

pizza topping and 

cooked or raw 

meatballs 

0.01 percent based on 

fat content 

0.02 percent in 

combination with other 

antioxidants for use in 

meat, based on fat 

content. 

Tocopherols ......do Dry sausage, semidry 

sausage, dried meats, 

uncooked or cooked 

fresh sausage made 

with beef and/or pork, 

uncooked or cooked 

Italian sausage 

products, uncooked or 

cooked meatballs, 

uncooked or cooked 

meat pizza toppings, 

brown and serve 

sausages, pregrilled 

beef patties, and 

restructured meats 

Not to exceed 0.03 

percent based on fat 

content. Not used in 

combination with other 

antioxidants. 

Binders and A mixture of sodium To bind poultry pieces Ground and formed raw Sodium alginate not 

Extenders alginate, calcium 

carbonate, lactic 

acid, and calcium 

lactate 

or cooked poultry pieces more than 0.8 percent, 

calcium carbonate not 

more than 0.15 percent; 

lactic acid and calcium 

lactate, in combination, 

not more than 0.6 

percent of product 

formulation. Added 

mixture may not exceed 

1.55 percent of product 

at formulation. The 

mixture must be added in 

dry form. 

Bread To bind and extend 

product 

Bockwurst 3.5 percent individually 

or collectively with other 

binders for use in meat. 

Cereal To bind and extend 

product 

Sausages as provided 

in 9 CFR Part 319, 

bockwurst 

3.5 percent individually 

or collectively with other 

binders for use in meat. 

Dried milk ......do Sausages as provided 

for in 9 CFR Part 319 

3.5 percent individually 

or collectively with other 

binders for use in meat 

93 
 

 

 

 

 

Dried skim milk, 

calcium reduced 

......do Sausages as provided 

in 9 CFR 9 CFR Part 

319 

Do. 

Enzyme (rennet) 

treated with calcium 

reduced dried skim 

milk and calcium 

lactate 

......do Sausages as provided 

for in 9 CFR Part 319 

3.5 percent total finished 

product (calcium lactate 

required at rate of 10 

percent of binder.) 

......do Imitation sausages; 

nonspecific loaves; 

soups, stews (meat 

only) and various 

poultry products 

Sufficient for purpose in 

accordance with 21 CFR 

172.5 (calcium lactate 

required at a rate of 10 

percent of binder). 

Enzyme (rennet) 

treated with sodium 

caseinate and 

calcium lactate 

......do Imitation sausages; 

nonspecific loaves; 

soups, stews (meat 

only) and various 

poultry products 

Sufficient for purpose in 

accordance with 21 CFR 

172.5 (calcium lactate 

required at a rate of 25 

percent of binder). 

Isolated soy protein ......do Sausage as provided for 

in 9 CFR Part 319, 

bockwurst 

2 percent. 

......do Imitation sausages; 

nonspecific loaves; 

soups; stews (meat 

only) and various 

poultry products 

Sufficient for purpose in 

accordance with 21 CFR 

172.5. 

Sodium caseinate To bind and extend 

product 

Imitation sausages, 

nonspecific loaves, 

soups, stews (meat 

only) 

Sufficient for purpose in 

accordance with 21 CFR 

182.1748 and 21 CFR 

172.5. 

......do Sausages as provided 

for in 9 CFR Part 319 

2 percent in accordance 

with 21 CFR 182.1748. 

Soy flour ......do Sausages as provided 

for in 9 CFR Part 319, 

bockwurst 

3.5 percent individually 

or collectively with other 

binders and extenders 

for use in meat. 

Soy protein 

concentrate 

......do Sausage as provided for 

in 9 CFR Part 319, 

bockwurst 

3.5 percent individually 

or collectively with other 

binders and extenders 

for use in meat. 

94 
 

 

 

 

 

 

 

 

 

 

05 - Cured Meat and Poultry Product Operations 

Objectives

1. Describe how to perform the % Yield/Shrink task. 

2. Describe how to perform the General Labeling task. 

3. Calculate the maximum amount of curing agent, curing accelerator, and phosphate 

allowed, when given a formula, and determine if these restricted ingredients are in 

compliance. 

4. Calculate the volume of a tank, when given the dimensions of a tank. 

5. Compute parts per million of restricted ingredients in cured meat products at the time of 

pumping to determine compliance. 

6. Calculate parts per million allowed for each restricted ingredient approved for use in 

bacon products. 

7. Calculate the yield of cured pork bellies when given finished weight and green weight 

numbers. 

8. Calculate the percent shrink for dry cured pork products. 

Curing Methods

There are three general methods of curing, with a number of variations for each method. These 

methods are pickle curing, dry curing, and dry salt curing. 

Dry curing is the application of salt alone; salt, nitrate, and/or nitrite; or salt, nitrate, and/or 

nitrite with sugar directly to the surface of the meat. Meat subjected to this curing method cannot 

be injected with, or immersed in, a cure solution. 

Dry salt curing is modification of the dry curing method, which includes the same mixtures in 

dry curing, except that product may be injected with cure solution directly into the muscle tissue 

(not through the circulatory system). Just prior to being covered with the dry mix, the meat may 

be momentarily moistened to facilitate salt penetration. 

Pickle curing includes the use of a cure solution that could be prepared with a: 

• brine solution (water and salt); 

• pickle solution (water, salt, nitrate and/or nitrite); or 

• sweet pickle solution (water, salt, nitrate and/or nitrite, and a sugar) 

NOTE: Other ingredients could also be added to enhance flavor. Binders are permitted in 

certain PFF cured pork products in §319.104 in accordance with §424.21(c), e.g., “ham with 

natural juices”, “ham water added”, and “ham and water product X% of weight is added 

ingredients.” Binders are not permitted in bacon, “ham” or other cured pork products without 

adjusting the product name to identify the binders, e.g., “bacon and binder product.” 

Product covered with pickle solution for any length of time should be checked by the IPP to 

assure the amount of added solution does not affect the establishment’s procedural controls. 

After mixing, a pickle solution should be continually agitated to assure a uniform blend of the 

curing agents and to prevent ingredients such phosphates from precipitating out of the pickle. 

Cure solutions are often reused. When a cure solution is reused, it should be filtered to keep it 

clear, free of sediment, and prevent decomposition. The IPP should check the filter to ensure 

that it is in good repair and removing meat residue and sediment. 

95 
 

 

 

 

 

 

 

 

NFSCP PHIS Tasks 

The proper inspection tasks used to verify the cured meat and poultry product regulatory 

requirements may not always be readily apparent. Below are two commonly used tasks for the 

products covered in this module: 1) General Labeling Verification Task, and 2) % Yield/Shrink 

Verification Task. 

Performing the General Labeling Task 

Before starting the task, review the applicable regulations and review the steps for performing 

the task. Use professional knowledge, good judgement and begin your (GAD) process. 

Inspection program personnel perform this task to verify general labeling regulatory 

requirements and determine if the label accurately reflects the finished product for the cured 

meat and poultry products. Restricted Ingredients regulatory requirements should also be 

verified while performing this task. 

General Labeling Requirements 

Select the Label - Select a label to verify that is being applied to a product on the day that the 

task is being implemented. Check the label to verify that all mandatory features required in 

9CFR 317.2 are present; product names include qualifying statements and/or descriptive 

designations if necessary; that label does not include any false or misleading information, etc. 

You will verify that the product is not misbranded by use of the label. 

NOTE: Product is misbranded if its label is missing a required feature, qualifying statement, or 

descriptive designation or is anyway false or misleading. 

A product is misbranded, if: 

• a declared ingredient is omitted 

• an ingredient is added but not declared on the label 

• the ingredient order of predominance is not accurate 

Labeling file – Determine if the label approval is on file (sketch, temporary, or generic per 

§412.1); if sketch approval is required by §412.1 verify that the label has LPDS approval; if a 

temporary approval (which requires LPDS approval) is being used verify that the expiration date 

is still valid; verify that the product being made follows the formula and processing procedures in 

the label approval. In order to do this, you will need to request to see that the label approval is 

on file for review; the establishment is required to provide this information upon request. 

NOTE: If a noncompliance is found, IPP should issue an NR and take the appropriate

action necessary to ensure misbranded product does not enter commerce. 

Label Accurately Reflects the Product 

Determining that the label accurately reflects the finished product involves: 

• reviewing the product’s formulation record 

• observing its actual preparation and, in some cases 

• performing formula calculations 

Steps for performing the General Labeling task: 

1. Select one or more batches of product at formulation 

96 
 

 

 

 

 

 

 

 

2. Verify ingredient amounts comply with the formula on file 

3. Verify that no undeclared ingredients are added or declared ingredients are omitted from 

the finished product 

The verification process may involve: 

1. Observing pre-weighed ingredients for proper identification and weights 

2. Observing establishment employees weighing ingredients 

3. Actually, weighing pre-weighed ingredients to determine if the weight on the container is 

accurate 

NOTE: An ingredient added at a different level than indicated in the product formula 

could affect the ingredient order of predominance on the label. 

Once the formula process for the curing solution preparation has been observed, verify that the 

label does not have false or misleading information, that the ingredients are correctly listed in 

the ingredients statement and that they are in descending order of predominance. 

Restricted ingredients 

The regulations and many product standards of identity allow the establishment to add various 

ingredients to the formula of certain meat and poultry products. Some meat and poultry 

components used in the formulation may have regulatory limits. Some nonmeat ingredients 

have a specified maximum amount or percentage allowed in the product. These nonmeat 

ingredients are called restricted ingredients. The establishment MAY add the component or 

ingredient in any amount up to its permitted limit. IPP will perform calculations when restricted 

ingredients are used, e.g., nitrite, cure accelerators, phosphates, etc. 

If the product is formulated with a meat or poultry component with a regulatory limit or with a 

restricted ingredient, the IPP should select one or more batches of product during formulation. 

They should determine the amount or percentage of the meat or poultry component and/or the 

amount one or more restricted ingredients used in the formula. The IPP verifies that the: 

• percentage of meat or poultry component meets the regulatory limit 

• restricted ingredient is allowed in the product 

• the amount of the restricted ingredient added to the product does not exceed the 

regulatory limit 

Verifying meat and poultry components or restricted ingredients are in compliance with 

regulatory limits usually requires the IPP to perform a formula calculation. When meat or poultry 

components or restricted ingredients are added at levels in excess of their maximum regulatory 

limit, they become economic adulterants. 

If IPP find noncompliance, they issue an NR and take the appropriate action necessary to 

ensure adulterated or misbranded product does not enter commerce. 

Performing the %Yield/Shrink Task 

Inspection program personnel (IPP) perform the percent yield/shrink task in establishments that 

are preparing meat or poultry cuts, parts and products with added solutions at levels that do not 

require the product’s label to be qualified with a statement to indicate the percent of the solution 

and ingredients added to the product. When the product’s label is qualified with a percentage, it 

is verified using the X% solution task. We will discuss this in the next module. 

97 
 

 

 

 

The added solution, product shrink, and yield verification determinations are performed on one 

or more subgroups (samples) of product or on entire batches of product. 

When performing this task, IPP: 

• select an appropriate product (has to be one that the product name does not require an 

added solution statement) 

• verify compliance with regulatory requirements by: 

o reviewing establishment records and labels 

o weighing appropriate amount of meat or poultry 

o calculating the % added solution, gain, pump or pickup, yield or shrink 

o comparing the result with the appropriate regulatory requirement, the establishments 

records, and product label 

In addition, inspection program personnel should weigh a sample of product before and after 

(IPP should weigh the same product/pieces) the appropriate step in the process (i.e., pumping, 

cooking, chilling, curing, drying, etc.); then calculate the % yield or shrink, and compare the 

result with the appropriate regulatory requirement, the establishment records, and the product 

label. 

To calculate the % yield, shrink: 

• Weigh a subgroup (sample) of product before and after the appropriate step in the 

process (pumping, injecting, dipping, cooking, chilling, or drying). 

o There is not a specified number of pieces of product that must make up a subgroup. 

The number of pieces selected and weighed should be representative of the lot size. 

For example, the IPP may select 20 or 30 pieces of meat or poultry and have them 

weighed before the solution is applied (green weight) and 20 or 30 pieces after the 

appropriate processing step, e.g., pumping, immersion, or cooking and chilling, and 

have them weighed (finished weight). 

o Actual % pump or pick-up – the actual amount of solution above green weight that is 

in the meat or poultry without allowing a drain time. 

o Effective % pump or pick-up – the amount of solution above green weight that 

remains in the meat or poultry after allowing a specified drain time. 

o Restricted ingredient calculations will be based on whether or not the company 

includes a drain time in their processing procedures, if not, then the actual % pump is 

used. 

• After the subgroup or batch weights (green and finished weights) are obtained, the IPP 

must perform a calculation to verify that the added solution or the product’s yield or 

shrink complies with the product’s standard of identity or regulatory requirement. 

Note: Shrink and yield determinations should be conducted on entire lots of product.

However, in many instances it is not feasible to perform shrink and yield tests with the entire 

weight of the lot (inspection personnel time constraints or extremely large lot size). Therefore, 

weighing a large enough portion (subgroup sample) to represent the lot would be acceptable. 

Restricted Ingredients 

This section includes information on ingredients and the limitations for their use in curing 

compounds and curing solutions that are to be applied in or on meat and meat food products 

98 
 

 

 

 

and poultry and poultry food products. It also covers mathematical calculations to determine 

compliance for the following restricted ingredients: 

• Curing agents and curing compounds, 

• Curing accelerators, and 

• Phosphates 

Note: In the establishment, FSIS Directive 7620.3, Processing Inspectors' Calculations 

Handbook can be used to assist you. Restricted ingredients are verified using the General 

Labeling Task. 

IPP may use two methods to determine curing agent, curing compound, curing accelerator or 

phosphate compliance. 

1. Determine ingoing parts per million of cure agent, cure accelerator or phosphate in 

pickle formula then compare their result against the ingoing amount allowed by the 

regulations. If the calculated ingoing amount is equal to or less than the amount allowed 

by regulation, the product is in compliance. 

2. Determine the maximum amount of the cure agent, cure compound, cure accelerator or 

phosphate allowed in the formula and then compare their calculated result to the amount 

that is actually being used in the formula. If the amount used in the pickle formula is 

equal to or less than the maximum amount allowed, the product is in compliance. 

Limits for restricted ingredients (RI) permitted in pickle cured meat and poultry products are 

expressed in terms of ounces (oz) or pounds (lb.) per gallons of pickle solution, or as 

percentages (%) in the Table of Approved Substances in section 9 CFR 424.21(c) and FSIS 

Directive 7120.1. The same limits may be expressed in parts per million (ppm) which are more 

convenient units for verifying food additive compliance. The conversion of curing agent and 

accelerator weight limits, and the phosphate percentage limit to parts per million (ppm) limits is 

shown in Table I. 

Note: When nitrate and nitrite are used in combination, the limits are calculated separately and 

the permitted maximum (weight or ppm) of each may be used. 

99 
 

to Maximum P;PM LJm it 

Cur·e Agent L imits in Regul~tions General PPM Equ.ation for Pickled Product: 

ppm= ID .Bl .x % gumR x 1 Q~HI ~~g 

~ ofpickl.t! 

II 1-gallon pld<le welgns 10 (l).(wt base when 

regulallons were wntten). then 100 gallons 

weighs 1000 lb. 

Nitrite 

2 (l). to 100 gallons ol pid<le at 10% 2 1tP< lQ (l!!:'.!l,l x ] l!QQ l!QQ = 200 ppm pump 1000 lll, 

Nitrate 

z H:I X 1 ll (1 ll'lltl x ] QQll QQll ; 700 ppm 7 (l). to 100 gallons o t pid<le at 10% 1000 lll, pump 

Nott!: wnen nitrite and nitrate are used 

in combinauon. the limits are carciutate<I 

separateiy anc1 tne permitted maximum 

(weiQht or nnm\ or each mav be used 

Cure Accelerators In Regulations Converta-d to ~ 

Ascorbic Acicl and Erythorbic AOkl 111 gal pid<le welgtls 10 ll). lhen 100-gal pickle 

v.re,gh 1000 (l). 

75 oz to 100-gal pidde at 10% pump 

75 OZ. = 75/16 = 4.687 111, 

~ &DZ x !J Jg x J !lQQ t!Q2: 469 ppm 

AScomate and Erythor0ate 1000 

87.5 oz to 100-gal pickle at 10% pump 87.5 OZ; 87.5 OV16; 5.468 111, 

:i!l6§ xl)]ll x] !!QQ!!QQ;547 ppm 

I ,~ Phosph.ates '" Regufatlons Converte.d to ~ 

Used to decrease cooked out Juices: 

5 percent ot phospnate In pickle at 10% 5% In plel<le : 5 U>. in 100 Ill, 

pump (meal regulallons} 

:;ix Q]ll x l QQQQQQ = 5000 ppm 100 

0 .5% or tota l prOducl (poultry 5000 ppm : 0,005 K 0.5% 

regulallons) 5000 ppm ~ 0.005 ~ 0.5% 

0 .5% or pnospnate In proouct (meat 

regulations) 

Used to protect navor: 5000 ppm = 0.005 = 0.5% o 5% or tota l oroouct 1meat reou1a11ons1 

TABLE 1 

Conversion of Restricted Ingredient Weight or Percentage Limitations to PP limitations 

Curing Agent (Nitrite and Nitrate) Compliance Determinations 

Table II lists the maximum parts per million (ppm) for each of the four curing agents permitted in 

products, based on the curing method used. The limits vary among curing methods because the 

methods differ in the efficiency with which the curing agent is brought in contact with the meat 

and/or poultry. Limits for nitrite/nitrate combinations and combination procedures (such as 

pumping and dry curing) are addressed in the Processing Inspectors’ Calculation Handbook. 

100 
 

 

 

LE IIJ 

Max imum Ingoing Nitrite and Nitrate Lim its (in PPM) for Meat and Poultry 

Products* 

Curing 

Method 

Immersion Massaged or Comminuted Dry Cured 

Cured Pumped 

Curing Agent 

Sodium Nitrite 200 200 156 625 

Potassium 200 200 156 625 

Nitrite 

Sodium Nitrate 700 700 1718 2187 

Potassium 700 700 1718 2187 

Nitrate 

* There are more stringent limits for curing agents in bacon to reduce the formation of 

nitrosamines. For this same reason, nitrate is no longer permitted in any bacon (pumped 

and/or massaged, dry cured, or immersion cured). 

The amount of ingoing nitrite or nitrate used in pumped, massaged, injected, or immersioncured products, such as hams, poultry breasts, poultry rolls, corned beef, etc., is based on the 

green weight of the meat and/or poultry used in the product formulation. 

The green weight is the weight of the meat and/or poultry (e.g., ham, chicken breast, pork belly, 

beef brisket or pork trim for sausage) prior to processing (such as grinding and adding 

ingredients, pumping with a solution, adding batter and breading, cooking, or drying). Nothing 

has been added or removed from the meat and/or poultry. 

Curing Accelerator Compliance Determinations 

Cure accelerators speed up the color development (color fixing) of cured products by 

accelerating the chemical conversion of nitrite to nitric oxide. In addition, cure accelerators aid in 

keeping myoglobin (muscle pigment) in the reduced state so that it can readily combine with 

nitric oxide to form nitric oxide myoglobin. Since cure accelerators aid the curing agents in cure 

color development, they may only be used in combination with the curing agents. 

Ascorbic/Erythorbic Acid: 

• 75 oz to 100 gallons of pickle at 10% pump or 469 ppm maximum. 

Ascorbate/Erythorbate: 

• 87.5 lb. to 100 gallons of pickle at 10% pump or 547 ppm maximum (except or bacon). 

101 
 

 

 

1111 lists the permitted maximums ior acoelerators used alone and in combination in 

the curing of pumped, massaged, and immersed meat or poultry products other than 

bacon. Maximums for sodium ascorbate and sodium el),~horbate (iisoascorbate), in bacon 

.are ,given on pag.e 15 of this handout. 

TAIBLE Ill 

Maximum lngoin.g Cure Accelerators ~in PPM), 

for Meat and Pou,try Prnducts 

Cu re Accelerator Maxiimu11n ILimit 

Ascorbic Acid 469 ppm* 

Erythorbk Acid 469 ppm* 

Sodiiu rn Ascorbate 547 ppm* 

Sodil!Jlm Erytho~bate (isoascomate) 547 ppm* 

Citric Acid or Sodium Citrate may replace up to hallfof any one oHhe abov,e 

.. Except in bacon 

"Tihe amount of ingoing cu re accelerators used in wried, picklled products, such as ham, cormed 

beef, turkey ham, etc., is based on the green w,ejght of the meat and/or poultry and/or 

meat/poultry byproducts used in Ile product formulation. 

All the me'lhods for calculating nitrite and nitrate amounts also apply in the calculation of 

cu:re accelerator amounts. Different limits apply, depending1 upon wh ich cure accelera.torr is 

1U1Sed as s!hm,m in Talble Ill. 

Phosphate Compliance Determinations 

Phosphates are frequently added to curing solutions and cured product formulations because of 

the numerous beneficial effects they have in meat and poultry curing. Phosphates increase the 

water retention (water binding capacity) of the meat and poultry, which reduces the shrinkage 

(moisture loss) and purge (cook-out) of pickle-cured products during further processing. The 

improved water binding results from the reaction of the phosphate ions with the meat and 

poultry proteins. Phosphates also improve the sensory characteristics of the product (texture, 

juiciness, and tenderness), improve the stability and uniformity of the cure color, and suppress 

the development of rancidity in cured products. Phosphates tend to precipitate out of pickle if 

not agitated. 

Phosphates are permitted in meat and poultry products, unless otherwise prohibited by the 

regulations, to reduce the amount of cooked-out juices. Phosphates in pickle-cured meat 

products such as ham, corned beef, and bacon are limited to 5% in a pickle at a 10% pump 

level. Phosphates in pickle-cured poultry products such as turkey ham are limited to .5% in the 

total product. Both limits are equivalent to 5000 ppm. For pickle cured meat products, the 

maximum ingoing phosphate limit is based on the green weight of the meat or meat byproduct 

in the product formulation. Calculations for phosphate(s) are the same as those for nitrite and 

cure accelerators in pickle-cured meat products. 

102 
 

 

Solving for Ingoing RI parts per million (ppm) 

An establishment's written procedure calls for 10% pump, 100 gal of pickle weighing 1,000 lb. , 

and 2 lb. of sodium nitrite. 

('X") = unknown 

X = 2 x 0. 1 x 1 000 000 

1,000 

X = 200.000 

1,000 

X = 200 ppm ingoing nitrite 

Note: Ingoing parts per million for cure accelerators and phosphate (meat product only) are 

determined using the same method except the weight of the cure accelerator or phosphate would 

be substituted into the equation for the weight of nitrite. 

2. Solving for maximum percent pump 

Pickle "A " contains 1 lb. 12 oz of nitrite for 1,000 lb. What percent of pump is permitted? 

Calculation: Convert 1 lb. 12 oz to 1. 75 lb. nitrite allowed at 200 ppm 

200 = 1. 75 x Xx 1 000 000 

1,000 

In this instance, all the known values are moved to the left side of the equation, leaving 'X " on the 

rJSJ.tJ.t and keeping it in the numerator. To transfer a value from one side of the equation to the 

other, it is simply moved to the numerator on the other. 

200 x 1 000 =X 

1. 75 X 1,000,000 

200 000 = X 

1, 750,000 

0.1142=X 

11.42% maximum % pump allowed 

Pickle Solution Compliance Determinations 

Firstly, when the pickle is measured by volume, not weight; 

• determine its weight by multiplying the number of gallons of water by 8.33 (the weight in 

pounds of a gallon of water) and adding the actual weight of the other ingredients. 

Next, if two parts of the equation are known, the third can be calculated by: 

• substituting the known values using the following calculation equation: 

ppm (parts per million) = lb. Restricted Ingredient (RI) × % Pump × 1,000,000 

lb. Pickle 

Example Problems 

103 
. ...Solvin_gj_ol_maximulJ)_amount of_restriQt ed ingred ie._.n,._.._ ___________________ _ 

r Establishment 38 is using a cure mix with 6.25% nitrite. The establishment is planning to pump 

hams at 12% using a pickle solution. How much cure mix can the establ;ishment use per 100 

gallons of pickle at this level of pump if the pickle weight is 9.5Ib. per gallon? 

Calculation: 200 = Xx 0_ 12 x 1,000.000 

950 

In this instance, all the known values are moved to the left of the equation, leaving ·x• on the 

right where it is the numerator. 

200x950 = X 

0_12x 1,000,000 

190 000 = 1_58 lb_ nrtnte allowed per 100 gallons of cunng solu1Jon 

120,000 

Special Note: To find the amount of cure mix allowed. IPP divide the amount of nitrite allowed 

(in this case 1_58Ib_) by the percent nitrite in the mixture (in this case 6.25% nitrite). 

1-58 = 25.28 lb_ of ptckle solution allowed m each 100 gallons of pid<le 

.0625 

4. Determining the volume of a container 

Pickle tank "C " is a rectangular tank with these dimensions: 

Length = 60 inches; Width = 48 inches; Height = 48 inches 

How many gallons will it hold when complete Iv. filled ? 

Special Note: There are 231 cubic inches in a gallon and 7.48 gallons in a cubic foot. 

ANSWER: V = LWH 

231 

V = 60 x 48 x 48 

231 

V= 598.44 gal 

Special Note: When calculating for restricted ingredients, the tanks are usually never filled to the 

brim. Therefore, /PP may calculate for the gallons per inch of depth and multiply the gallons per in ch 

by the height in inches that the tank will be filled to find the total volume. 

5. Deterrninin volurne in a ania/1 filled tank 

P ickle tank "D " is a rectangular tank w ith these dirnensions: 

Length = 65 inches; Width = 60 inches; Height = 48 inches 

H ow m a ny inches from the top would 600-ga l measure in this tank? 

NSWER: 

V= 187200 

231 

V = 810.39 gallons 

V = 810.39 gal 

48in 

V per inch in height= 16_88 gal 

H = 600 gal + 16.88 in 

H = 3 5.55 inches in tank 

H = 48 in - 35. 55 in 

H = 12.54 inches or 12.5 in c hes from the top of the tank 

3 

104 
 

 

 

 

·1 d~ "'" 

Volume Determinations 

The volume of a rectangular or square container is determined by multiplying length x width x 

height. When determining volume, you may need to do a calculation based on the size of the 

continuer and the amount of solution in it before performing a calculation to determine volume. 

The container holding solution may not be full. Calculations must be performed on the actual 

solution volume not the container volume to be accurate. Cylindrical volume will be calculated 

differently. 

Formula: V= Lx W x H 

Cylinder volume formula: 

V= π x r2 x h 

π = pi or 3.41

r2

= radius squared 

h = height 

*(note: the radius is one-half of the diameter) 

**(note: radius squared is the radius multiplied by Itself, r x r) 

105 
 

 

 

 

 

 

 

 

 

Cure Agent and Cure Accelerator Determination Workshop 

Curing Problem Scenario 1 

There is a General Labeling task scheduled on the task calendar today. The establishment’s 

production sheet indicates that the boneless ham water added product is being prepared today. 

You go to the production office and review that procedure. The Boneless Ham Water Added 

procedure indicates that the pickle solution is prepared in a 200-gallon batch. A gallon of pickle 

weighs 10 lb. The target pump is 14%. 

The restricted ingredients used in the pickle formula: 

Phosphate - 72 lb. 

Nitrate - 8 lb. 

Nitrite - 2 lb. 10 oz. 

Sodium Ascorbate - 5 lb. 

In the pickle preparing room, you find the Boneless Ham Water Added procedure posted above 

the pickle tank. It is the same procedure you observed in the production office. You find the tank 

used for mixing this pickle has these dimensions: length = 40”; width = 40”; height = 30” 

There is a 200-gallon mark located 3” from the top of the tank. 

Note: There are 231 cubic inches in a gallon 

1. What is your first name? 

2. What is your last name? 

3. What is the volume of the pickle in the tank? (What are your general concern(s) in 

relation to the restricted ingredient levels? Would you expect the levels in this volume of 

solution to be higher or lower than in 200 gallons?) 

a. 187.01 gallons 

b. 207.79 gallons 

c. 205.71 gallons 

4. Is the mark on the tank correct? 

a. Yes 

b. No 

5. Phosphate – calculate the ingoing PPM based on 200 gallons of pickle 

a. 5040 ppm 

b. 5400 ppm 

c. 50.40 ppm 

6. Nitrate – calculate the ingoing PPM based on 200 gallons of pickle 

a. 560 ppm 

b. 56 ppm 

c. 5.6 ppm 

106 
 

 

 

 

7. Nitrite – calculate the ingoing PPM based on 200 gallons of pickle 

a. 183.75 ppm 

b. 1.83 ppm 

c. 18.37 ppm 

8. Ascorbate – calculate the ingoing PPM based on 200 gallons of pickle 

a. 350 ppm 

b. 35 ppm 

c. 3500 ppm 

Calculate the ingoing PPM for nitrite based on the gallons of pickle from question. 

9. Nitrite 

a. 196.52 ppm 

b. 19.65 ppm 

c. 1.96 ppm 

10. Did these calculations support your concern(s) from the previous question? 

a. Yes 

b. No 

11. Based on the pickle formula (200 gallons), was the regulatory limit exceeded for any of 

the restricted ingredients? 

a. Yes 

b. No 

Curing Problem Scenario 2 

The General Labeling task is on the task calendar today. The establishment’s written procedure 

states that the beef brisket pickle solution is prepared in an 860-gallon curing vat. The total 

ingredients (including water) weigh 8,586 lb. The pump target is 12%. 

(Note: The cure ingredients are combined in a curing compound.) 

The cure compound label states: 

Sodium nitrite 23% 

Sodium erythorbate 25% 

Salt carrier 52% 

Total 100% 

12. What is the maximum amount of curing compound permitted in this pickle formula? 

a. 62.21 lb. 

b. 6.221 lb. 

c. 622.1 lb. 

107 
 

Curing Problem 3 

13. How many gallons are contained in a cylindrical drum filled to within two inches of the 

top with pickle if the drum dimensions are 24” (diameter) X 30” (height)? 

V = π r2

h π = 3.14 r

2 = radius h = height V= volume 

Note: There are 231 cubic inches in a gallon 

a. 54.8 gallons 

b. 548 gallons 

c. 5.48 gallons 

14. How much nitrite, nitrate, and ascorbic acid could be used if the establishment wants to 

pump 15%? (A gallon of pickle weighs 9.68 pounds.) 

Nitrite 

a. 0.70 lb. 

b. 70 lb. 

c. 7.0 lb. 

Nítrate 

a. 2.47 lb. 

b. 247 lb. 

c. 24.7 lb. 

Ascorbic Acid 

a. 1.65 lb. 

b. 165 lb. 

c. 16.5 lb. 

108 
 

 

 

Method 

IPP can use the steps in the table below to compare a product's green weight with its 

pumped, treated, or massaged weight and determine the percent added solution. 

STEP EXAMPLE 

1 Determine the green weight of a given Fifteen beef briskets to be 

number of pieces of fresh (unpumped, pickle- cured weigh 227.6 lb. 

untreated, etc.) meat or poultry or an amount 

of fresh (unpumped, untreated, etc.) meat or 

poultry product that will represent the lot 

2 If a drain time is listed in the establishment's After pumping, the same fifteen 

written procedure, allow the pumped/treated beef briskets weigh 271.1 lb. 

product to drain for the specified time period 

and then weigh. If no drain time is listed, 

take the weight directly after pumping. 

3 Subtract the green weight from the pumped 271.1 lb 

or treated weight to obtain the pounds of - 227.6 lb 

added solution. 43.5 lb of solution 

4 Divide the pounds added solution by the 43.5 lb+ 227.6 lb= 0.191 1 

green weight 

5 Convert the decimal answer into the 0.1911 x 100 = 19.11% added 

percentage of added solution by multiplying solution. In this case 19.11 o/o 

by 100. could also be referred to as the 

effective percent pump (if 

product is drained) or actual 

percent pump (if product is not 

drained). 

Added Solution and Shrink Determinations 

Several meat food products and turkey ham have specific regulatory limits for the amount of 

water that can be added or picked-up from a curing solution. Inspection program personnel 

must perform pump or pick-up determinations to verify that the amount of solution added to the 

product is in accordance with the regulations, the establishment’s written procedures, or product 

label. IPP also perform the % Yield/Shrink task to verify that the product’s finished weight meets 

the regulatory requirement prior to packaging. 

This section includes examples and/or practice problems designed to assist IPP in: 

Performing percent added solution (pump/pick-up) determinations; 

Maximum percent pump/Maximum amount of added solution (gain, pump or pick-up) 

Performing product shrink determinations on the finished product 

Performing cooking/smoking/cooler shrink determinations. 

Interpreting processing procedure charts; and 

Calculating maximum amounts of restricted ingredients allowed. 

Percentage of Added Solution (Gain in the Calculation Aid) Determination 

109 
 

 

 

 

Calculation Equation for Raw Products 

(pumped, treated, or massaged) weight - green weight × 100 = % pump/pick-up/added solution

 green weight 

Note: Pumped weight, treated weight, or massaged weight can be in inserted into the above 

equation depending upon the method in which the solution is applied, e.g., treated weight is 

used when the product is dipped or submerged in the solution; pumped weight is used when the 

solution is injected into the cut. 

Note: The green weight is the weight of the meat and/or poultry prior to processing (such as 

adding ingredients, pumping with a solution, cooking, or drying) 

If the beef briskets in the above example were targeted to have a 17% pump had a 19.11% 

effective or actual pump, there is regulatory noncompliance. If the establishment can 

demonstrate with records (e.g., its own added solution tests during the shift and previous shifts) 

that the added curing solution is consistently or routinely 17% (as declared on the label) or 

below, then there is no noncompliance. On the other hand, if the establishment cannot 

demonstrate that the added curing solution is consistently or routinely 17% (as declared on the 

label) or below (i.e., has no data or records), then the IPP would retain the lot of beef briskets 

until the briskets drain to 17% percent added solution. If a consistent pattern of over pumping 

(indicates lack of process control) is identified, then the IPP shall request that establishment 

management update its written procedure to reflect the effective or actual pumping 

percentage—9 CFR 320.1(b) (11) or 381.175(b) (6). Any pumping above the establishment’s 

target pump but below the maximum solution allowed in the product should be discussed at the 

weekly meeting. The establishment response needs to be documented in the MOI. When 

applicable, the 20% range is determined as, (X% declared on the label x 0.8 for the lower limit) 

– (X% declared on the label x 1.2 for the upper limit). 

If the IPP determined the amount of curing solution added to the raw beef briskets in the 

example above was 21% (i.e., above the FSIS allowance of 20% which for 17% declared on the 

label is 20.4% maximum), the IPP would document this as a noncompliance. 

Note: The amount declared on the label is the limit for the actual/effective pump. 

If an establishment does not have a history of over-pumping and it was not intentionally 

targeting an amount of added solution above what is declared on the label, the agency has 

allowed a 20% variance. The variance is not to be used all the time it is only for occasional 

unusual circumstances. 

Additional Added Solution Example Calculations 

A pump test shows 30 fresh, uncured hams had a green weight of 450 pounds; the same 30 

pumped hams had a weight of 510 pounds. The procedure indicates 16% target pump. 

What percent added solution does this test show? 

Answer: 510 - 450 = 60 lb. 

60 ÷ 450 = 0.133 or 13.3% 

If a consistent pattern of under pumping is identified, then the IPP should request that 

management adjust the procedure to reflect the actual pumping percentage. Pumping 

110 
 

 

alculation Method 

IPP may use the steps in the following table to determine the maximum percent pump allowed 

for each restricted ingre<lient in a pickle or curing solution. 

STEP EXAMPLE 

1 Determine the weight of the nitrite added to Pickle Fonmula 

the pickle solution, the total weight of the W ater 1310.00 lb_ 

pickle solution, a nd the target percent pump Salt 132.00 lb_ 

from th e label transmittal fonm or the Dextro se 18.00 lb. 

establishment's written procedure Phosphate 3 5 .00 lb. 

record/chart. If any two of these quantities are Sodium Erythorbate 3.25 lb. 

known, the third can b e calculated by Sodium N itrite 1.75 lb_ 

substituting the known values in to the Total 1500.00 lb. 

equa tion_ 

Beef briskets are pumped with 16% 

solution. 

2 E nter the w eight of the nitrite , the w e ight of W e have 1.75 lb. of nitrite in 1500 

the pickle solution, and th e ppm limit for nitrite lb_ of solution that is to be pumped 

(200 ppm) into the equation and solve for n , into beef brisket s at a target ed 

the maximum percent pump_ level of 16%. How ever, what would 

be the maximum% pump a llowed in 

the event the establishment 

excee<led the t arget % pump? 

200 = 1. 75 X n X 1 000 0 00 

1500 

n = 200 X 15 00 = 0 .1714 

1 _75 X 1,000,000 

3 Convert t he decima l answe r into the percent 0.1714 x 100 = 17.1 4 % is the 

pump by multiplying by 100_ maximum pump % lev el for nitrite_ 

Since the target % pump is 16%, 

this processing proce<lure would 

produce beef briskets in complia nce 

for in going nitrite _ 

equipment is checked for accuracy daily by the establishment and should be spot checked by 

the IPP. The under pumping should be discussed at the weekly meeting and the 

establishment’s response documented in the MOI. 

A second test was conducted on 25 pork hams. The procedure indicates a 19% effective pump. 

Pumped weight = 260 lb.; Green weight = 210 lb. 

What is the percentage of added solution? 

Answer: 260 – 210 = 50 lb. of solution 

50 ÷ 210 = 0.2380 or 23.80% 

Note: The IPP should request that the establishment demonstrate that these hams are in 

compliance with the minimum PFF value in the table in 9 CFR 319.104 after they are cooked 

and accurately labeled because they have been over pumped by 4.8%. IPP should also verify 

the amount of ingoing restricted ingredients are in compliance using the 23.8% effective pump. 

This finding should also be discussed at the weekly meeting and the establishment’s response 

documented in the MOI. 

Maximum Percent (Gain, Pump or Pick-up) Determination 

111 
 

 

 

 

 

Amount of Added Solution (Gain) Allowed Determination 

Beef cuts or beef briskets dipped or submerged into or injected with pickle solutions may not 

have more than the 10% or 20% solution added to them in accordance with regulations. 

Calculation method 

The steps in the table below will assist IPP in determining the maximum amount (pounds) of 

added solution. 

STEP EXAMPLE 

1 Multiply the green weight ofthe meat or Ten beef tongues treated with a 

poultry to be pumped/treated by the amount pickle .cure 

of solution allowed - 10% (.10) or 20% (.20). 

Ten tongues weigh 38 lb. 

38 lb. 

X .10 (10%) 

3.8 lb. of solution permitted 

2 Add the untreated (green) weight and the 38.0 lb. 

solution permitted to get the total maximum + ;L!Llb. 

weight of the treated product. 41.8 lb. would be the 

maximum amount the ten 

tongues could weigh after 

being treated. 

To verify that the level of ingoing restricted ingredients (curing agents, cure accelerators, 

phosphates, etc.) in a pickle formula are in compliance, IPP can determine the maximum % 

pump for each restricted ingredient and compare it to the targeted % pump. The listed target % 

pump shall never be greater than the maximum % pump allowed for any restricted ingredient in 

the solution. To verify restricted ingredient compliance at the time of pumping, the effective or 

actual % pump must be compared to the maximum % pump allowed for the pickle solution. 

Calculation Equation for Maximum Percent (Gain, Pump, or Pick-up) 

lb. restricted ingredient × % pump × 1,000,000 = ppm 

lb. pickle 

If the weights and maximum permitted levels (in ppm) of phosphate and sodium erythorbate 

were substituted into the table on the previous page, the IPP would obtain a maximum % pump 

of 21.42% for phosphate and 25.24% for sodium erythorbate. Although three different maximum 

% pump levels exist for this pickle solution, 17.14% would be the maximum % pump level 

allowed for this solution because the ingoing nitrite limit would be exceeded at any % pump 

greater than 17.14%. 

As stated before, restricted ingredient compliance must be verified at the time of pumping. 

Verifying at this point helps assure that the pumping machine is in proper adjustment and 

draining procedures are followed. This can be done by determining the effective or actual % 

pump and comparing it with the maximum % pump for the pickle solution. For example, if the 

beef briskets on the previous example were pumped with the pickle solution in Step 1 in the 

table on the previous page, they would be out of compliance for ingoing nitrite because the 

effective or actual % pump (19.11%) is greater than the maximum % pump (17.14%) for the 

pickle solution. 

112 
 

 

 

 

EXAMPLE 

1 Determine the g ,reen weight of the meat. Dry-Cured Pork Shoulders 

Pork shoulder s 500 lb 

2 Determine the we·ght of the product After the specified curing and 

after p r ocessing, (cooking, d lry·ng, etc.). drying period, the pork shoulde,rs 

weigh 395 lb 

3 Subtr a ct the weight of the product after 500I1b 

processing (finished weight) from the - 395 lb 

green weight of the ,meat to findl the 105 llb amount the product shrunlk . 

4 Divide the number of pounds the product 105 lb - 500 lib= 0.21 

has shrunlk by the green weight of the meat. 

5 Convert the deci1mal answer into the 0 .21 x 100 = 21% shrinlk (in 

percentage of shrinlk by multiplying b y compliance). The weight of 

100. the pork shoulders is at least 

18% less than the fresh 

uncured (green) weight of the 

pork shoulders 

Each restricted ingredient's compliance at the time of pumping could also be verified by 

inserting its weight, the effective or actual % pump, and the weight of the pickle solution into the 

equation in Step 2 of the table on page 39 and solving for ppm. 

Finished Product Shrink and Cooking/Cooling Shrink Determinations 

After processing, some products must weigh a certain percentage less than the green weight of 

the fresh meat cut. IPP are responsible for verifying the shrinkage of various cured meat 

products. For example, dry-cured hams and pork shoulders must shrink a minimum of 

18%--9 CFR 319.106(b)(7). IPP may also verify that the establishment is following its written 

processing procedures required by 9 CFR 320.1(b)(10) and 381.175(b)(6). 

Use the equation on the next page to verify the percent shrink compliance of dry cured hams 

and pork shoulders. This equation may also be used to determine the shrink for other meat food 

products that are required to have specific amount of shrink, e.g., bacon bits and barbecued 

meat. 

Calculation Equation for Percent Shrink 

green weight meat or poultry - finished weight X 100 = % shrink 

green weight meat or poultry 

Note: Finished weight is the weight of the meat and/or poultry plus the weight of any ingredients 

added during processing minus the weight loss (shrink) from smoking, cooking, cooling, or 

drying. 

The steps in the table below should be used when IPP want to find a finished product's percent 

shrink. 

113 
 

 

 

EXAMPLE 

1 Determine the weight of the product (less tare) 1000 lb. of turkey thigh 

going into the smokehouse, oven, cooler, etc. meat 

2 Determine the weight of the product (less tare) 927 lb of Turkey Ham 

coming out of the smokehouse, oven, cooler, etc. after cooking and 

smoking 

3 Subtract the weight coming out from the weight 10001b 

going in to find the amount of product shrink. 9271b 

731b 

4 Divide the number of pounds shrunk by the product 73 lb -+- 1000 lb = 0 .073 

weight going into the smokehouse, oven , cooler, 

etc. 

5 Convert this decimal answer into the percentage of 0 .073 X 100 = 7 .3% 

shrink by multiplying by 1 00. cook shrink 

Cook and Chill Shrink Determinations 

The establishment must adhere to its written procedures, e.g., solution formulation, cooking and 

chilling time, temperature and humidity, and cook and chill shrinks. Smokehouse instrument 

charts should be checked periodically against a known accurate thermometer to determine the 

accuracy of the recording devices. When an establishment is producing a PFF controlled cured 

pork product and does not meet the target shrinks, the product may not be accurately labeled, 

e.g., ham natural juices versus ham water added versus ham X% of weight is added 

ingredients. Likewise, if an establishment is producing cooked cured beef product or cooked 

turkey ham and does not meet the target shrinks, the finished product weight may exceed the 

original (green) weight of the beef cut or thigh meat prior to curing, i.e., the product yield is more 

than 100%. Cooked corned beef products and turkey ham, whose weights after cooking exceed 

the weights of the fresh uncured beef or thigh meat, must be descriptively labeled to indicate the 

presence and the amount of the additional substances, e.g., “Corned Beef Containing 15% 

Solution” or “Turkey Ham, Cured Turkey Thigh Meat 25% Added Water.” 

Use the following equation to determine the percent cook shrink or chill shrink of cooked bacon 

bellies, PFF-controlled cured pork products, cured beef products, and turkey ham. 

Calculation Equation for Cooking and Chilling Shrink 

weight in (smokehouse/oven/cooler) - weight out (smokehouse/oven/cooler) X 100 = % shrink 

weight in (smokehouse/oven/cooler) 

The steps in the following table should be used when IPP want to determine the percentage of 

cook or chill shrink. 

Additional Example Shrink Calculations 

The establishment may record or periodically monitor the cooking shrink. 

114 
 

 

 

 

 

 

 

 

Cooking Shrink Example 

The weight of 60 hams on a smokehouse tree going into a smokehouse is 990 lb. The hams 

have been pumped at 14%. The same tree coming out of the smokehouse weighed 910 lb. 

What is the percentage of smokehouse shrink? 

(990 – 910) × 100 

990 

= (80 ÷ 990) = 0.0808 x 100 

OR 

= (80 ÷ 990) x 100 

= 8% shrink 

Similar to the cooking shrink, the establishment may monitor cooler shrink. 

Cooler Shrink Example 

The weight of 60 hams on a smokehouse tree (hot weight) going into the cooler is 910 lb. The 

weight of the same 60 hams after the minimum chill time is 895 lb. 

(910 – 895) × 100 

910 

= (15 ÷ 910) = .0164 x 100 

OR 

= (15 ÷ 910) x 100 

= 1.64 % shrink 

Note: When shrinks targets listed in the establishment’s written procedure are exceeded, the 

IPP should discuss this finding at the weekly meeting and document the establishment’s 

response in the MOI. If the establishment has a history or pattern of not meeting the target 

cooking and chilling shrinks, the IPP should request that the establishment update the written 

processing procedure. When the product is cooked corned beef or turkey ham, the IPP should 

also determine if the corned beef product or turkey ham returned to the weight of the fresh 

briskets or turkey thigh meat (green weight). When the product is a PFF-controlled product, the 

IPP should request that the establishment demonstrate that the product is truthfully labeled, 

e.g., the minimum PFF value in §319.104 is met for qualifying statement in the product name 

(ham natural juices, ham water added, or ham X%..., etc.) 

115 
Processing Procedures tor Cured, Cooked, and/or Smoked Ham 

STYLE Fully Cooked 

EST.# 38 PRODUCT Bone-in Ham with Natural Juices Wei ht Ran es 14/16 

PICKLE FORMULA 

100-Gal Pickle 

weighing 1000 lb 

SALT 

CORN SYRUP 

WATER 100 GAL 

PHOSPHATE 

NITRITE 

ASCORBATE 

TOTALS 

LB 

~ 

_4_0_ 

...filL 

_ 3_0_ 

....12L 

~ 

1000.0 

%PUMP 

I USUAL PROCEDURES 

%PUMP 

LB. PRESSURE 

SPEED 

BEGIN S.H. TEMP. 

TIME 

MIDDLE S.H. TEMP. 

TIME 

FINISH S.H. TEMP. 

TIME 

TOTAL S.H. TIME 

INT. FINISH F0 

% S.H. SHRINK 

% COOLER SHRINK 

S.H. HUMIDITY 

COOLER TIME 

EST. REP. ______ _,_R,,,u,..e'-'D"'e"-"'B,,. ag.,.g..,a,,_ ____ _ 

PROCEDURE REVIEW 

PUMP TEST SMOKEHOUSE PERIODS 

DATE GREEN PUMPED % FIRST SECOND FINISH 

WT WT PUMP TIME Fo TIME Fo TIME Fo 

2/15 455 520 1G.O 1:55 140 2:20 102 0:00 102 

2/23 420 486 15.7 2:00 140 2:00 160 8:00 180 

16 

60 

140° F 

2 nours 

160° F 

2 nours 

180" F 

8 nours 

12 nours 

152° F 

12% 

2% 

70 

24 nours 

SHRINK 

SMOKEHOUSE COOLER 

HOT % CHILL % WT 

472 lb 10.94 450 1b 2.9G 

432 lb 11 .83 422 lb 2.31 

Added Solution and Shrink Calculation Workshop 

The chart below is a written cured ham example processing procedure for establishment 38. 

Review the information in the chart and answer the questions. 

1. What is your first name? 

2. What is your last name? 

Calculate the maximum percent of pump permitted for each restricted ingredient and compare 

your answers to the procedure chart. 

3. Phosphate 

a. 16.66% 

b. 166% 

c. 1.66% 

4. Nitrite 

a. 16% 

b. 160% 

c. 1.6% 

116 
 

 

5. Ascorbate 

a. 16.83% 

b. 168.3% 

c. 1.68% 

6. Is the % of pump indicated on the procedure chart acceptable? 

a. Yes 

b. No 

Calculate the pump tests using the procedure chart above and compare your answers. 

7. Test dated 2/15 % pump 

a. 16.04 % pump 

b. 1.60 % pump 

c. 160.4 % pump 

8. Test dated 2/23 % pump 

a. 15.71 % pump 

b. 157.1 % pump 

c. 1.57 % pump 

Added Solution and Shrink Problems 

The % Yield/Shrink task is on the task calendar today. The establishment is producing product 

labeled Corned Beef Brisket. The target pump on the establishment’s written procedure for the 

beef briskets is 18%. There is a 30-minute drain time for the pumping procedure. The 

establishment has data indicating that it does % added solution (pump) checks once a month. 

You select a stainless-steel bin with several corned beef briskets (approximately 90) and follow 

the establishment to the scale and have them weighed. After the weight of the bin is removed, 

the beef briskets weigh 895 lb. green. You accompany the bin of beef briskets to the pumping 

machine and observe them being pumped with a curing solution. You place a U.S Retained tag 

on the bin with the pumped briskets and write pump test on the tag. Thirty minutes later you 

return to the processing room and have the bin moved to the scale and weighed. After the 

weight of the bin is removed, the beef briskets weigh 1,105 lb pumped. Are the briskets in 

compliance? 

9. Calculate ________ % pump (added solution) 

a. 23.46 % pump 

b. 234.6 % pump 

b. 2.35 % pump 

10. Are the briskets in compliance? 

a. Yes 

b. No 

117 
 

 

 

The % Yield/Shrink task is on the task calendar today. The establishment is producing product 

labeled Country Style Bone-in Hams. The Bone-in hams are place on stainless steel rack and 

covered with the salt, curing agents, spices, etc. Each rack holds 80 hams. After the hams are 

placed on the racks but before the dry curing ingredients applied to them, you have the 

establishment weigh a single rack of hams. The hams weigh 1,280 lb. You place a U.S 

Retained tag on the rack with the uncured hams and write shrink test on the tag. The 

establishment begins covering the hams with the dry curing ingredients. Each time the 

establishment overhauls the hams (adds new dry curing ingredients) they notify you. After 45 

days they notify you they are going to hang the hams on tree and move them to the drying 

(ripening) room. You observe the hams transferred from the rack to a tree and you transfer the 

U.S. Retained tag to the tree. After another 155 days the establishment informs that they want 

to remove the hams from drying room and package and label them. While on the way to the 

packaging room, you have the establishment weigh the hams on the tree. After the weight of the 

tree is removed, the finished hams weigh 1,042 lb. 

11. Calculate__________% shrink 

a. 18.59 % 

b. 1.86 % 

b. 185.9 % 

12. Are the hams in compliance? 

a. Yes 

b. No 

118 
 

 

 

 

 

 

 

 

Bacon Processing 

This section includes information on bacon manufacturing and IPP verifications activities 

including bacon restricted ingredients and bacon yield determinations. The establishment is 

responsible for controlling bacon manufacturing to assure that the finished product is in 

compliance with FSIS Regulations §318.2, §319.107, and §424.22. Calculation examples are 

provided for reference purposes. 

Introduction 

Because of problems associated with nitrosamine formation in bacon, FSIS regulations, section 

424.22(b) (1) prescribe the regulatory amounts of nitrite and sodium ascorbate or sodium 

erythorbate (isoascorbate) to be used in pumped and massaged bacon. For the immersion 

curing and dry curing of bacon, maximum amounts of sodium and potassium nitrite are 

prescribed in section 424.22(b)(2) and (3) of the regulations. 

Establishment management must develop written pickle formulas and processing procedures 

for preparing bacon (9 CFR 320.1(b)(10))and 381.175(b)(6)). The pickle formula and targeted 

percent pump or pick-up or cure mixture must ensure that the restricted ingredient limits listed 

below are met. 

Regardless of the curing method used, restricted ingredient calculations for bacon are based on 

the green weight of the skinless belly. For rind-on bacon, e.g., where the skin is sold as part of 

the finished product, a restricted ingredient conversion calculation is necessary. Nitrate is no 

longer permitted in any curing method for bacon. 

Restricted Ingredient Limits 

Pumped and/or Massaged Bacon (rind-off): These bellies are injected with a cure solution, or 

a cure solution is added to them by massaging or tumbling. Pumped and/or massaged bacon 

must contain 120 ppm ingoing sodium nitrite (or 148 ppm potassium nitrite). 

550 ppm ingoing sodium ascorbate or sodium erythorbate (isoascorbate) is required in pumped 

and massaged bacon, in addition to any prescribed amount of nitrite. 

Note: When determining pumped and/or massaged product compliance with the nitrite and 

ascorbate (or erythorbate) limits, the Agency allows a plus or minus 20% ppm allowance at the 

time of injecting or massaging due to variables in pumping procedures, draining, purge, etc. 

For example: 20% = 0.20, thus 0.20 × 120 ppm nitrite = 24 ppm 

120 ppm 120 ppm 

- 24 ppm + 24 ppm 

96 ppm minimum nitrite 144 ppm maximum nitrite 

The same calculation can be done for ascorbate or erythorbate (440 ppm minimum, 660 ppm 

maximum). 

The additional solution added to the product from the higher effective or actual % pump than the 

establishment's target % pump would be considered negligible because the finished product 

weight must return to green weight. 

119 
 

 

 

 

 

 

 

 

 

 

 

 

 

Note: The 20% variation is only for actual pump test and is not to be used when determining 

pickle formulas or % pump for the establishment’s written procedure. 

Immersion Cured Bacon (rind-off): These bellies may be place in a pickle solution containing 

salt, nitrite, and flavoring. A maximum of 120 ppm of nitrite or equivalent of potassium nitrite 

(148 ppm) can be used in immersion cured bacon. 

Note: The calculation method for nitrite in immersion cured bacon is the same as that for nitrite 

in other immersion cured products. 

Dry Cured Bacon (rind-off): These bellies are cured by covering them with a pre-measured 

amount of cure mixture. A maximum of 200 ppm of nitrite or equivalent of potassium nitrite (246 

ppm) can be used in dry cured bacon. 

Note: The calculation method for nitrite in dry cured bacon is the same as that for nitrite in other 

dry cured products. 

Bacon labeled “Dry Cured” may not be injected with, or immersed in, a curing solution. 

Bacon labeled “Dry Salt Cured” may contain a curing solution injected directly into the tissues 

but not through the circulatory system. It is then covered with dry curing mixtures. 

Pumped, Massaged, Immersion Cured, or Dry Cured Bacon (rind-on): The maximum limit 

for ingoing nitrite and sodium ascorbate or sodium erythorbate must be adjusted if bacon is 

prepared from pork bellies with attached skin (rind-on). A pork belly's weight is comprised of 

approximately 10 percent skin. Since the skin retains practically no cure solution or cure agent, 

the maximum ingoing nitrite and sodium ascorbate or erythorbate limits must be reduced by 10 

percent. For example, the maximum ingoing limit for nitrite and sodium ascorbate or 

erythorbate for pumped pork bellies with attached skin would be 108 ppm [120 ppm − 12 ppm

(120 × .10)] and 495 ppm [550 ppm − 55 ppm (550 × .10)], respectively.

Written Bacon Processing Procedure Ingoing Restricted Ingredient Determination 

Calculation Equations 

The equation for determining nitrite compliance in a proposed pumped or massaged bacon 

processing procedure is: 

lb. nitrite × % pump × 1,000,000 = ppm 

lb. pickle 

In pumped and/or massaged bacon, this equation can be used to determine: 

The permitted weight of nitrite allowed, if you know the weight of the pickle solution and the 

target percent pump to be used. 

The minimum weight of the pickle solution that can be made, if you know the weight of the nitrite 

and the target percent pump to be used. 

The maximum percent pump, if you know the weight of the nitrite and the weight of the pickle 

solution. 

120 
 

 

 

 

 

T EP EXAMPLE 

1 Determine the w eight of the nitrite added to Pidde Formula 

1he pidkle solution, the tota'I w eiglht of the 

pi clde solution, and the ta rget % pump from Water 1996-3 lb. 

1he• establislhment's wr,itten procedure. Salt 302.2 lb. 

Sugar 156.2 lb. 

Sod1um 

Phosphate 31 _3 lb. 

Sodium 

Erythorbate 11-51b. 

Sod1u m Nitrite 2-51b. 

Total 2500 lb. 

Target pump is 12% 

2 If all three faci:orrs are known, one can just W e have 2-5 lb. of nitrite and want 

solv,e for ppm .and compare the answe1r vllith to malk.e 2500 lb_ of pickle and 

1he• re.gulation to determine if fu,e procedure pump at a level of 12%_ 11s tlhiis in 

produ ces bacon in co mp'liance_ compliance? 

.Note.: The ingoing ppm of sodium erythorbafe n = 2 .5 >< 0_ 12 X 1 .. 000,000 

and sodium phosphate can be de.termined .by 2500 

replacing the pounds of nitrite with the n = 120 ppm nitrite (in compliance) 

pounds of sodium eryfhorbafe and sodium 

phosphate and performing the m athematics_ 

Whether or not a procedure will be in compliance with the regulations, if you know the weight of 

the nitrite, the weight of the pickle solution, and the target percent pump to be used. 

To determine nitrite compliance based on the effective or actual % pump, you can use the 

equation above by replacing the target pump with the effective or actual % pump. 

Note: You can use the calculation above in conjunction with the % Gain formula (shown below, 

which calculates the percent gain/pick-up) to verify amount of RI at the time of pumping. 

(pumped or treated) weight – green weight x 100 = % pump or pick-up 

green weight 

Alternatively, you could use the following variations to the equation on the previous page: 

lb. nitrite × 1,000,000 = ppm nitrite in the pickle 

lb. pickle 

ppm nitrite in the pickle × effective or actual % pump = ppm nitrite in the bacon 

IPP can use the steps in following table to determine if a proposed bacon processing procedure 

will produce product in compliance with the regulations. 

121 
 

 

 

Examp le 1 

IPP can use the steps in the following table to determine if bacon is in compliance at the time of 

pumping and/or massaging. The pickle formula in the table above will be used as the example 

in this table. 

STEP EXAMPLE 

1 Multiply the w e ight of the sodium n itrite by 2.5 lb. sodium nitrite x 1,000,000 = 

1 ,000,000 . 2 ,500,000 ppm nitrite . 

2 Divide this figure by the w eight o f the pickle 2 ,500,000 + 2 ,500 = 1000 ppm 

solution. njtrite in the pickle solution. 

3 Multiply this figure by effective or actual % 1000 ppm x 0.096 (9.6 % effective 

pump to obtain ppm. pump) = 96 ppm ingoing nitrite in 

the pork bellies . Product i.s in 

Refer to the How to Determine the Percentage compliance with the 2 0% ppm 

of Added Solution section prev iously allowance. 

discussed in this handout to learn how to 

det e rmine th e effective or actual % pump. 

Example 2 

Establishment 38 has a vat of uncured (green) bellies weighing 1,635 pounds. 

After pumping and draining the vat of bellies weighs 1, 782 pounds. The 

establishment's written bacon production procedure calls for using 1.2 lb. of 

sodium nitrite in a pickle weighing 1,000 lb. and a 10% pump. 

Step 1: Determine errective % of pump (use the added solution equation) 

1, 782 (treated W - 1,635 (green W) = 14 7 -e 1,635 (green W) = 0. 0899 x 100 = 8. 99% pump or 

9.0%pump 

Step 2: Determine ppm of Ingoing nitrite based on errectlve or actual % or pump (use the ppm 

equation from Table 1) 

ppm = 1.210. x 0.09 x 1000000 = 108 ppm (above 96 ppm which is the 20% variation) 

1,000/b. 

The establishment's process produces bacon that is in compliance for 

ingoing nitrite! 

Ingoing Nitrite at the Time of Pumping Determination 

Bacon Yield Determination 

In accordance 9 CFR 319.107, the weight of the pork bellies produced by pumping, immersion, 

massaging, or tumbling that are ready for slicing, packaging and labeling as “Bacon” must not 

exceed the green (fresh uncured) weight of the pork bellies. In other words, the weight of the 

cured pork bellies must return to green weight or their yield CANNOT be greater than 100%. 

FSIS does not routinely sample for added solution or ingredients; therefore, the determination of 

solution above the green weight is accomplished by the IPP’s in-plant % yield tests. IPP 

assigned to a bacon producing establishments will verify that the bacon yield is in compliance 

when performing %Yield/Shrink task. 

122 
 

 

 

Bacon Yield Determination Method 

Note: When determining yield and comparing green weight to pumped weight, it 

is not necessary to compare the same uncured pork bellies as long as a 

comparison is done on pork bellies produced under similar conditions and the 

subgroup (in this case all 100) are in the same weight range. 

Step 1: Use a subgroup such as 50 uncured (green) pork bellies of the same 

weight range (e.g., 10-12 pounds). Normally bellies are skinned and 

trimmed prior to pumping. 

Step 2: Determine total weight of 50 cured pork bellies that have: 

• Completed the chilling cycle as described in the establishment's 

processing procedure. 

• Previously undergone skinning/trimming prior to pumping. 

If any trimming or removal of any portion of pork bellies occurs after 

pumping/massaging, the weight of these trimmings must be added when 

determining the finished weight. 

Note: If the green weight must be calculated with the skin on, the finished weight 

figures must include the weight of the skin. 

Bacon Yield Determination Example 

Establishment 38 produces bacon. The IPP selects 50 chilled bellies from the cooler and has 

them weighed. The total green weight is 705 lb. The IPP selects 50 uncured bellies and has them 

weighed. The total finished weight is 717 lb. 

The percent of yield is: 

717Ib. x1QO =101 .7% 

705 lb. 

Remember that IPP are to determine whether product complies with the regulations based on 

production lots or process controls rather than on an individual % yield result. Although a % yield 

result of 101. 7 is above 100% before concluding there is regulatory noncompliance, the IPP 

should determine if the establishment is routinely conducting % yield tests. If so, when the 

average of the establishment's recent yield results is 100% or less, then there is no regulatory 

noncompliance. However, when the establishment's yield results also indicate a pattern or history 

of producing bacon with a yield above 100% or the establishment is not routinely conducting 

bacon yield determinations, then the % yield result of 101 .7 would be considered noncompliant. 

Calculation Equation 

Determine the yield by inserting the green (fresh, uncured) weight pork bellies and the finished 

weight (cured bellies ready for slicing) into this equation: 

Percent yield = finished weight × 100 

green weight 

Note: Finished weight is the weight of the meat and/or poultry plus the weight of any ingredients 

added during processing minus the weight loss (shrink) from smoking, cooking, cooling or dying. 

*** If you incur this situation discuss with your supervisor before making a determination. 

123 
Establishment 38 has recently expanded its production of cured product to 

include curing and slicing bacon. The establishment's pickle formula and written 

processing procedure on file is provided below. The Labeling-Product Standards 

task appears on the task calendar today. view the establishment's procedure 

chart and answer the questions related t s bacon processing procedure. 

Processing Procedure for Smoked Bacon 

s TYLE He-at Treated 

EST. I# _ __,3-,8'----- PRODUCT e;u;an W•lght R•ngos ....1.!!!ll_ 

BACON PICKLE FORMULA USUAL PROCEDURES 

SKIN OFF ..lL I SKIN ON - LB ozs % PUMP 12 

WATER 1990.30 LB. PRESSURE 60 

SALT 300.20 DRAIN TIME 30 minutes 

SUGAR (DEXTROSE) 150.30 TIME IN SMOKE 7-7.5 hOurs 

SODIUM PHOSPHATE 31 .25 S.H. HUMIDITY 70-75% 

NA nJRAL FLAVORINGS 14.00 SMOKEHOUSE TEMP 125-130°F 

SODIUM ERYTHORBA TE 11.45 BACON INTERNAL TEMP 126-128'F 

SODIUM NITRITE 2 .50 TIME HELD 1-7 Days 

% COOL.ER SHRINK 2-4% 

TOTALS 2500 

EST. REP. _____ ..... su..,, ... o..,,..,B,.,a,...g.,.93 ____ _ 

Bacon Calculations Workshop 

1. What is your first name? 

2. What is your last name? 

Based on the bacon pickle formula identified in the chart, calculate the ingoing parts per million 

(ppm) for: 

3. Sodium erythorbate 

a. 549.6 ppm 

b. 54.96 ppm 

c. 5.49 ppm 

4. Sodium nitrite 

a. 120 ppm 

b. 12 ppm 

c. 1200 ppm 

The establishment is producing bacon using the processing procedure above, so you decide to 

proceed to the pumping machine and select 50 pork bellies from lot 1A1 (weight range 10-12 

lbs.). The 50 bellies weigh 545 lbs. before pumping. After pumping, the same bellies weigh 

604.5 lbs. 

124 
 

 

 

Note: Base your calculations on the amount of sodium nitrite in the bacon pickle formula in the 

processing procedure above. 

5. The actual % of pump is: 

a. 10.9 % 

b. 1.09 % 

c. 109 % 

6. The ppm of ingoing nitrite (based on the actual pump) is: 

a. 109 ppm 

b. 10.9 ppm 

c. 1.09 ppm 

7. Will the pump procedure will produce bacon in that is compliance? 

a. Yes 

b. No 

The % Yield/Shrink task appears on the task calendar today. You select 50 uncured pork bellies 

from lot 2B3 (12-14 lb. weight range). The 50 pork bellies weigh 635 lb. (green weight). Then 

you select 50 cured/smoked bellies from the cooler. These bellies range in weight from 12-14 lb. 

each, and weigh 649 lb. The establishment does not routinely perform and document bacon 

yield determinations. 

8. The % yield is: 

a. 102 

b. 10.2 

c. 1.02 

9. Is the bacon in compliance with 9 CFR 319.107? 

a. Yes 

b. No 

125 
 

 

 

 

 

 

 

 

 

 

 

 

06 - Meat and Poultry Products with Added Solutions 

Objectives 

1. After completion of this module, the student will be able to: 

2. Identify some enzyme tenderizers that are approved for use on meat or poultry cuts. 

3. Describe how to perform the X percent (%) solution task. 

4. Determine when there is noncompliance with the added solution regulatory 

requirements. 

5. Given example problems, calculate the amount of a water-based solution (e.g. curing, 

marinating, or flavoring) added to both raw and cooked products to verify the percentage 

of solution in the product name designation is accurate and truthful. 

Introduction 

Water-based and oil-based solutions (curing, tenderizing, marinating, basting and flavoring) are 

added to raw meat and poultry cuts for several purposes. These solutions are added by 

pumping (injecting), tumbling, massaging, dipping, or immersing to impart favorable quality and 

sensory characteristics and add weight to the finished product. For instance, enzyme 

tenderizing solutions are often added to raw beef cuts from no-roll carcasses (i.e., a carcass 

that did not grade as prime or choice) or raw poultry cuts from mature birds to reduce the 

toughness of connective tissue in the cut. The proteolytic enzymes degrade several tissue 

proteins, including collagen and elastin, which are major constituents of connective tissue to 

improve tenderness. Curing solutions are added to meat and poultry cuts to impart specific color 

and flavoring, but they also serve to preserve the product for food safety and quality purposes. 

Marinating and basting solutions add unique flavors to the meat or poultry cut and also improve 

the texture of the cut. 

Solutions may be added to raw bone-in or boneless meat and poultry cuts at various amounts 

unless such use is not allowed or otherwise restricted by FSIS policy or regulation. Some meat 

and poultry products have a standard of identity which identifies the amount of solution allowed 

in the product. 

Added Solutions Requirements 

The Food and Drug Administration (FDA) approves all food safe for human consumption. FSIS 

additionally has an approval process for determining food ingredients and additives safe and 

suitable for use in meat and poultry products (9 CFR 424.21 and Directive 7120.1). FSIS 

additionally determines standards of identity for some products through regulations or as 

outlined in the Food Standards and Labeling Policy Book. Under certain circumstances, when 

establishments add solutions to meat and poultry products, these solutions must be declared on 

the label. 

Descriptive Designations - Raw Meat and Poultry Products 

Raw (not heated or cooked) meat and poultry products with added solutions that do not meet 

their standard of identity and raw meat or poultry products with added solutions that do not have 

a standard of identity are subject to the Added Solutions final rule in 9 CFR 317.2(e)2 and 

381.117(h). Since addition of solutions to meat or poultry products changes the nature of the 

product, the label needs to identify the percentage and composition of the solution. These 

regulations require establishments to inform the consumer that the raw product contains an 

added solution and make them aware of the ingredients in the solution. The standardized or 

common and usual name with a truthful descriptive designation distinguishes the product with 

the added solution from the standardized product. 

126 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

In accordance with 9 CFR 317.2(e)2 and 381.117(h), establishments must ensure the product 

name (standardized or common and usual) on the label contains a descriptive designation that 

includes: 1) the percentage of added solution (which must appear as a number and the percent 

symbol (%), 2), a declaration that may use the words “containing'' or “contains'' (such as, 

“contains 15% added solution of water and salt,” or “containing 15% added solution of water and 

teriyaki sauce”), and 3) the common or usual name of all individual ingredients or multiingredient components in the solution listed in descending order of predominance by weight. 

The product name and descriptive designation must be printed in a single easy-to-read type 

style and color, and must appear on a single-color contrasting background. The print may 

appear in upper- or lower-case letters with the lower-case letters not smaller than 1/3 the size of 

the largest letter. The product name may not include the word “enhanced.” 

Raw corned beef, corned beef brisket, corned beef rounds, other corned beef cuts and cured 

beef tongue have standards of identity in 9 CFR 319.100-103. Corned beef brisket (§319.101) 

can contain no more than 20% added solution. Corned beef (§319.100), Corned beef rounds, 

other corned beef cuts (§319.100) and cured beef tongue (§319.103) can contain no more than 

10% added solution. These products may contain up to the regulatory maximum percent curing 

solution (20% or 10%) without the presence of the solution being declared on the label. Verify 

these regulatory limits by calculation when you perform the %Yield/Shrink Task. When these 

beef products are treated with a solution at levels that exceed the regulatory limit, the presence 

and amount of the ingredients must be declared as part of the product name. The percentage of 

solution declared in the product name is the percentage of added solution above the green 

weight of the beef cut or part. “Corned Beef Contains Up to 35% of a Solution of Water, Salt, 

Natural Flavorings, Sodium Erythorbate, Garlic and Sodium Nitrite” would be an acceptable 

product name. Verify this percentage on the label using the X% Solution Task. 

X% Solution Task 

• IPP verify that the value inserted into the “X” is accurate for products labeled with a 

descriptive designation. For example. A descriptive designation could read, “Contains up 

to X% of ..” 

• The contains statement would refer to solution which has been marinated, injected, 

pumped, etc. 

• The X% solution task only verifies the label truthfulness as it pertains to the percent of 

added solution declared on the label. 

For raw meat and poultry products, the percent added ingredients for the descriptive 

designation is determined by subtracting the fresh (green) weight of the article from the weight 

of the finished product, (e.g., after being pumped or treated), dividing by the fresh (green) 

weight, and multiplying by 100. “Pumped or treated” refers to any method used to increase the 

weight of the raw meat or poultry, e.g., tumbling, vacuum tumbling, massaging, marinating, 

injecting, and dipping. 

The following formula is used to calculate X: 

[(pumped or treated) weight – green weight] x 100 = % added solution (ingredients) 

green weight 

Note: This equation is also used to calculate % Gain, as it is expressed in the Calculation Aid. 

127 
 

 

 

 

 

 

 

 

 

 

 

 

X% Solution Labeled Meat and Poultry Products - Raw Product Example 

Given - Product name on the label: “Corned Beef Brisket, Contains Up to 25% of a Solution of 

Water, Salt, Sodium Phosphate, and Sodium Nitrite” 

[(pumped or treated) weight – green weight] x 100 = % added solution (ingredients) 

green weight 

Step 1: Weigh the beef briskets. The weight of a steel tub of fresh uncured beef briskets 

weighs (less the tare) 127.8 lb. (This is the green weight.) 

Step 2: Weigh beef briskets after pumping. After pumping the same tub of beef briskets 

weighs (less the tare) 159.6 lb. 

Step 3: Subtract the green weight from the pumped weight 

159.6 lb. 

− 127.8 lb.

31.8 lb. 

Step 4: Divide weight difference by the green weight 

31.8 lb. ÷ 127.8 lb. = 0.2488 

Step 5: Convert the decimal answer to a %. 

0.2488 

× 100 

24.88% 

Since “up to 25%” added solution is declared in the descriptive designation in the product name, 

this product is in compliance. 

Tenderized Raw Meat and Poultry Products 

In some establishments, enzyme tenderizers, such as papain, bromelin, and Aspergillus oryzae 

(a mold) are used on meat and poultry cuts to degrade connective tissue proteins and improve 

the tenderness of the cut. They are applied to carcasses and cuts by direct application to the 

surface dipping, immersion or injection. The enzymes are activated when the meat or poultry cut 

is heated during cooking by the consumer. As the temperature rises, the enzymes are 

denatured and become inactive. 

Tenderizing agents that may be applied to raw meat and poultry cuts and their regulatory limits 

are identified in 9 CFR 424.21(c) and in FSIS Directive 7120.1. The regulation states that a 

solution consisting of water and a proteolytic enzyme (e.g., papain) applied or injected into the 

tissue of a raw meat or poultry cut shall not result in a weight gain (solution pick-up or pump) of 

more than 3% above the weight of the untreated cut (green weight). When proteolytic enzymes 

are used on raw meat and poultry cuts, the qualifying statement "Tenderized with (Approved 

Enzyme)” must prominently appear on the label. 

If an establishment produces a tenderized product with more than 3% added solution, it must 

have a descriptive designation for the amount above 3%. The percent solution reflected on the 

label for tenderizers is the actual percentage minus the 3% which is already allowed. For 

example, if the establishment added 20% of a flavoring and proteolytic enzyme solution to a 

meat or poultry cut, the name of the product must show that the product contains 17% added 

128 
 

 

 

 

 

 

 

 

 

 

 

solution in a descriptive designation that meets the requirements in 9 CFR 317.2(e)(2) and 

381.117(h). When a descriptive designation and the “Tenderized with (Approved Enzyme)” 

qualifying statement appear on the label, the “Tenderized with (Approved Enzyme)” may not 

intervene between the product name and descriptive designation. The product name may read: 

“Beef Skirt Steak, Contains Up To 17% Solution of Water, Natural Flavor, Salt, Spice, Sugar, 

Hydrolyzed Corn Protein, Spice Extract, Citric Acid, Sodium Lactate, Sodium Phosphate, 

Soybean oil, and Yeast Extract - Tenderized with Bromelin.” The “tenderized” qualifying 

statement may be incorporated into the descriptive designation, for example, “Beef Skirt Steak 

Tenderized and Flavored with 17% Solution of Water, Natural Flavor, Salt, Spice, Sugar, 

Hydrolyzed Corn protein, Spice Extract, Citric Acid, Sodium Lactate, Sodium Phosphate, 

Soybean Oil, and Yeast Extract.” 

When a descriptive designation and a product name qualifier (e.g., “Tenderized with Papain”) 

appear on the label, the Tenderized with Papain may not intervene between the product name 

and descriptive designation. The qualifying statement and descriptive designation can be 

combined. For example, “Beef Skirt Steak Tenderized and Flavored with 7% Solution of water, 

salt, spices, and papain.” 

Performing the X% Solution Task (for tenderized product) 

• IPP verify that the value inserted into the “X” is accurate for products labeled with a 

descriptive designation. For example. A descriptive designation could read, “Contains up 

to X% of...” For a tenderized product, the green weight has increased by more than 3% 

tenderizing solution. 

• Weigh a subgroup of meat or poultry before the tenderizing solution is applied. 

• Determine the maximum amount of tenderizing solution multiplying the green weight by 

0.03 (3%) 

• Weigh the same group of meat or poultry after tenderizing solution is applied 

• Compare the treated subgroup weight to the maximum treated product 

• Calculate the added solution using the formula then subtract 3%. This answer is the 

adjusted percentage that should be declared on the label. 

X% Solution Meat and Poultry Products - Raw Product - Tenderizing Agents (Enzyme) 

Example 

[(pumped or treated) weight – green weight] x 100 = % added solution (ingredients) 

green weight 

Product name - “Beef Skirt Steak Tenderized with Bromelain, Contains up to 15% Solution”. 

Before being treated, the skirt steaks weigh 200 oz., after being treated, the weight is 236 oz. 

Step 1: 236 oz - 200 oz = 36 oz 

Step 2: 36 oz = 0.18 x 100 = 18% 

200 oz 

15% was declared on the label. Subtract the 3% allowed - 18% - 3% = 15%. In Compliance. 

Note: The % Yield/Shrink Task is performed to verify that the amount of tenderizing solution 

does not exceed 3% above green weight. The label would not have an X% declared. Instead, it 

would just have the product name qualifier, e.g., “tenderized with...” The same formula would 

be used to make this determination. 

129 
 

 

 

Meat and Poultry Products Treated with Added Enzyme Solutions - Workshop 1 

1. What is your First Name 

2. What is your Last Name 

3. Which of the following enzyme is not approved for tenderizing meat and poultry cuts? 

a. protozoa 

b. Aspergillus oryzae 

c. bromelin 

4. The maximum pick-up of solution used for tenderizing purposes is (without 20% 

allowance): 

a. 1% 

b. 2% 

c. 3% 

5. The regulations do not require that proteolytic enzymes be approved if they tenderize the 

product. 

a. True 

b. False 

6. Untreated boneless chicken breasts weigh 160 lb. How much can the boneless chicken 

breasts weigh after being treated with a tenderizing solution (without 20% allowance)? 

a. 160 lbs. 

b. 164.8 lbs. 

c. 170.2 lbs. 

7. An establishment produces a product labeled “Beef T-Bone Steak, Tenderized with 

Papain.” While performing the % Shrink/Yield task, the IPP randomly selected 10 beef 

T-bone steaks to conduct an added solution or pick-up test. The untreated steaks weigh 

12 oz each. After the steaks are dipped in the enzyme solution, the same 10 steaks 

weigh 123.9 oz. The establishment does not implement a procedure for monitoring the 

amount moisture the meat and poultry cuts it tenderizes picks up. The percent solution 

pick-up is: 

a. 3.15% 

b. 3.25% 

c. Less than 3% 

8. Based on the answer to the previous question, the IPP would: 

a. Attach a U.S. Retained tag to all tenderized Beef T-Bone Steaks produced on the 

shift until the establishment takes corrective action. 

b. Weigh additional sample units as another verification pick-up test. 

c. Allow product to move freely. 

130 
 

 

 

 

 

 

 

 

 

 

 

 

Cooked or Raw Cured Pork Products 

Cooked and raw cured pork products covered by the cured pork products regulations (9 CFR 

319.104 and 105) have labeling schemes for indicating the presence of added solutions in these 

products listed in the regulation. For example, the presence and amount of added ingredients 

must be declared as part of the product name, e.g., "Ham and Water Product-- X% of Weight is 

Added Ingredients.” The percent of added ingredients in the finished product is inserted as the 

"X" value. 

Cooked Poultry Products 

Turkey ham cured and cooked has a standard of identity in 9 CFR 381.171 that requires the 

finished product weight to be no more than the original weight of the turkey thigh meat prior to 

curing. In accordance with the Food Standards and Labeling Policy Book (FSLPB), turkey ham 

weighing more than the original weight of the turkey thigh meat used prior to curing shall be 

descriptively labeled as "Turkey Ham,” with words that specify the amount of the additional 

ingredients, e.g., "and X% Water,” "With X% Water Added" or "Turkey Ham and Water Product 

X% of Weight is Added Ingredients". The ingredients of the added solution may be incorporated 

into the product name, e.g., "Turkey Ham and Water Product X% of Weight is Added Water, 

Salt, Dextrose, Sodium Phosphate, and Sodium Nitrite.” The X is filled in with a percent 

determined by subtracting the original weight of the turkey thigh meat from the weight of the 

cooked finished product. "Turkey Ham, Cured Turkey Thigh Meat, 12% Water Added" is an 

example product name. 

Added Solutions in Cooked Product 

The FSLPB provides requirements for cooked red meat products containing added substances 

and labeling prominence guidelines for cured, cooked products with added substances that do 

not return to green weight. 

Cooked Cured Beef and Pork Products 

Cooked cured beef products and cooked cured pork products not addressed by the cured pork 

products regulation (9 CFR 319.104), that weigh more than the weight of the fresh uncured 

article (green weight), may be prepared if they are descriptively labeled to indicate the presence 

and amount of the added solution. Acceptable product names include: "Corned Beef and X% 

Water" or "Cured Pork and Water Product, X% of Weight is Added Ingredients,” and "Beef 

Pastrami Contains Up to X% of a Solution.” The ingredients of the solution may accompany the 

product name or appear in locations prescribed for ingredient statements. If product name 

qualifiers, such as "X% of Weight is Added Ingredients," are used, the labeling prominence 

guidelines used for cured pork products as found in 9 CFR 319.104(b) apply. 

Cooked Uncured Meat Products 

Labeling requirements for uncured meat products to which solutions are added to impart flavor 

and other sensory characteristics then are subsequently cooked. It does not apply to solutions 

containing ingredients used to extend a product, such as isolated soy protein (ISP) and 

carrageenan. 

These products must be labeled to identify the amount and composition of solutions added. For 

a product to be truthfully labeled, a differentiation must be made from a cooked product (e.g., 

131 
 

 

 

 

 

 

 

 

 

 

 

 

 

Cooked Beef) that has had no solution added to it from a cooked product labeled with the same 

name (e.g., Cooked Beef) that has had solution added. Remember, meat and poultry products 

with added solutions that are heat treated or cooked are not subject to the Descriptive 

Designation for Raw Meat and Poultry Products Containing Added Solutions final rule. 

There are two allowable methods of providing descriptive labeling necessary to distinguish 

cooked meat products with added solutions from the traditional products without added 

solutions. 

Establishments may choose either of two labeling methods: 

Labeling Method 1 

When solutions are added to uncured meat products prior to cooking and return to equal to or 

less than the green weight after cooking, words such as "seasoned" or "flavored," are to be 

used to reflect that solutions have been added, e.g., "Seasoned Cooked Beef." While solution 

has been added, all the solution has been “cooked out.” (Verify this requirement while 

performing the General Labeling Task.) 

Labeling Method 2 

Uncured meat products that weigh more than the green weight after cooking must be labeled 

with a product name qualifying statement indicating the amount of solution remaining after 

cooking, e.g., “Contains X% of a Solution.” The ingredients of the solution may accompany the 

qualifying statement or appear in locations prescribed for ingredient statements, e.g., “After 

cooking, Contains X% of a Seasoning Solution of Water.....” The qualifying statement must be 

at least one-fourth the size of the largest letter in the product name. If the ingredients of the 

solution accompany the qualifier, they must appear in print at least one-eighth the size of the 

most prominent letter in the product name. 

For cooked products, the percent added solution for the label statement is determined by 

subtracting the fresh (green) weight of the article from the weight of the finished cooked product, 

(e.g., after injecting or marinating and cooking), dividing by the weight of the finished product, 

and multiplying by 100. 

X% Solution Labeled Meat and Poultry Products - Cooked Product Example 

(finished weight – green weight) x 100 = % added solution 

finished weight 

Product name - “Beef Pastrami Contains up to 10% of a Solution” 

Step 1: Weigh beef top rounds. The weight of a stainless-steel vat of fresh uncured beef 

top rounds weighs (less the tare) 161.4 lbs. 

Step 2: Weigh the top rounds after cooking and chilling. The same beef top rounds 

finished weight is 178.7 lbs. (less the tare). 

Step 3: Subtract the green weight from the finished weight. 

178.7 lbs. 

− 161.4 lbs. 

17.3 lbs. 

132 
 

 

 

 

 

 

 

 

 

 

 

----

Step 4: Divide weight difference by the finished weight. 

17.3 lbs. ÷ 178.7 lbs. = 0.0968 

Step 5: Convert the decimal answer to a %. 

0.0968 

× 100 

9.68% 

Since 10% added solution is declared in the containing statement. This product is in 

compliance. 

Performing the X Percent (%) Solution Task 

Inspection program personnel (IPP) perform the X percent (%) solution task in establishments 

that are producing meat or poultry cuts, parts, and products containing added solutions that are 

required to have the percent (X) of the solution identified in the product’s name to be truthfully 

labeled. 

When performing this task, IPP select an appropriate product and verify compliance with 

regulatory requirements by reviewing establishment records and labels, calculating the amount 

of solution added to the product and comparing the result with the regulatory requirement, when 

applicable. Compare the calculated amount of added solution with the X% declaration in the 

product’s name. 

IPP have the establishment weigh a subgroup (sample) or batch of product before and after the 

appropriate step in the process (pumping, injecting, dipping, or cooking and chilling). The 

number of pieces selected and weighed should be representative of the lot size. For example, 

the IPP may select 20 or 30 pieces of meat or poultry and have them weighed before the 

solution is applied (green weight) and 20 or 30 pieces after the appropriate processing step, 

e.g., pumping, dipping or cooking and chilling, and have them weighed (finished weight). After 

obtaining the subgroup weights (green and finished weights), perform a calculation to verify the 

percentage of solution (the value for the “X”) in the product name is accurate and truthful. 

To accurately determine the percent of the solution added to a raw product, IPP have to 

differentiate between an actual or effective percent pump or pickup. (This determination is not 

necessary for cooked products.) 

The actual percent pump or pick-up is the amount (pounds) of a water-based or oil-based 

solution (curing, tenderizing, marinating, etc.) pumped or injected into or picked up by a piece of 

meat or poultry that is not held for a period of time and allowed to drain prior to being further 

processed. This is expressed as a percentage of the weight of the meat or poultry before it is 

pumped with the solution. 

The effective percent pump or pick-up is the weight gained (expressed as a percent) by the 

meat or poultry after draining for the specified amount of time in the establishment’s written 

procedure and represents the amount of reactive solution that remains in the product. Any 

reactive ingredients (nitrites, phosphates, enzymes, flavors, etc.) in the solution are thought to 

remain in solution during the drain time after pumping, rather than reacting immediately with the 

meat or poultry protein. Therefore, using the effective percent pump in calculations more 

accurately reflects the ingoing amount of solution and reactive ingredients. 

133 
Weighing the same pieces of meat or poultry weighed before and after the solution application 

is the most accurate way to determine the percent added solution. 

Identification of the pieces of meat or poultry should be maintained. IPP may use another 

method to determine the percent added solution under certain circumstances, e.g., the scale 

and pumping or injecting apparatus are not in the same area or room. In this situation, IPP may 

select and have the pumped or treated pieces of meat or poultry weighed before selecting fresh 

unpumped or untreated pieces provided that the pieces are uniform in size and weight (e.g., 

lotted into 2-to-3 lb. weight ranges). The green weight is determined from different pieces of 

meat or poultry. All pieces selected must be in the same weight range. 

Compliance Determinations 

FSIS allows the added solution to be 20% above the X% solution declaration in the product 

name, before there is noncompliance, provided that the establishment does not have a history 

of (or is routinely) adding the solution above the percentage declared in the product name. For 

cured products with X% solution declarations, the establishment is allowed up to 20% solution 

above the percent declared in the product name, provided the establishment is not routinely 

adding solution above the percentage declared in the product name AND the added solution 

does not result in any restricted ingredient (e.g., cure agent) regulatory limit being exceeded. 

The 20% solution allowance relates to the truthfulness of the X% in the product name 

and not for other regulatory limits or product standards of identity. 

When the IPP’s added solution or pick-up test reveals that the product has gained more than 

3% tenderizing solution and there is no descriptive designation indicating the percent above 3% 

in the product name, he or she needs to determine if the establishment has data that 

demonstrates it is producing tenderized product in compliance with the regulatory limit. For 

instance, the establishment may be implementing a written program that includes conducting 

pick-up tests and the records show the process is still under control even though the IPP’s pickup test is over the regulatory limit. Normal variation in the process of tenderizing meat and 

poultry cuts may occasionally result in a solution pick-up test being over 3%. When the 

establishment does not have data that demonstrate control over the process of tenderizing meat 

and poultry cuts and the IPP’s pick-up test exceeds the regulatory limit, the IPP should retain all 

of the product on hand from that shift's production. 

Keep in mind that while many establishments have some type of quality control (QC) program, 

these are not required by regulation. IPP may exercise additional discretion when the 

establishment’s program is effective, and this data can be used as additional records. 

20% Allowance Example 

A Turkey Breast Tenderloin label reads..."Contains 10% Solution..." 

We know the product contains 10% solution and to figure out what 20% of 10% is, we first need 

to multiply 10% by 20%, which gives us 2%. 

10 % x .20 (20%) = 2% 

Then we add and subtract the 2% from the 10%, which give us 12% and 8%, respectively, to be 

within the 20% allowance 

10% + 2% = 12% 

10% - 2% = 8% 

134 
 

Noncompliance 

After performing the tasks, IPP are to use the GAD thought process to determine compliance. 

Examples of Noncompliance: 

• Label, solution formula or processing procedure is not on file. 

• LPDS temporary approved label is used beyond the expiration date. 

• Label requiring sketch approval by LPDS has not received sketch approval by LPDS 

• Missing mandatory feature, e.g., safe handling instructions or handling statement. 

• Missing product name qualifying statement 

• Solution ingredients not listed in the descriptive designation 

• Ingredients not listed in descending order of predominance in ether the descriptive 

designation and/or ingredients statement 

• Inaccurate ingredients statement 

• Any false or misleading information 

• A RI ingredient, e.g., nitrite exceeds the maximum amount allowed 

• The % solution declaration (X%) listed on the label is false or misleading (not truthful) 

135 
 

 

 

 

 

 

 

 

 

X% Solution Labeled Meat and Poultry Products Summary Workshop - Workshop 2 

Using the methods outlined in this handout, perform the required calculation to verify the X% 

solution label declaration is accurate and the product name is truthful. 

Scenario A 

You are a CSI assigned to an establishment that adds water-based tenderizing and flavoring 

solutions to raw meat and poultry products. When you arrive at the establishment, you log-on to 

your computer and bring up the task calendar in PHIS. The X Percent (%) Solution task is on 

the task calendar for today. You start the X Percent (%) Solution task by proceeding to the 

processing room. You know this establishment has a history of exceeding the regulatory limit for 

this added solution, therefore they are not given a 20% allowance. The establishment is 

applying a tenderizing and flavoring solution to beef skirt steaks. After the solution is added to 

the skirt steaks, the treated beef skirt steaks are moved to the packaging room and vacuum 

packaged in a plastic film with the pre-printed label below. 

The establishment uses a tumbler to mechanically agitate the tenderizing and flavoring solution 

into the beef skirt steaks. You notice beef skirt steaks in stainless steel containers and a plastic 

container of solution with the label staged next to the tumbler. You have the production 

supervisor move the stainless-steel containers and plastic container with the 

tenderizing/flavoring solution to the scale. After removing the tare weight of the containers, the 

beef skirt steaks weigh 199.5 lb. and the solution weighs 43 lb. The tumbler runs for 15 minutes, 

and the solution is completely absorbed, which makes the treated weight equal to the addition of 

the green weight and the weight of the solution. 

136 
 

 

 

111/lllll Lll 

1. What is your First Name 

2. What is your Last Name 

3. Calculate the percentage of solution added to the beef skirt steaks and select your 

answer. 

a. 21.55% 

b. 22.02% 

c. 17.00% 

4. Is the X% solution label declaration in compliance? 

a. Yes 

b. No 

Scenario B 

You are a CSI assigned to an establishment that adds water-based flavoring solutions to raw 

beef cuts that are subsequently cooked to produce roast beef, cooked beef and beef pastrami. 

The cooked beef products do not return to green weight; thus the finished beef products have 

an X% solution qualifying statement in the product name. When you arrive at the establishment, 

you log-on to your computer and bring up the task calendar in PHIS. The X Percent (%) Solution 

task is on the task calendar for today. You start the X Percent (%) Solution task by proceeding 

to the processing room. The establishment is pumping beef top rounds with a seasoning 

solution today. After the top rounds are cooked, they are sliced in the RTE product packaging 

room and the slices are vacuum packaged in 7 oz plastic trays that have the following label. 

137 
 

 

 

 

 

 

The establishment’s processing procedures attached to the label indicates that the beef top 

rounds are weighed and grouped into 10 to 12 lb. or 12 to 14 lb. weight ranges. The top rounds 

are pumped with 30% of a flavoring/seasoning solution. The top rounds are cooked in an oven 

for 2 to 2.5 hours based on the weight range to an internal temperature 145 degrees Fahrenheit 

for 3 minutes. The cook shrink is 8 to 9% and the chiller shrink is 2 to 3%. 

You have the production supervisor assist you in weighing 15 unpumped (green) top rounds 

from lot A2456. The 15 unpumped top rounds weigh 169.5 lb. The next day, before the top 

rounds are moved from the cooler to the RTE product room for slicing, you have the production 

supervisor assist you in weighing 15 cooked top rounds from lot A2456. These top rounds weigh 

214.6 lb. The establishment does not routinely monitor the amount of solution remaining (or the 

“X” % on the label) for its finished cooked beef product. The 20% allowance is not given. 

5. Calculate the percentage of solution remaining in the beef top rounds and select your 

answer. 

a. 26.60% 

b. 25.04 % 

c. 21.01 % 

You review the MOIs for the establishment and find that the previous three added solution tests 

for this product were above the 20% declared on the product’s label but were within the 20% 

solution allowance. Each time the IPP’s added solution calculation was above the percentage 

declared in the product name (20%), the IPP discussed the added solution result with 

establishment management at the weekly meeting. Each time the establishment stated it would 

adjust the pumping procedure. 

6. Based on the information you have gathered, is the establishment in compliance? 

a. Yes 

b. No 

138 
Antioxidants 

Baller/Breading 

Calculation Aid Menu 

Nel Weights 

Percenl Baller/Breading 

Beef Cheek Meat (lbof beef cheek meat known) Percenl Proteinaceous Ingredients 

Beef Cheek Meat (lb of beef known) 

Binders and Extenders 

Cure Accelerators 

Cure Agenls 

Fal Content 

Gain 

Maximum Amount of Poultry 

Minimum Meat or Poultry 

Projecled Finished Weight 

Shrink 

Shrink (dry cured porl< product) 

Volume of a Container 

X % Solution (uncooked product) 

X% Solution (coo~ed product) 

Yield 

Center for Leaming 

Click for TIJTOIUAL ij - Version 2.0 

I 

Attachment 1: Demonstrating the Use of the Calculation Aid 

Accessing the Calculation Aid 

Step 1: Click on the Start button (or Windows button) lower left corner computer screen 

Step 2: Click on FSIS Applications 

Step 3: Highlight and double click on Calculation aid in the menu 

139 
Antioxidants 

Batter/Breading 

Calcuilation Aid M e nu 

N et Weights 

Percent Batter/ Bread ing 

Beef Cheek Meat (lb of beef cheek meat known) Percent Proteinaceous Ingredients 

Beef Cheek Meat (lb of beef known) P rojected Finished Weight 

Binders and Extenders 

Cure Accelerators 

Cure Agents 

Fat Content 

Gain 

M aximum Amount o f Po ultry 

Min imum Meat or Poultry 

Contor for Lca..rning 

e 

Sh rink 

Shrink (dry cured pori< pro z u 

Volume of a Container 

X % Solution (uncooke product) 

X% Solution (cooked p roduct) 

Yield 

Clidc for TUTOIUAL 

04A02 - X% Solution 

(uncooked product) 

ij vension z.o 

(pumped, treated , or massaged) w eight - green weight 

green weight X 100 =% a dded 

ingredients 

pumped.treated, or massaged weigh! green weight 

1 1sa.s 1 127.8 

X 100 = 24.88 

127.8 % added ingredients 

green weight 

Colculote - Reset 

X% Solution Labeled Meat and Poultry Product

Raw Product Example Problem 

140 
(l) Macromedia Flash Player 7 

04A02 - X3⁄4 Solution 

(uncooked product) 

(pumped, treated, or massaged) weight - green weight 

green weight 

pumped.treated, or massaged weight green weight 

1 23s 1 - 200 

X 100 =%added 

ingredients 

X 100 = 18 

Calculate 

200 

green weight 

04A02 - X% Solution 

(cooked p1roduct) 

% added ingredients 

Reset 

finished weight - green weigiht x 100 =%added ingredients 

finished weight 

finished weight green weight 

178.7 161.4 

X 100= 

□ X 

9.68 

178 . 7 % added ingredlients 

fin,ished weight 

Calculate Reset 

Tenderizing Agents (Enzyme) Example 

X% Solution Labeled Meat and Poultry Product

Cooked Product Example 

141 
 

 

 

 

 

 

 

 

 

 

 

 

07 - Inspection Responsibilities 

Objectives 

After completion of this module, the student will be able to: 

1. Apply inspection methodology to determine when to write a noncompliance report. 

2. Take appropriate actions when product is economically adulterated or misbranded. 

3. Describe the IPP actions when there is repetitive noncompliance. 

Verification Methodology for NFSCP Tasks 

NFSCP tasks are performed to verify that meat, poultry, and egg products distributed to 

consumers are not economically adulterated or misbranded. As with other inspection tasks, IPP 

are to schedule the tasks on the dates most appropriate for performing the particular verification 

task. 

FSIS Directive 7000.1 provides IPP with guidance for verifying that an official establishment 

complies with consumer protection regulatory requirements that are not related to food safety. 

Attachment 1 in this directive identifies each PHIS NFSCP verification task, verification 

instructions for the task, regulatory references, and guidance documents. 

Before performing the NFSCP task, IPP are to review the regulatory requirements associated 

with the scheduled task listed in the attachment of FSIS Directive 7000.1. Regulations can be 

viewed using the Regulations Tab on the Inspection Results Page in PHIS. Always use the GAD 

thought process. 

When a NFSCP task is performed, IPP may gather information by conducting one or more of 

the following verification activities as appropriate for the task and product produced. 

• Observing the formulation of the product 

• Observing processing procedures 

• Examining product 

• Reviewing establishment records [9 CFR 320.1(b)(10) and 381.117(b)(6)] 

• Verifying the accuracy of product’s labeling 

• Checking product identification, condition and temperature 

• Performing a variety of other in-plant (hands-on) measurements, such as weighing 

ingredients, and calculating RI amounts. 

Products may have a standard of identity in the regulations or in the Foods Standards and 

Labeling Policy Book. Restricted ingredients are identified in 9 CFR 424.21 and FSIS Directive 

7120.1. Calculations may be necessary to verify regulatory requirements. Available calculation 

tools for IPP include The Processing Inspector’s Calculations Handbook (FSIS Directive 7620.3) 

and the Calculation Aid available on IPP’s computer. NIST Handbook 133 identifies the sample 

sizes for net weight compliance determination. 

If IPP identify a food safety concern while performing a NFSCP task, they should perform the 

appropriate food safety task as a directed task and follow instructions from FSIS Directive 

5000.1. Remember, IPP are not to perform directed NFSCP tasks unless they observe 

conditions or activities while performing a food safety verification task that gives them reason to 

suspect product has not met NFSCP regulatory requirements. 

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IPP assess all the information gathered and determine compliance by comparing what was 

observed to the relevant regulatory requirements. Compliance with most of the NFSCP 

requirements is based on production lots and assessing the establishment’s control of the 

process (e.g., applying accurate labeling, applying added solutions to products, applying an 

accurate net weight statement, or adding ingredients or meat and poultry components that meet 

the product’s standard of identity). 

Documentation and Enforcement 

Before making a determination that the establishment’s process is out of control, IPP consider 

all available sources of information (e.g., establishment records, and/or monitoring or testing 

results). IPP may exercise additional discretion when the establish has an effective quality 

control (QC) program. 

If the establishment has a QC program or control procedures, IPP should review sample size, 

sample frequency, control limits, recordkeeping practices, and the actions taken if the control 

limits are exceeded, observe employees implementing the procedures, and review 

establishment records. This information should be considered when determining if the 

establishment is maintaining control of its processes and meeting regulatory requirements. 

IPP are to consider any relevant factors when determining the amount of noncompliant product 

involved. Factors to be considered include factual information such as the establishment’s lot 

identification procedures, receiving records, and production records, as well as those facts that 

can be reasonably ascertained based on the average amount of product produced per shift or 

per production line. When necessary, IPP consult with their supervisor for assistance in 

determining the extent of product involvement. 

IPP are to orally notify the establishment and issue an NR when verification results reveal that 

product is not in compliance with a NFSCP regulatory requirement. When noncompliance is 

found, IPP take the appropriate regulatory control actions, such as retention of product, rejection 

of equipment or facilities, stopping lines, or refusing to allow the processing of specifically 

identified product (9 CFR 500.1(a), if it is determined that misbranded or economically 

adulterated product would otherwise enter commerce or be shipped from the establishment. 

Additionally, FSIS may rescind or refuse approval of false or misleading marks, labels, or sizes, 

or forms of any container for use with any meat or poultry product per 9 CFR 500.8. If it is 

determined that economically adulterated or misbranded product has entered commerce, FSIS 

may implement recall procedures. 

IPP should associate the NRs when noncompliances are related to the same process (e.g., the 

application of solutions to meat and poultry products) as described in FSIS Directive 5000.1. 

Notify the District Office (DO) through supervisory channels when establishment management is 

unwilling or unable to take necessary steps to re-establish control of its process. The DO may 

notify the establishment in writing that the repetitive noncompliances may lead to a regulatory 

control action (9 CFR 500.1-3) that would affect the entire production of the product in question 

because product may be economically adulterated or misbranded. 

The DO may notify the Office of Investigation, Enforcement, and Audit (OIEA) Regional 

Manager if there is a reason to believe that NFSCP noncompliances involve the shipment of 

economically adulterated or misbranded product or criminal intent to defraud the consumer. 

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