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PROCESS CATEGORY INTRODUCTION

Objectives

To demonstrate mastery of this module, the Inspection Program Personnel (IPP)

will:

1. Distinguish between the different HACCP processing categories.

2. Identify common hazards for all raw products.

3. Identify common hazards for other product categories.

4. Identify the raw product processing categories.

5. Identify common meat and poultry slaughter steps.

6. Identify common processing steps for intact and non-intact raw product.

7. Explain the food safety significance of non-intact product.

8. Identify common lethality for ready-to-eat product.

9. Identify amenable fish species and product types.

HACCP PROCESSING CATEGORIES

The HAACP regulations set out 9 processing categories in which finished product 

can be identified, 9 CFR 417.2(b)(1): 

(i) Slaughter—all species

(ii) Raw product—Non-Intact (ground)

(iii) Raw product—Intact (not ground)

(iv) Thermally processed—commercially sterile

(v) Not heat treated—shelf stable

(vi) Heat treated—shelf stable

(vii) Fully cooked—not shelf stable

(viii) Heat treated but not fully cooked—not shelf stable

(ix) Product with secondary inhibitors—not shelf stable.

In PHIS, these Processing Categories are further divided into Finished Product 

Categories. Both categories are based on the process for the shipped finished 

product. We discussed these categories during the Establishment Profile 

presentation, and additional information can be found in Directive 5300.1. 

Remember, Processing Categories are considered critical profile information in 

PHIS. This information directs the system to provide the proper tasks for that 

establishment and, to some extent, the correct sampling projects and 

frequencies. The IPP is ultimately responsible for determining the correct 

HACCP Processing Category for the establishment’s product. 
 

 

 

 

 
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Slaughter Processing Category

This HACCP processing category applies to establishments that slaughter 

livestock or poultry. Slaughter is the process whereby healthy, live animals are 

humanely stunned, bled, dehided, dehaired and eviscerated. The slaughter 

process has inherent food safety hazards that originate with the live animal. 

Therefore, the slaughter process has heightened food safety significance. 

Slaughter establishments typically produce carcasses which are raw intact 

finished products. The food safety hazards identified for the slaughter process 

are also common to the Raw Product Intact and Raw Product Non-Intact 

processing categories.

Common Hazards

Most of the food safety hazards inherent in raw processes originate with the live 

animals that enter the slaughter establishment. These hazards are common in 

all raw processes. Common hazards include the biological hazards of bacterial 

pathogens, the chemical hazard of allergens and residues, and the physical 

hazards of foreign material. These hazards could be present in raw product in 

any step of the food process. We will now address each of these three categories 

of hazards in more detail.

Biological Hazards

The following chart summarizes the common microbiological hazards in 

slaughter products: beef, lamb, pork, and poultry. 

Process 

Category

Species Biological Hazards, reasonably likely to be 

present and cause foodborne illness, denoted 

by "+” 

Salmonella STEC, including 

E. coli O157:H7

Campylobacter SRM

SLAUGHTER

Beef + + +

Sheep, 

Goat 

+

Pork +

Poultry + +
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Biological Hazards - Bacteria

The biological hazards of meat and poultry products result from the presence of 

pathogenic bacteria in and on the live animal or bird, including intestinal contents 

and exterior surfaces such as hide, hair, feathers, hooves and the 

gastrointestinal tract contents. Bacterial contamination of carcass surfaces is a 

detrimental consequence of processing animals and birds into meat and poultry 

for human consumption. The types of bacteria present on the live animal or bird 

will largely determine the bacterial population that exists on the carcass surface. 

Consequently, products derived from carcasses will contain the same types of 

bacteria present on the carcass surfaces. The establishment faces a challenge, 

in that the Slaughter, Raw Intact and Raw Non-intact processes do not include a 

lethality step. A lethality step is a procedure that would eliminate the bacteria or 

reduce the bacteria to an acceptable level. These establishments must control 

the hazard, or prevent it from entering the process. 

The prevalence of the pathogen Salmonella in beef, lamb, pork, and poultry 

carcasses varies greatly. The overall contamination of meat and poultry 

carcasses with these pathogens depends not only on the numbers of the 

pathogens on the hair, feathers, skin, and in the intestinal tract of the animals, 

but is also significantly affected by the degree of cross-contamination occurring 

from these sources during slaughter and processing. Establishment operators 

must adhere to pathogen reduction performance standards for Salmonella, as 

specified in 9 CFR 310.25 for livestock and in 9 CFR 381.94 for poultry. 

Escherichia coli is commonly found as part of the normal bacteria of the intestinal 

tract of humans and animals. Some strains, notably the Shiga toxin-producing 

E. coli (STEC) including Escherichia coli O157:H7, can cause serious illness in 

humans. Cattle may carry STEC in the intestinal tract at the time of slaughter, 

although it is actually harmless to these animals. Beef has been implicated in a 

number of foodborne illnesses associated with Escherichia coli O157:H7. 

Contamination with this pathogen can be reduced through the use of effective 

sanitary dressing procedures during slaughter and pathogen reduction 

intervention treatments. FSIS considers raw, non-intact beef products and raw, 

intact beef used to produce raw, non-intact beef products contaminated with 

STEC to be adulterated, unless the beef is further processed to destroy these

pathogens. 

Raw poultry is the major source of Campylobacter. Cross-contamination during 

raw poultry preparation and the consumption of inadequately cooked poultry 

appear to be significant sources of the human illness - campylobacteriosis. FSIS 

has conducted research about the prevalence of this organism and, as of FSIS 

Notice 54-12, September 11, 2012, announced new performance standards for 

Salmonella and Campylobacter.
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The following tables show examples for each of these biological hazards, the 

public health concerns associated with them, and some methods for controlling

these biological hazards. 

Salmonella

Disease 

symptoms

Causes infection (invasion of the lining of the intestine) with acute diarrhea, nausea, 

vomiting, abdominal cramps, chills, headache and fever. Occasionally, may cause blood 

stream infections and death. Frequency of death, 1-4%.

Source Fecal contamination of meat and poultry.

Transmission Primarily from consumption of raw or undercooked eggs, milk, meat and poultry. Infective 

dose can be as low as 15-20 organisms for immunocompromised individuals.

Controls Sanitation, proper hygiene practices. Killed by mild heat, effective antimicrobial treatments 

are acetic and lactic acids, acidified sodium chlorite, trisodium phosphate, and hot water 

or steam.

Characteristics  Grows at 41-115o F.

 Grows with or without air. Optimum growth at human body temperature. Grows very 

poorly at refrigeration temperatures.

 Survives well in frozen or dry foods. 

STECs including Escherichia coli O157:H7

Disease 

symptoms

Causes infection with bloody diarrhea (hemorrhagic colitis). Produces a potent toxin in the 

intestinal tract of infected people. May lead to hemolytic uremic syndrome, resulting in 

kidney failure and death, especially in children. Mortality rate as high as 50% in elderly.

Source Fecal contamination of beef.

Transmission Consumption of raw or undercooked beef. Age and immunity status will impact infective 

dose. As few as 10 organisms may cause illness.

Controls Prevention of cross-contamination. Killed by mild heat, effective antimicrobial treatments 

are acetic and lactic acids, acidified sodium chlorite, trisodium phosphate, and hot water 

or steam.

Characteristics  Grows with or without air. 

 Grows at 45-121o F; optimum temperature for growth is human body temperature.

 Grows in moist, low-acid foods. 

Campylobacter

Disease 

symptoms

Causes a 2-5 day infection with diarrhea, fever, abdominal pain, nausea, headache, 

muscle pain. May lead to nerve damage. Rarely causes death.

Source Fecal contamination of raw poultry

Transmission Cross-contamination from poultry or consumption of undercooked food. Infective dose is 

400-500 bacteria

Controls Sanitation, proper hygienic practices, effective antimicrobial treatments are acetic and 

lactic acids, acidified sodium chlorite, trisodium phosphate, and hot water or steam.

Characteristics  Sensitive to heating, drying, disinfection, acid, and air.

 Grows only in reduced oxygen environments.

 Grows at 86-113 o F 
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Biological Hazards – Other 

In addition to bacterial hazards, FSIS has taken a number of steps to ensure that 

the public does not receive product from animals that could have the Bovine 

Spongiform Encephalopathy (BSE) disorder or “mad cow disease.” As we 

discussed in the Food Microbiology module, BSE is a progressive neurological 

disorder of cattle that results from infection by a protein, called a prion. The 

potential food safety hazard is the contamination of meat product by BSE, which 

is at highest risk in the Central Nervous System (CNS) of cattle. High-risk 

tissues for BSE contamination, known as Specified Risk Materials (SRM), 

include tonsils and distal ileum for cattle of all ages. For cattle 30 months of age 

or older, additional SRMs include the cattle’s skull, brain, eyes, spinal cord, 

dorsal root ganglia, trigeminal ganglia, and sometimes the vertebral column. The 

direct or indirect intake of high-risk tissues may have been the source of human 

illness. SRM are inedible and prohibited for use as human food.

Specified Risk Material (SRM) 

Disease 

symptoms

Variant Creutzfeldt-Jakob disease (vCJD). Cases of vCJD present with psychiatric 

problems, such as depression. As the disease progresses, neurological signs appear 

including unpleasant sensations in the limbs/face, problems with walking and muscle 

coordination, forgetfulness, among others. Late in the course of the disease, patients are 

hospitalized until death. Disease is rapidly progressing and fatal.

Source Cattle Specified Risk Material (SRM)

Transmission Not well understood. The direct or indirect intake of high-risk tissues may have been the 

source of human illness

Controls §310.22 Removal of all SRM from cattle

Characteristics  Some prion types can survive dry heat at 600 ̊C for 15 min.

 Found mostly in the Central Nervous System (CNS) tissue and brain.

 Incapable of replicating itself. 

Common Controls for Slaughter - Biological Hazards

Establishments utilize a variety of controls to address bacterial hazards in the 

slaughter environment. Prerequisite programs and antimicrobial interventions 

are being used to control, eliminate or reduce microbial hazards in the slaughter 

process. While numerous antimicrobial interventions are used and effective, they 

are by no means to be used as a substitute for effective sanitary dressing 

procedures. 

Let’s look at the most common controls, using the beef slaughter process as our 

example for common livestock and the young chicken slaughter process as our 

example for poultry. 

Beef Slaughter - Antimicrobial Interventions

Knife trimming and carcass washing with plain water were historically the primary 

means by which the industry addressed meat contaminants. However, the 
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occurrence of foodborne disease outbreaks and scientific advances over the 

years have shown that trimming and washing alone will not achieve the level of 

food safety that regulators and consumers expect from meat products. In 

response to food safety concerns, the industry and scientific community, with 

encouragement from FSIS, have introduced numerous antimicrobial interventions 

to the beef slaughter process. 

Steam vacuum systems are designed to remove small visible spots of 

contamination from carcass surfaces. The system is a hand-held apparatus that 

uses a hot water spray in a vacuum nozzle, with steam sprayed above and below 

the vacuum head. The hot water sprayed onto a carcass kills bacteria and 

detaches contamination such as ingesta or feces, which is then vacuumed off. 

Many establishments utilize the steam vacuum system at multiple points in the 

slaughter process. For example, there may be a steam vacuum location after 

each of the carcass parts is skinned. 

After hide removal, the carcass may be subjected to a pre-evisceration wash 

and subsequent organic acid rinse. The use of a carcass spray immediately 

after hide removal serves to remove bacteria before they have the opportunity to 

attach themselves to the carcass surface and begin growing. The subsequent 

organic acid rinse then provides a significant kill step for any bacteria that remain 

on the carcass surface. This intervention is also commonly applied after the 

slaughter process is complete and before the carcasses enter the cooler. The 

organic acids commonly used are acetic and lactic, although citric acid is also 

approved for this purpose. The concentration of the organic acid is normally 

between 1.5% and 2.5% and it may be applied as a mist, fog, or a small droplet 

rinse. Studies have shown that washing followed by an organic acid rinse is 

significantly more effective in reducing bacterial numbers than washing alone. 

Acidified Sodium Chlorite has been shown to have a significant kill rate for E. 

coli O157:H7, Listeria, Campylobacter, Salmonella, and other bacteria. Applied at 

ambient temperature by spray, it is being used in several establishments across 

the country. 

High temperature water sprayed on the carcass (Hot Water Rinse) as the last 

step prior to chilling has been shown to be effective in substantially reducing the 

numbers of STEC and Salmonella. 

Steam pasteurization is a process in which the carcasses are placed in a 

slightly pressurized, closed chamber at room temperature and sprayed with 

steam that blankets and condenses over the entire carcass, raising the surface 

temperature (generally to 185o F) and killing up to 95-99% of all bacteria. 

Carcasses are then sprayed with cold water.
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Beef Slaughter – Other Biological Controls

According to §310.22, establishments that slaughter cattle and establishments 

that process the carcasses or parts of cattle must develop, implement and 

maintain written procedures for the removal, segregation and disposition of SRM. 

Such procedures must be in the HACCP plan, Sanitation SOP or other 

prerequisite program. FSIS expects that establishments which slaughter beef 

and process beef products would consider SRM in the hazard analysis. IPP will 

verify that establishments meet §310.22 and that they considered all potential 

hazards in the hazard analysis (§417.2(a)(1)).

In addition to the required SRM removal for cattle of all ages, establishments 

may also choose to reduce the risk of this hazard by only slaughtering and/or 

processing product from cattle younger than 30 months of age. Dentition 

programs may be used to determine or confirm the age of the cattle or 

certificates may be collected for establishments using carcasses and parts.

Poultry Slaughter – Antimicrobial Interventions

The poultry industry has historically depended upon knife trimming, chlorine, and 

water washing to address carcass contaminants. Scientific research has brought 

interventions to the young chicken slaughter process, which we will look at now. 

Many establishments have added antimicrobial carcass treatments in the form of 

sprays or dips, after the final carcass wash and prior to chilling. Some chemicals 

commonly used include the following:

Trisodium Phosphate (TSP) is used in many establishments as a drench, 

spray, or dip and has been shown effective in preventing the attachment of 

bacteria to the skin. It has been shown capable of reducing Salmonella

incidence. TSP has been approved for use in establishments using online 

reprocessing of contaminated birds.

Acidified Sodium Chlorite applied at ambient temperature by spray has been 

shown to achieve an average reduction in Salmonella prevalence of 27% and an 

average reduction of Campylobacter prevalence of 25%. It can be applied as a 

spray or dip, and has also been approved for use in establishments using online 

reprocessing of contaminated birds.

Chlorine used as a spray has been shown to produce a significant reduction in 

bacterial numbers. Hot water sprays, with or without chlorine, show a significant 

reduction in Campylobacter on carcasses. Several other chemicals have been 

investigated as antimicrobial additives to the chiller water (Chiller Treatments), 

but the most commonly used in practice are chlorine and chlorine dioxide. 

Chlorine is the most widely used sanitizer in poultry processing. Chlorine dioxide 

may be used in chillers. Both have been shown to control cross-contamination by 
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killing bacteria in the water and preventing their transfer from one carcass to 

another. Some poultry slaughter establishments use a system which injects 

ozone into the chill water tank in order to reduce the numbers of bacteria in the 

water.

On August 21, 2014, FSIS published the Modernization of Poultry Slaughter 

Inspection final rule. FSIS Notice 50-14 addresses how IPP are to verify 

compliance with approved online and offline reprocessing antimicrobial 

intervention systems. Establishments that slaughter poultry other than ratites are 

allowed to use these approved systems to clean carcasses accidentally 

contaminated with digestive tract contents (9 CFR 381.91). A list of approved 

systems is included as an attachment to this notice.

Poultry Slaughter– Other Biological Controls

As mentioned in the above paragraph, FSIS published the Modernization of 

Poultry Slaughter Inspection final rule in August, 2014. This rule does away with 

the previous time and temperature regulatory requirements for all ready-to-cook 

poultry, except ratites. Establishments must develop, implement and maintain 

poultry chilling procedures and incorporate these procedures into one of the 

following written documents: the HACCP Plan, the Sanitation SOP’s or a 

prerequisite program (9 CFR 381.66(b)(3)). Refer to FSIS Notice 51-14. 

Chemical Hazards - Residues

Animals may be presented at slaughter with violative levels of chemical 

residues. This hazard includes chemical residues resulting from use of, or 

exposure to, drugs, pesticides, and other compounds.

The most commonly affected types of animals presented for slaughter with 

chemical residues are bob veal (calves slaughtered at 21 days or less) and cull 

cows. These slaughter operations have historically had the highest rate of 

residue violations. For example, dairy cows may be given antibiotics by the 

producer to treat infections like mastitis, and failure to observe the required 

withdrawal time may result in violative residues. 

Common Controls

The best available preventive practices for control of violative residues include: 1) 

Ensuring that all animals brought into an establishment for slaughter are 

identified so they can be traced back to their producers, with receiving as a 

Critical Control Point; 2) Notifying animal producers in writing of residue findings, 

with such notification including (a) a discussion of the issues involved; (b) the 

company’s future expectations; (c) an indication that repeat violators will not be 

future suppliers; 3) Exploring possibilities for the establishment of state-certified 

voluntary residue avoidance programs comparable to those developed by major 
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producer trade organizations and require suppliers to participate in such 

programs and supply certifications to that effect; and, 4) Exploring the 

possibilities of live-animal testing so slaughter establishments could have a rapid, 

convenient verification tool. 

Chemical Hazards - Other

Other examples of environmental contaminants that may be consumed by 

animals include lead, cadmium, mercury, arsenic, dioxins, or polychlorinated 

biphenyls (PCBs). Industrial chemicals such as dioxins may be of concern 

because they have the potential to cause endocrine effects or interfere with the 

immune system. Some hazards such as lead contamination can affect a certain 

population - infants or young children - causing toxic effects. Lead, in addition to 

being a chemical hazard, may be a physical hazard which will be discussed 

below. 

Common Controls

Establishments may pay special attention to cattle, carcasses and parts received 

to avoid environmental chemical contamination. Since these hazards can come 

into the process from a variety of sources, establishments should be vigilant to 

control and prevent them in the product. Establishments may use programs to 

ensure only food grade ingredients and chemicals are being used in their 

processes, and have procedures to ensure. They may use a visual examination 

program in which employees examine product at different points, remove 

effected product, and document any findings and concerns.

Physical Hazards

A physical hazard is a physical component of a food that is unexpected and may 

cause illness or injury to the person consuming the food. Physical hazards, such 

as pieces of metal, sometimes occur because equipment has not been properly 

maintained. Product may be received that is contaminated by foreign material, 

which if not controlled, may subsequently become incorporated into the finished 

product. Foreign material would include non-animal objects such as metal, wood, 

rubber, glass, steel, lead, or other objects. For example, lead shot in a carcass 

may be considered by the establishment as a food safety hazard reasonably 

likely to occur in their operation, especially if the establishment historically 

receives animals containing such material. Another example might be a poultry 

operation that historically has a problem with metal shavings in its carcass 

chillers. Keep in mind that the foreign material we discuss here does not include 

things such as rail dust or rust, which would be covered by sanitation 

performance standards or Sanitation SOP requirements. The size, shape, and 

consistency of the foreign object should be considered in determining whether it 

is or is not a hazard. 
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Typical public health concerns associated with consuming products that contain 

physical hazards include broken teeth and damage, such as tears, to the mouth, 

esophagus, stomach, and intestines. These physical hazards may obstruct air 

passages or intestines. In some cases, death may result due to suffocation or 

infections (intestinal blockages). Small children are particularly susceptible to 

problems brought on by physical hazards since their body structures are smaller, 

and the physical objects may have a greater effect. 

Common Controls

Establishments may install metal detectors to identify and eliminate metal in 

product due to broken pieces of equipment or other metal items that enter with 

the live animal. Methods that establishments use to control physical hazards 

also include visual observation of product, sanitation procedures, standard 

operating procedures (SOP) for product handling, good manufacturing practices 

(GMP) to ensure proper maintenance and inspections of facilities and equipment, 

and foreign materials detection equipment (inline magnets, screens, traps, filters, 

etc.) used during the production process. 

 
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Common Steps in a Slaughter Process

- Beef Carcass as the example

We are now looking at an example of steps in the slaughter process using beef 

slaughter as an example. This is just to give you some familiarization to the 

slaughter process. This is only one example and is simplified from the flow 

diagram which follows. This process will vary from establishment to 

establishment. This example is more typical for highly mechanized, large. 

Smaller plants follow many of the same steps, but with fewer employees and less 

automated equipment. 

Receiving

Cattle are received, unloaded from trucks, and held in pens. Prior to slaughter, 

packers will usually require that animals be kept off feed to facilitate the dressing 

procedures. The amount of time animals are kept off feed will vary by 

establishment. The animals must have access to water at all times. 

Stunning

Stunning is the first step in the slaughter procedure. This must be done in a way 

that complies with the Humane Slaughter Act. You will learn more about this in 

your Humane Methods of Slaughter module. Most establishments use a 

mechanical method, such as a captive bolt, to render each animal completely 

unconscious with a minimum of excitement and discomfort. 

Sticking/ Bleeding

Sticking causes death, resulting from the rapid loss of blood (exsanguination). A 

sharp blade is inserted into the neck, severing the carotid arteries and jugular 

vein. Typically, this is done while the animal is hanging head down from the rail. 

These overhead rails or tracks move at a controlled speed so that the carcass 

advances through the various slaughter processing steps. 

Hide Removal

The next step is removing the hide. This may be achieved through various 

methods, either using mechanical equipment or by hand (at small operations). 

After the head and hide are removed, many establishments use anti-microbial 

interventions, as previously discussed. 
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Bunging

Bunging happens prior to evisceration. It entails severing the muscular 

attachments to the rectum so that it can be removed. It is important that it be 

secured to prevent contaminating the carcass with fecal material. 

Evisceration

Evisceration is performed to separate the internal organs from the carcass. Even 

in highly mechanized plants, this is still done by hand. It is important that 

evisceration is done properly so as not to contaminate the carcass with the 

contents of organs such as the stomach or intestines. Fecal material or stomach 

contents (ingesta) will contain many bacteria, and may possibly harbor certain 

harmful pathogens. 

Splitting

Next, the carcass is split with a saw. At the trim rail, an inspection reveals 

whether the carcass is free from contamination or quality concerns that can be 

removed by trimming.

Chill

In the next step, the carcasses are weighed and washed. They move to a chill 

box or cooler and chilled to a specified temperature. The chilling step helps 

inhibit the growth of microorganism. There are various methods and equipment 

used for chilling the carcass. Carcasses are typically stored in large refrigerated 

warehouses called coolers until they are shipped.
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Receiving 

Live Cattle

Stunning/

Bleeding

Head/Shank 

Removal

Skinning

Evisceration

Splitting

Trim Rail

Final Wash

Chilling

Packaging/Labeling

Finished Product

Storage (cold)

Shipping

Variety Meats

Production

Receiving 

Packaging 

Materials

Viscera

Processing

Storage 

Packaging 

Materials

SLAUGHTER FLOW DIAGRAM 

Example product: Beef (carcasses)
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Raw Product - Non-Intact Processing Category

This HACCP processing category applies to establishments that further process 

product by comminuting product, injecting product with solutions, or mechanically

tenderizing product by needling, cubing, pounding devices or other means of 

creating non-intact product. If the establishment produces bench trim or pieces of 

meat produced from non-intact meat, then the bench trim or pieces are also 

considered non-intact. It includes all raw products that are not intact in their final 

form. 

It is very important to understand and properly identify a product’s processing 

category both for FSIS sampling and PHIS establishment profile purposes. 

Understanding the way in which the establishment produces raw product will 

assist you in determining its appropriate processing category.

This processing category was previously referred to as Raw Product –Ground. It 

is important to note the changes from the old terminology. Products that formerly 

belonged to this category have changed as well. You may reference FSIS 

Directive 5300.1, April 11, 2011 Managing the Establishment Profile in the Public 

Health Information System (PHIS) for HACCP Processing Categories and 

Products as well as the 1999 Federal Register Notice 64 FR 2803. 

Non-intact product presents an increased food safety concern due to the 

spreading of pathogens throughout the product and pathogen penetration from 

the surface into the interior of the product. Among the non-intact products, beef 

products pose a heightened public health concern. Beef products pose 

increased risk of adulteration from Shiga-toxin producing E. coli (STEC), 

including E. coli O157:H7. A very small dose of consumed E. coli O157:H7 can 

result in severe health consequences, and consumers frequently consume beef 

after preparations that do not destroy this pathogen.

Beef, pork, veal, lamb, chicken, and turkey can all be further processed into nonintact product, then sold or used in other products. Some of the common 

products are bone in and boneless meats that are mechanically tenderized or 

injected. 

Mechanically Separated Product (MSP) is also considered raw non-intact 

product. The mechanical separation process is a way to obtain more usable 

product from bones from which the muscle has been removed. The species that 

can be used are lamb, pork, chicken, or turkey. Mechanically separated beef is 

not allowed.

Bones for this process have usually already had most of the muscle tissues 

removed by hand boning, or they are bones, like neck bones, which are difficult 

to process. The bones are ground up, and the resulting mass is forced through a 

sieve. The softer muscle particles are thus separated from the hard bone 
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particles, which remain behind the sieve. The resulting product has a paste-like 

consistency. 

Great pressure is used to force the product through the sieve, which results in a 

temperature rise in the product. Therefore, product must be processed quickly 

and the temperature immediately reduced in order to prevent oxidation and 

microbial degradation of the product. Even with these precautions, this product 

may deteriorate quickly. 

Although mechanically separated product has many of the characteristics of 

meat and may be used as a meat ingredient in the formulation of meat food 

products, it is not “meat” as defined in the regulations. In particular, the 

consistency of mechanically separated livestock product and its mineral content 

are materially different from those of meat. A certain amount of fine bone 

particles and bone marrow are incorporated as part of the process, increasing 

the calcium and iron content of the product. There are specific limits on the 

quantity and size of the bone particles that can be included in the final product. 

These limits can be found in 9 CFR 319.5 and 381.173 for meat and poultry, 

respectively.

A process similar to MSP is called Advanced Meat Recovery (AMR). This 

process obtains the meat tissues from the bones without including materials that 

are not normally expected in meat. The resulting product consists of distinct 

particles of meat, with the typical color and texture of the species used. 

Regulations (9 CFR 318.24) require that meat derived from AMR systems meet 

iron and calcium requirements. FSIS has established and enforced regulations 

that prohibit spinal cord from being included in products labeled “meat.” Because

Specified Risk Material (SRM) is considered inedible, these parts cannot be used 

for AMR.

Remember, the distinction between intact and non-intact product depends on 

whether the meat interior remains protected from pathogens migrating below the 

exterior surface and whether or not the depth of pathogen penetration is 

significant. 
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Common Hazards

Establishments must address common biological, chemical, and physical 

hazards as they pertain to and affect their non-intact raw product. 

Biological Hazards

The biological hazards in the non-intact raw product are mostly carried over 

from the slaughtered carcass. Establishments that further process raw products 

are dependent on their suppliers to eliminate or reduce microbial hazards 

because antimicrobial treatments and interventions are most practical when the 

product is still intact. 

Trichinae is a potential pathogen of concern in raw pork products. This pathogen 

is only of concern when the consumer doesn’t thoroughly cook pork products. 

Directive 7320.1 (8/6/2018) gives direction to IPP on how to verify the 

establishment is properly addressing trichinae as a potential hazard in their 

hazard analysis. It is of greater concern in feral swine, and NRTE pork products 

that may not customarily be thoroughly cooked. For more information, see FSIS 

Compliance Guideline for the Prevention and Control of Trichinella and Other 

Parasitic Hazards in Pork and Products Containing Pork (March 2016).

Chemical Hazards

Food allergies are responses of the immune system to naturally occurring 

proteins in certain foods that most individuals can eat without any adverse effect. 

Frequently such reactions occur because the presence of the allergenic 

substances in the foods is not declared on the food label. Evidence indicates 

that some food allergens can cause serious reactions in sensitive individuals 

upon ingestion of very small amounts, therefore, the presence of an ingredient 

that contains an allergen must be declared on the product label. There is 

scientific consensus that the following “big 8” foods can cause serious allergic 

reactions in some individuals and account for more than 90% of all food allergies. 

They are peanuts, soybeans, milk, eggs, fish, crustacean, tree nuts and wheat 

gluten.

Under the Federal Meat Inspection Act (FMIA), the Poultry Products Inspection 

Act (PPIA), and the Egg Products Inspection Act (EPIA), all ingredients used to 

formulate a meat, poultry, or egg product must be declared in the ingredients 

statement on product labeling. A product is misbranded under the Acts when it 

contains ingredients that are permitted, but are not declared on product labeling.

Establishments are responsible for ensuring that food is not adulterated or 

misbranded as a result of the presence of undeclared allergens. There may be 

situations where these substances are added intentionally to food, but not 
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declared on the label. Other situations involve substances unintentionally 

introduced into a food product and consequently not declared on the label. 

Physical Hazards

Establishments conducting processes such as needle injection or comminution of 

product regularly use equipment with numerous moving metal parts. If this 

equipment is not properly maintained, it can easily lead to metal contamination of 

product. 

Common Controls

Other Biological Hazards

Establishments producing non-intact raw product may require certificates from 

their suppliers or institute programs that ensure the slaughtering establishment 

has removed any SRM. They may also purchase only carcasses and parts of 

cattle less than 30 months of age. 

Chemical

Establishments producing non-intact product may use programs to ensure the 

safe handling, weighing, and use of ingredients of public health concern 

(allergens and ingredients that cause food sensitivities) in product and only 

antimicrobial agents listed in FSIS Directive 7120.1 are being used in their 

processes. They may also have procedures in place to ensure the safe handling 

and use of chemicals in processing areas. When an allergen is identified, the 

establishment should implement controls to prevent potential allergen cross

contamination such as dedicated equipment, separation, labeling, production 

scheduling, sanitation, or proper rework usage.

Physical

For physical contaminants, they may use a visual examination program in which 

employees examine product at different points, remove affected product, and 

document any findings and concerns. They may incorporate an enhanced 

equipment maintenance program as well.
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Common Steps in a Raw Non-Intact Process

- Ground Beef Patties as the example

Now let’s look at an example of steps in the raw non-intact process, using 

Ground Beef Patties as the example. This is just to give you some familiarization 

to a raw non-intact process. This is only one example and is simplified from the 

flow diagram which follows. This process will vary from establishment to 

establishment.

Receiving

Establishments receive raw beef and other components at the receiving step to 

produce the ground product. Raw components for beef patties could include 

advanced meat recovery products, boneless meat, trimmings of different fat 

content, meat from older animals, head meat, cheek meat, diaphragm meat, and 

esophagus. Low temperature rendered products such as lean finely textured 

beef (LFTB) and boneless lean beef tissue (BLBT) are derived from beef 

trimmings and may be used as components in raw ground beef and beef patties. 

Partially defatted beef fatty tissue (PDBFT) and partially defatted chopped beef 

(PDCB) are also low temperature rendered products derived from beef trimmings 

but they may only be used as components in raw beef patties. Meat ingredients 

used may be fresh or frozen, or a combination. Some of these raw meat 

materials have undergone several processing steps already and have the 

potential to have become contaminated. 

Sometimes non-intact products contain nonmeat ingredients. These products are 

often seasoned with salt, sugar, spices, or other flavorings. Depending on the 

product being made, water may be added, and some product formulations 

include binders and extenders such as soy flour or nonfat dry milk. 

Weighing

Establishments may use a formula to create a consistent product. The formula 

lists the weights or percentages of ingredients to be used. Meats and other 

ingredients are weighed before use to ensure that the proper amount of each is 

added. 

Comminution

Comminution is the process of reducing the particle size of meats. The grinder

consists of a hopper into which the meat chunks are placed. The meat then 

moves along an auger or screw, through a cylinder, at the end of which is a 

grinding plate and a knife. As the meat is pressed up against the plate, the knife 

turns and cuts off small bits of the meat. The size of meat particle produced is 

determined by the size of the holes in the grinding plate. 
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Other equipment can be used to achieve comminution. In addition to the grinder, 

establishments commonly use the flaker and the bowl chopper. Some producers 

use a combination of several of these in the production of a ground product. The 

flaker is used on large frozen blocks of meat or meat trimmings. Product is

pressed against the knife blades, which shave off pieces of the still-frozen meat, 

enabling it to be used in formulation without thawing. Another method of 

reducing particle size is the bowl chopper. This machine consists of a metal bowl 

that revolves and a metal knife that rotates, cutting through the meat pieces in 

the bowl. The bowl chopper also mixes product as it chops it. Sometimes meat 

ingredients go through several processes. Often, fat and lean meat ingredients 

are ground separately and then combined.

Mixing

Non-intact product is often transferred to a separate piece of equipment, called a 

mixer or blender, for integration. The mixer consists of a chamber that the 

ingredients are placed into, and blades or paddles that turn and mix the product, 

resulting in a more uniform distribution. Non-meat ingredients, if used, are added 

at this stage.

Shaping/ Patty Formation

Non-intact meat mixtures are often shaped into different forms. Hamburger or 

ground beef is often shaped into patties using a patty machine. 

Metal Detection

Because of the moving parts and high mechanical forces common in these 

operations, there is a possibility of metal chipping or breaking. Proper 

maintenance of equipment is essential to reduce this possibility. Some 

establishments use a metal detector to identify product that may be contaminated 

with metal fragments.

Packaging/ Labeling/ Distribution

After formation, and metal detection, the patties may be frozen. At this point the 

finished patties are packaged and labeled ready for storage and distribution. 
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Other steps and Considerations in Non-Intact Product

Tenderization

Tenderization is another procedure used in some establishments that produce 

non-intact products. All cuts can be tenderized, but this procedure is typically 

applied to less tender cuts of carcasses. There are several methods for 

tenderizing meat that produce non-intact product. These methods include the 

use of injected enzyme solutions and mechanical tenderization. Product that has 

been mechanically tenderized by needling, cubing, or pounding devices is

considered non-intact.

Whenever such cuts are made into a piece of meat, any bacteria on the surface 

of the meat, or on the equipment, will be spread onto the cut surfaces. This is 

particularly significant when many cutting blades or needles are inserted into the 

center of the meat, potentially drawing bacteria down from the surface. Nonintact beef steaks, specifically, have been subjected to processes that cause 

significant pathogen penetration such that customary cooking practices would not 

attain a time and temperature combination sufficient to destroy any potential E. 

coli O157:H7 throughout the product. 

Added Solutions

Non-intact meat and poultry products may have solutions added. The solutions 

may be added by injecting, also known as pumping, or by being tumbled with or 

without a vacuum. Any process which adds the solution using a process that 

could result in significant pathogen penetration from the surface of the product 

into the interior would be considered a non-intact product. Some of these 

products may be labeled as “marinated”, if they contain a maximum of 10% in red 

meat products and 3% for bone-in poultry/8% boneless poultry. If the solution is 

in excess of these percentages the term “% added solution” is required on the 

label. There are labeling policy memos available on the FSIS website if more 

detailed information is needed about product labeling. Some of these products

have proteolytic enzymes applied for tenderization; these ingredients are listed in 

9 CFR 424.21. 

Trace Back and Trace Forward

Establishments must purchase raw materials from suppliers that maintain 

producer records representing the source of their raw material. Establishments 

must also maintain records of distribution of products and are required per 9 CFR 

418.3 to maintain written recall procedures (See FSIS Notice 34-12). Some 

establishments have developed a production coding system for tracking 

purposes. These systems enable the establishment to track the product from the 

raw material source up to the finished product. 
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Rework

Rework is sound finished product that is reincorporated into a batch of fresh 

ingredients prepared to make similar finished product. Establishments also 

sometimes choose to develop a rework tracking system to reduce the amount of 

product that would be implicated in a recall. Some establishments include all 

rework at the end of the production day, or divert it to cooked product processing 

departments. There have been instances where a product recall was greatly 

affected by the establishment’s ability to track the use of rework. 
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RAW PRODUCT- NON-INTACT FLOW DIAGRAM

Example product: Ground beef patties

Receiving -

Packaging 

materials

Metal 

Detection

Freezing 

Packaging,

Labeling

Patty 

formation

Mix, 

Final grind

Weigh, 

Comminution

of Meat

Storage -

Meat

Receiving -

Meat

Storage -

Packaging 

materials

Storage,

Shipping,

Distribution

Storage -

Non-meat 

ingredients

Receiving -

Non-meat 

ingredients
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Raw Product – Intact Processing Category

This HACCP processing category refers to product that receives further 

processing directly after the slaughter processing steps or after receiving raw 

products. It includes all raw products that are intact in their final form. This 

processing category was previously referred to as Raw Product – Not Ground. 

Again, it is important to note the changes from the old terminology. Products that 

formerly belonged to these categories have changed as well. As previously 

stated, it is important to understand and properly identify a product’s processing 

category both for FSIS sampling and PHIS establishment profile purposes. 

Understanding the way in which the establishment produces raw product will 

assist in determining its processing category. See FSIS Directive 5300.1, April 

11, 2011 Managing the Establishment Profile in the Public Health Information 

System (PHIS) for HACCP Processing Categories and Products as well as the 

1999 Federal Register Notice 64 FR 2803. 

The processing steps at the establishment include the meat fabrication or poultry 

cut-up. If the establishment also slaughters, these steps are typically applied 

after the chilling requirements (9 CFR 381.66) are met for poultry carcasses, or 

after meat carcasses are cooled. 

Finished products such as raw poultry (in whole or in part) or raw meat products 

such as primal or subprimals are part of the Raw Product-Intact processing 

category. Beef manufacturing trimmings (e.g., pieces of meat remaining after 

steaks, roasts, and other intact cuts) are also an example of intact raw beef 

product. FSIS considers raw products to be intact unless they have undergone 

any of the processes previously discussed, associated with the Raw Product 

Non-Intact HACCP processing category. The distinction between intact and nonintact product depends on whether the interior remains protected from pathogens 

migrating below the exterior surface and whether or not the depth of pathogen 

penetration is significant. 

Common Hazards

The common hazards for raw intact product are the same as those identified in 

the Slaughter Processing Category. The common biological, chemical, and 

physical hazards in the intact raw product are mostly carried over from the 

slaughtered carcass. Establishments must address these hazards as they 

pertain to and affect their intact raw product.

Common Controls - Biological

In addition to the controls that may have already been used during the slaughter 

process, establishments commonly utilize additional antimicrobial interventions 

for pathogens of concern.
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Acidified Sodium Chlorite

Acidified sodium chlorite is an antimicrobial agent, effective against most of the 

pathogens of concern. Acidified sodium chlorite solutions are typically applied at 

ambient temperature as either sprays or immersion dips, directly to the surfaces 

to be treated, at 500-1200 ppm. Although it is most commonly used in slaughter 

operations, it is permitted for use on parts or trimmings post-chill with no 

requirements for treated product labeling. Products treated with acidified sodium 

chlorite that retain water would need to reflect this on the label. Use of acidified 

sodium chlorite results in significant reduction of all microbial species, for 

example, 2-log10 reduction for Escherichia coli O157:H7 and 1-log10 reduction 

for total aerobics.

Ozone

Ozone may be used in contact with food as a gas or liquid as an antimicrobial in 

meat and poultry products, including ground meats.

Irradiation

Food irradiation is the process of exposing food to radiant energy in order to 

reduce or eliminate bacteria. Ionizing radiation will reduce, and in some 

circumstances eliminate, pathogenic microorganisms in or on meat and poultry. 

The Food and Drug Administration (FDA) regulates all aspects of irradiation, 

what products it can be used on, what dose can be used, and how those 

products are labeled. Ionizing irradiation is recognized by FSIS as an approved 

additive in fresh or frozen, uncooked, packaged meat or poultry products for the 

purpose of reducing pathogenic microorganisms and extending shelf life. 

Irradiation does not significantly increase the temperature of food; product is still 

raw and requires refrigeration. 

Ionizing radiation penetrates into food, killing microorganisms. Treating product 

with irradiation could result in the significant reduction or even the elimination of 

certain pathogens. Ionizing radiation has been shown to be effective at 

eliminating Salmonella, STEC, Clostridium perfringens, Staphylococcus aureus, 

Listeria monocytogenes, and Campylobacter jejuni. 

 
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The “radura” is an internationally recognized symbol identifying irradiated food. 

The FDA requires that both this logo and a statement “treated with irradiation” 

must appear prominently on the label of packaged foods, and on bulk containers 

of unpackaged foods. 

Common Controls – Other Biological

Establishments producing intact raw product may require certificates from their 

suppliers or institute programs that ensure the slaughtering establishment has 

only sold them carcasses and parts of cattle with SRMs properly removed.

Common Controls – Chemical, Physical

Establishments may use programs to ensure the safe handling, weighing, and 

use of ingredients of public health concern (allergens and ingredients that cause 

food sensitivities) in product and only antimicrobial agents listed in FSIS Directive 

7120.1 are being used in their processes. They may also have procedures in 

place to ensure the safe handling and use of chemicals in processing areas. 

They may also use a visual examination program in which employees examine 

product at different points, remove effected product, and document any findings 

and concerns.

When an allergen is identified, the establishment should implement controls to 

prevent potential allergen cross contamination such as dedicated equipment, 

separation, labeling, production scheduling, sanitation, or proper rework usage.
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Common Steps in a Raw Intact Process

- Beef Trimmings and Roasts as the example

Let’s look at an example of steps in the raw intact process, using Beef Trimmings 

and Roasts as the example. This is just to give you some familiarization to a raw 

intact process. This is only one example and is simplified from the flow diagram 

which follows. This process will vary from establishment to establishment.

Receiving

The first step in these processes is typically receiving. Carcasses or primal and 

subprimal parts are received either from other establishments, or from the 

slaughter department. After meat ingredients are received, they are stored in 

freezers or coolers until use. Any packaging materials or ingredients, if used, are 

also received and stored prior to use. 

Prerequisite Programs or Other Written Purchase Specifications are 

developed by some establishments to ensure that a safe and consistent product 

is received. Specifications are formal agreements between the supplier and the 

purchaser, and may include quality aspects, such as portions of lean and fat, and 

safety factors such as laboratory testing for pathogens. 

Refrigeration achieves several purposes. Carcasses are chilled after slaughter 

for a specified period, allowing them to become firm enough to cut. Refrigeration 

reduces moisture loss from the product. It slows down metabolic and enzymatic 

activities within the meat tissues that would lead to product deterioration.

Refrigeration is also an important food safety factor. It slows the growth of 

microorganisms, including spoilage bacteria and pathogens. Continuous 

refrigeration is essential to control microbial growth. The temperature and the 

holding time of the raw materials affect the multiplication of microorganisms. 

Meat products must be maintained at refrigeration temperatures adequate to 

control spoilage and growth of pathogens.

Chiller or cooler temperatures substantially retard most pathogen growth. Chiller 

storage is temporary because even at these temperatures the spoilage 

organisms will continue to grow, although at a very slow rate. Freezers halt the 

growth of all bacteria. Product kept frozen will maintain safety and quality for 

longer periods of time.

Fabrication

Fabrication refers to creating the various cuts from the carcass to produce 

particular types of product. Primal or wholesale cuts are made first. Their names 

usually identify where the meat comes from on the animal, such as the loin, the 
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shoulder, etc. The establishment typically uses large mechanized saws to 

fabricate the carcass into primal cuts. 

Retail cut names tell what part of the primal cut the meat comes from, for 

example, rib roast or round steak. Retail cuts may be made with a saw, 

especially if they include bone. Primal parts are often boned before cutting into 

retail cuts, in order to produce boneless items. Establishments that produce 

portion-controlled retail cuts for hotels, restaurants, and institutions are often 

called HRI operations.
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Marination 

Marination is the process of combining a liquid solution with the meat or poultry 

product. Products are marinated to improve taste, tenderness, color, juiciness, or 

other sensory attributes. Products that are “still” marinated are considered intact 

as long as the process does not cause significant pathogen penetration into the 

products’ interior. Some examples of ready-to-cook marinated products include 

lemon-herb flavored boneless chicken breast, beef strips for fajitas, or seasoned 

pork roast. 

Packaging

Packaging materials protect the product from damage during refrigerated or 

frozen storage. Product may be packaged into retail size packages, into larger 

containers for institutional use, or into bulk containers for sale to other 

establishments for further processing. Modified Atmospheric Packaging (MAP) 

systems are commonly utilized to maintain product wholesomeness. MAP 

systems introduce carbon monoxide into the package which also provides 

greater flexibility with distribution and reduces shrinkage of the meat. Sodium 

nitrite may be used inside packaging film at this step to maintain color. Intact 

cuts may also be sprayed with antimicrobials to aid in controlling bacteria. 

Although there are many different combinations of packaging materials in use, 

plastic films and cardboard boxes are some of the materials commonly used.

Distribution

The final step is distribution, either to other departments in the same 

establishment, or to other establishments or retail markets. 

Other Common Steps not included in the Diagram

Aging

Some establishments age meat to tenderize it and improve taste and texture. 

This is generally done with higher quality cuts used for steaks. Aging is done in 

temperature and humidity controlled coolers for various lengths of time.

Curing

Curing refers to the addition of certain additives to preserve the product and 

stabilize the color, most commonly salt and/or nitrite. The amounts of nitrite and 

the less commonly used nitrate are restricted by FSIS regulations; thus they are 

often referred to as “restricted ingredients.” These cure ingredients are 

sometimes mixed with water to form a curing solution, or “pickle,” before adding 

them to the meat or poultry products. Beef products that are immersion cured or 
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have the cure solution massaged or tumbled into the product without a vacuum 

are considered intact because the actions of these processes do not typically 

cause significant pathogen penetration into the products’ interior. An example of 

uncooked, cured product may include corned beef briskets.

Edible offal

Edible offal is produced as a byproduct of the slaughter process. They may be 

sold as fresh or frozen items, or used to make other processed foods. Here are a 

few examples.

 Casings for sausages are sometimes made from sheep, hog, or beef 

intestines (distal portion of ileum removed as specified risk material (SRM) 

for beef). 

 Blood is used as an ingredient of certain specialty products.

 Sweetbreads are thymus glands obtained from the ventral side of the 

neck and inside the chest cavity of young cattle. 

 Hearts, livers, and tongues are sometimes used in the production of 

processed products.
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Receiving 

Packaging 

Materials

Receiving 

Carcasses

Storage

(Cold)

Carcasses

Storage 

Packaging 

Materials Fabrication of 

Beef Cuts, 

Roasts

and/or 

Beef Trimmings 

Beef Cuts, 

Roasts

Marination

Packaging/

Labeling

Finished 

Product 

Storage 

(Cold)

Shipping

Beef 

Trimmings

RAW PRODUCT- INTACT FLOW DIAGRAM

Example product: Beef Trimmings and Roasts 
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Workshop: Common Hazards for Raw Product

1. For each of the following biological hazards, list the temperature growth range 

from the information in the module. Looking over the list, what conclusion can 

you make about the value of refrigeration in the control of these hazards?

Organism Temperature Growth 

Range

Salmonella

E. coli O157:H7, STEC

Campylobacter

Conclusion:

2. Which biological hazard is regularly present in cattle, and therefore is often 

considered a food safety hazard in beef processes?

3. Which biological hazard is associated with all food animal species?

4. What are the sources of biological hazards in the slaughter process?

5. What are some examples of potential chemical hazards in the slaughter 

process and what type of animals are most often found to have violative 

chemical levels?

6. What are some examples of potential physical hazards in the slaughter 

process?
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Thermally Processed-Commercially Sterile Processing Category

This processing category includes canned meat products, some products 

processed in pouches and semi-rigid containers. Common examples are stew, 

chili, soup, canned hams, Vienna sausage, hash, potted meat product, and pasta 

sauce with meat. Although there are several types of packaging options 

available, such as pouches, plastic cups and plastic trays, the metal can is still 

the most common package used. For this reason, these products are usually 

referred to as “canned”. These products undergo a heat treatment (thermal 

process) while inside a specially sealed container which makes them ready-toeat.

Thermally processed product and its process are discussed in great detail in the 

2-week Thermal Processing Course. If you are assigned to an establishment 

that produces this type of product, you will attend this special training.
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Not Heat Treated - Shelf Stable Processing Category

This process category applies to products that are further processed by a curing, 

drying, or fermenting step as the sole means by which product achieves food 

safety. We will discuss the steps, products and hazards further in the Ready-toEat/ Shelf Stable (RTE/SS) module. A low-level heat treatment may be applied, 

as long as the heat treatment is not used as the sole means to achieve food 

safety. The finished products produced are shelf stable. Since these products are 

shelf stable, they don’t have to be frozen or refrigerated for food safety purposes. 

Several products (not all) in this HACCP category are considered ready to eat (9 

CFR 430.1), meaning they can be consumed as packaged, safe for the 

consumer to eat without refrigeration or further processing. 

Products in this category typically include dried sausage, such as salami and 

pepperoni. Semi-dry sausages may also be in this HACCP category, depending 

on the process steps. Dried whole muscle products which are mostly dry cured 

could also fall into this category. These products include dried hams, such as 

prosciutto, parma and country ham, and dried intact pieces of meat such as dried 

pork bellies (Pancetta), dried pork shoulders (coppa), and dried beef rounds 

(bresaola, beef prosciutto, basturma). Products in this category could sometimes 

also be categorized in the Heat Treated Shelf Stable processing category, due to 

the methods by which it is made. 

Again, the primary consideration in determining the processing category for these 

products is how food safety is achieved.

Common Hazards and Controls

Biological hazards which are common to these products differ from raw 

products. The lethality step(s) in these products kills the pathogens (e.g., 

Salmonella, Campylobacter, Listeria monocytogenes, and E. coli O157:H7) 

which may otherwise be present in the raw materials. However, there are other 

biological hazards of concern as a result of the different ingredients and process 

steps these products may undergo. 

Similar to a cooking step, these products undergo a step, multiple steps, or a 

process that eliminates or reduces biological hazards to an acceptable level. 

Such a step, steps or process is referred to as lethality. The lethality step(s)

addresses the common biological hazards which would otherwise be present in 

the product in its raw state.

Listeria monocytogenes (Lm) is also a potential biological hazards that may recontaminate the product. This could happen after lethality if products are 

exposed to food contact surfaces, raw products or contaminated ingredients prior 

to final packaging. The establishment may choose to control pathogenic 
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recontamination in a number of ways. To address Lm, the establishment could 

apply treatments or processes after lethality to kill any surviving pathogens of 

concern, in addition to executing additional sanitation procedures in the 

processing environment. 

While this product may undergo a mild heating step, this step would not include

elevated temperatures. Stabilization (cooling) is not a concern because the 

combination of acid and reduced moisture controls Staphylococcus aureus and 

Clostridium spp.

Common chemical hazards include allergens, such as soy or milk byproducts 

which may be used as ingredients. Lactic acid or acetic acid may be used to 

speed acid formation. Nitrites are commonly used as part of the curing process 

and phosphates might also be used for binding, flavor and/or color. Allergens 

and nitrite could be hazardous if not handled properly and used in proper 

measurements. The establishment may utilize procedures and programs to help 

prevent and control these hazards. 

There are no notable physical hazards unique to this process category. 

Like non-intact raw products, metal contamination from equipment with small and 

moving parts could pose potential physical hazards as well. As mentioned 

previously, establishments may install metal detectors to identify and eliminate 

metal in product due to broken pieces of equipment or other metal items that 

enter with the live animal. Methods that establishments use to control physical 

hazards also include visual observation of product, sanitation procedures, 

standard operating procedures (SOP) for product handling, good manufacturing 

practices (GMP) to ensure proper maintenance and inspections of facilities and 

equipment, and foreign materials detection equipment (inline magnets, screens, 

traps, filters, etc.) used during the production process. 
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Common Steps for a Not Heat Treated Shelf Stable Process

- Pepperoni as an example

Receiving/ Weighing/ Mixing/Stuffing

Raw meat ingredients are received, ground and mixed with non-meat 

ingredients. An ingredient important to this process, but not previously discussed 

is the starter culture. The starter culture is important in ensuring a predictable 

and consistent lethality. It consists of a blend of non-pathogenic bacteria that 

help to increase the acidity of the product. The meat mixture is stuffed into

casings.

Fermentation

This step is very important for pathogen control. During this step, the acidity of 

the product is increased by time, temperature and the starter culture activity. 

The product is held in an environment optimum for this process. Temperature 

and humidity are carefully monitored to ensure the starter culture bacteria 

actively reproduce, which produces acid and increases acidity. The acid needs to 

be produced quickly to inhibit pathogens, such as toxin-producing 

Staphylococcus. The pH is monitored to measure acidity and determine when 

the process is complete. 

Drying

At this stage, the salami/pepperoni is hung in a dry room to dry. Temperature,

humidity, and moisture which directly affect microbiological growth, is controlled. 

The product must be dried to the point at which harmful bacteria are inactived or 

destroyed in order to create a safe, shelf stable product. 

Slicing/Peeling

Some product is sliced so that it can be used for purposes such as sandwiches, 

pizza, or salads. This is a step where re-contamination can occur.

Packaging/Labeling

At this point the finished sausage sticks are dry and ready to be packed for 

storage and distribution. 

This process category contains all products that are shelf stable, which may or 

may not have been heat treated. These products are rendered safe by a 

combination of processes, such as fermentation, heating, and drying.
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Receiving 

Packaging 

Materials

Receiving 

Raw Meat

Receiving 

Restricted 

Non-meat 

Ingredients

Receiving 

Unrestricted 

Non-meat

Ingredients

Storage 

Packaging 

Materials

Storage 

Weighing 

Receiving 

Starter 

Cultures/

Casings

Storage 

Weighing

Storage

(Cold – Frozen/Refrigerated) 

Raw Meat

Tempering 

Frozen Meat

Weighing 

Raw Meat

Combine Ingredients/

Processing:

Chopping

Grinding

Mixing

Stuffing

Forming

Preparing Storage 

Fermenting 

Drying 

Slicing/Peeling 

Packaging/Labeling 

Finished Product Storage 

Shipping 

Heat 

(optional)

NOT HEAT TREATED- SHELF STABLE FLOW DIAGRAM

Example product: Pepperoni
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Heat Treated- Shelf Stable Processing Category

This process category applies to product that receives further processing by 

using a heat treatment in combination with a curing, drying, or fermenting 

process step to achieve food safety. The heat treatment is the primary means of 

achieving lethality. Finished products produced under this processing category 

are safe to eat without refrigeration or further processing. This processing 

category typically includes popped pork skins, bacon bits, snack sticks or jerky, 

summer sausage, Lebanon bologna, thuringer, kippered beef, pickled sausages 

and rendered products. Rendering refers to the extraction of edible and inedible 

fats and oils from meat after slaughter. The rendering process can be either wet 

(usually through steam) or dry. It yields products such as tallow and lard. 

These products are considered ready to eat (9 CFR 430.1), meaning they can be 

consumed as packaged. The finished products produced are shelf stable. Since 

these products are shelf stable, they don’t have to be frozen or refrigerated for 

food safety purposes. These products are considered ready-to-eat, meaning they 

.can be consumed as packaged, safe for the consumer to eat without 

refrigeration or further processing. Products in this category could sometimes 

also be categorized in the Not Heat Treated Shelf Stable processing category, 

due to the methods by which the product is made. 

Common Hazards and Controls

These ready-to-eat products, like the Not Heat Treated Shelf Stable products, 

undergo steps which achieve lethality in the product. Like those products, there 

are other biological hazards of concern as a result of the different process steps 

and procedures these products undergo. Potential biological hazards include 

Listeria monocytogenes, which may re-contaminate the product after lethality. 

Although this product does undergo an elevated heating process (typically 

cooking), stabilization (cooling) is not a concern because the combination of acid 

and reduced moisture controls Staphylococcus aureus and Clostridium spp.

Common chemical hazards include allergens, such as soy or milk byproducts 

which may be used as ingredients. Chemical accelerants, acidifiers and antioxidants may be used as part of the fermentation process or assist in the quality. 

These could pose hazardous if not used in proper measurements.

There are no notable physical hazards unique to this process category. 

However, like non-intact raw products, metal contamination from equipment with 

small and moving parts could pose potential physical hazards as well. As 

mentioned previously, establishments may install metal detectors to identify and 

eliminate metal in product due to broken pieces of equipment or other metal 

items that enter with the live animal. Methods that establishments use to control 

physical hazards also include visual observation of product, sanitation 
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procedures, standard operating procedures (SOP) for product handling, good 

manufacturing practices (GMP) to ensure proper maintenance and inspections of 

facilities and equipment, and foreign materials detection equipment (inline 

magnets, screens, traps, filters, etc.) used during the production process. 
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Common Steps for a Heat Treated Shelf Stable Product

- Jerky as an example

Receiving/ Weighing/ Mixing/Forming

Jerky may be made from solid pieces of whole muscle or chopped product at 

receiving. Many of the processing steps are similar to the processes we have 

already discussed. Raw meat ingredients may be sliced or ground, ground 

product is formed into strips.

Brine/Cure/Marinate

The strips may be mixed or tumbled with brine, cure and spices and/or marinated 

in a solution with salt, sugar and flavoring ingredients.

Cooking 

Cooking the product for a specified time and temperature with relative humidity is 

designed to eliminate pathogens and control bacterial growth. The cooking

process also helps to shorten the drying time.

Drying

The drying step helps to further reduce the moisture and water activity in the 

product to the safe and desired level. Reducing the moisture helps control 

harmful bacteria such as Staphylococcus aureus. Water activity (available 

moisture) of the product is the primary factor affecting shelf stability and safety. 

Packaging/Labeling

These products may be stored and shipped at frozen, refrigerated, or at ambient 

temperatures. Storing product below ambient temperature is usually done for 

quality reasons.
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Receiving 

Packaging 

Materials

Receiving 

Raw Meat

Receiving 

Restricted 

Non-meat 

Ingredients

Receiving 

Unrestricted 

Non-meat

Ingredients

Storage 

Packaging 

Materials

Storage 

Weighing 

Storage 

Weighing

Storage

(Cold – Frozen/Refrigerated) 

Raw Meat

Tempering 

Frozen Meat

Weighing and 

Slicing Meat

Combine 

Ingredients/

Processing

(Chopping

Grinding

Mixing

Forming)

Marination/Cure

Packaging/Labeling 

Finished Product Storage 

Shipping 

Cook/Heat Treatment

Drying 

HEAT TREATED- SHELF STABLE FLOW DIAGRAM

Example product: Jerky 
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Fully Cooked - Not Shelf Stable Processing Category

This process category applies to establishments that further process products by 

using primarily a full lethality heat process step (e.g. cooking) to achieve food 

safety. These products have been processed in a manner that makes them safe 

to eat, with no further preparation required by the consumer. However, the 

finished products that establishments produce under this process category are 

not shelf stable. These products must be frozen or refrigerated throughout their 

shelf-life to maintain product safety. These products also meet the definition of 

Ready to Eat (RTE) product, as defined in 9 CFR 430.1.

Please note, however, that many of these products are customarily eaten hot, 

and the establishment may choose to include cooking or reheating instructions 

may on the label. (This does not affect how FSIS classifies these products into 

this processing category.)

There are many different types of products that fall under this category. Deli 

meats such as ham, roast beef, and smoked turkey breast all have very similar 

processes. These products are produced by adding a solution of ingredients to 

the raw meat ingredient. Cured products, like ham, turkey ham, and corned beef, 

have nitrite in the solution. Other products, like roast beef or chicken roll, may 

have only salt and seasonings used. The solution is often added with an injector, 

but products may also simply be immersed in the solution. 

Another type of product in this category is the meat salad. Ham and chicken 

salad are some of the common salads produced. The establishment starts with

fully cooked product. The fully cooked meat is chopped or ground, and mixed 

with other ready to eat ingredients such as mayonnaise, salt, spices, onions, 

celery, or pickle relish. The finished salad is packed into containers, and may be 

distributed fresh or frozen. These products are rarely reheated; most consumers 

eat them cold.

There are other products that we did not mention that you might encounter in the 

marketplace or being produced in an establishment. These products all have 

some things in common: they are fully cooked and ready-to-eat by the consumer; 

and they require refrigeration or freezing in order to maintain product safety and 

quality.

Common Hazards and Controls

The cooking step in these products kills the pathogens. However, there are other 

biological hazards of concern as a result of the different process steps and 

procedures these products undergo. 

After the cooking process, the product is commonly cooled. The cooling process 

is also known as stabilization. Potential biological hazards during the
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stabilization process include spore-forming bacteria Clostridium perfringens and 

Clostridium botulinum. These pathogens can survive cooking and 

establishments must be carefully control time and temperature in order to ensure 

that product does not remain at warm temperatures that would support the 

outgrowth of these pathogens. Listeria monocytogenes (LM) is also a potential 

biological hazard that may re-contaminate the product after cooking, if cooked 

products are exposed to the environment, food contact surfaces, or crosscontamination with raw products prior to final packaging. 

The establishment must have procedures in place to ensure chilling and cold 

storage at acceptable time and temperature combinations during stabilization. 

These controls are essential to limit the growth of these bacteria.

The establishment may choose to control pathogenic microorganism 

recontamination in a number of ways. Spices that may contain Salmonella could 

be irradiated. To address LM, the establishment could apply treatments or 

processes after cooking to kill any surviving pathogens of concern, in addition to 

executing additional sanitation procedures in the processing environment. 

Common chemical hazards include allergens, such as soy or milk byproducts 

which may be used as ingredients. Chemical accelerants, acidifiers and antioxidants may be used as part of the fermentation process or assist in the quality. 

These could pose hazardous if not used in proper measurements.

There are no notable physical hazards unique to this process category. 

However, like non-intact raw products, metal contamination from equipment with 

small and moving parts could pose potential physical hazards as well. As 

mentioned previously, establishments may install metal detectors to identify and 

eliminate metal in product due to broken pieces of equipment or other metal 

items that enter with the live animal. Methods that establishments use to control 

physical hazards also include visual observation of product, sanitation 

procedures, standard operating procedures (SOP) for product handling, good 

manufacturing practices (GMP) to ensure proper maintenance and inspections of 

facilities and equipment, and foreign materials detection equipment (inline 

magnets, screens, traps, filters, etc.) used during the production process. 
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Common Steps for a Fully Cooked – Not Shelf Stable Product

- Hot Dog as an example

One of the major product groupings that fall under this category is the cooked 

and smoked sausage. There are many different types of these sausages made; 

some common examples are bologna, cooked salami, polish sausage, and hot 

dogs. Let’s take a closer look at hot dogs as an example of how these products 

are produced.

Receiving

The first steps are the same as we have previously covered: meat and/or poultry, 

other ingredients, and packaging materials are received and stored in the 

establishment until ready to use. Many establishments carefully control the 

quality of the incoming ingredients through purchasing specifications. Meat 

ingredients may have quality specifications such as percent fat, moisture, and 

protein. These are parameters that will affect the final quality of the product. 

Raw meat ingredients used in these products will depend on the type of finished 

product desired. Many formulations include at least some poultry products, 

(turkey or chicken), and some products are made exclusively with poultry. 

Weighing and Mixing 

The first step in the formulation process is weighing or measuring the meat 

and/or poultry ingredients. They are ground and mixed or blended with the nonmeat ingredients. Often establishments will pre-blend, that is, they will grind and 

mix the meats with water and salt, and sometimes with the nitrite, and let it stand 

for a period of time in a cooler. 

We have already discussed the most common non-meat ingredients used in hot 

dogs: water, salt, curing agents like sodium nitrite, and sugar. Let’s take a look 

at some of the other ingredients that may be used, depending on the formulation. 

Binders and extenders, such as dry milk powder, cereal flours, and soy protein, 

have a number of uses in a sausage formulation. They increase the overall yield, 

improve binding qualities, and add certain flavor characteristics.

Cure accelerators such as ascorbates and erythorbates are used to speed up the 

curing process. They also stabilize the color of the final product. 

Phosphates are used to improve the water-binding capacity of the meat, and 

contribute to the flavor and color of the product. 
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Spices and flavorings are used to add flavor to the sausage. The wide range of 

available spices, seasonings, and flavorings is a primary reason for the variety 

available in sausages in the marketplace. 

Emulsification

After the non-meat ingredients are blended with the ground meats, the mixture is 

emulsified. This is done in an emulsifier, and further reduces the size of the meat 

particles to achieve a very fine texture. Fat, protein, salt, and water are mixed 

and combined into a semi-fluid emulsion. 

Stuffing 

After emulsification, the mixture (or “batter”) is stuffed into casings, usually 

artificial plastic casings that allow moisture to cook out and smoke flavors to 

penetrate. Natural casings such as sheep small intestines may also be used. 

Following stuffing, the product is linked by pinching and twisting the casing to 

form separate units of sausage. The sausages are still held together by the 

casing. These lengths of casings are then placed on racks or trees, and are 

ready to be loaded into the smokehouse. Some establishments load trees into 

individual smokehouses, however, some large volume establishments use 

continuous smokehouses. 

Smoking

The smokehouse parameters that must be controlled are temperature, time, and 

humidity. The product must be exposed to a high enough temperature in order to 

produce a fully cooked, ready-to-eat product. Cooking is a very important step, 

because it is here that any pathogens that may be in the product will be 

eliminated.

Cooling

After product has reached the final temperature desired, the cooling process 

begins. This product is often showered with cold water inside the smokehouse. 

This removes some of the heat from the product, and immediately halts the 

cooking process. The shower is usually not sufficient to complete the cooling 

process. Usually product is moved to another chiller or cooler to finish cooling. 

Some establishments use very cold water as a chilling medium, sometimes with 

salt added to lower the temperature below the normal freezing point of water. 

This is called a brine chiller. Other establishments may use cold air, and some 

use a combination of methods. This is also referred to as the stabilization 

process, very important because this is also where biological hazards are 

potentially present.
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Peeling

After product has been chilled to the desired temperature, it is removed from the 

artificial casings in a machine called a peeler. This equipment quickly runs the 

sausage through a tunnel that has a tiny blade that slices the casing. Steam or 

air is then used to blow the casing away from the sausage. The sausage links 

are now separate. If you closely examine the outside of a hotdog, you might see 

where the casing had been cut. This blade is a potential source of 

contamination, since it contacts every hot dog. This is a potential source for 

recontamination with biological hazards.

Packaging and Labeling

The final steps are packaging, labeling, and storage. The product is ready for 

distribution to retail stores, restaurants, or institutions.
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FULLY COOKED- NOT SHELF STABLE FLOW DIAGRAM

Example product: Hot Dogs

Smoking,

Cooking

Packaging,

Labeling

Blending

Grinding

Weighing,

Metering

Receiving & Storage 

-Meat

Purchase Specifications, 

Sampling

Receiving, 

Storage

Packaging 

materials

Storage,

Shipping,

Distribution

Receiving,

Storage -

Non-meat 

ingredients

Stuffing,

Linking

Emulsification

Showering

Cooling

Peeling Rework
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Heat Treated But Not Fully Cooked - Not Shelf Stable

Processing Category

This process category applies to further processed products that are either not 

ready-to-eat products (NRTE) or raw, otherwise processed products that are 

refrigerated or frozen throughout the product’s shelf life. These products are 

produced using the criteria of one of the two following heat processing steps. The 

heat processing step is not adequate to achieve food safety; therefore, products 

may be partially cooked or heated to set batter on a raw product. The other 

criteria is that the heat processing step was adequate to achieve food safety;

however, product is further processed, assembled, or packaged so that the 

cooked product contacts non-ready to-eat product ingredients. In this case, the 

final product is in a form that is not edible without additional preparing to achieve 

food safety. 

The products included in this category vary quite a bit from each other. One 

well-known not ready to eat product is bacon. It is a cured and smoked pork 

product. Another product is cold smoked sausage, a product that has been 

smoked to add flavor, but is still raw. Partially cooked battered and breaded 

poultry is included in this category; it has been cooked only enough to “set” the 

breading. Char-marked patties are similar; they have been cooked only enough 

to add distinctive char marks on the meat surface, but are still essentially raw. 

Low temperature rendered products are heat treated to melt and remove some of 

the fat in the meat tissues, but again, they are not fully cooked. Chicken pot pie

contains cooked chicken and raw dough, and so, falls into this category. As you 

can tell, there are many different types of products grouped into this category. 

Cold smoked sausage is smoked primarily for appearance and flavor, but is still 

raw. The process is called “cold-smoked” because the smoking does not result 

in high enough temperatures to cook the product. The smoke used is not 

actually cold; it is usually 90 - 120 F. The product must be quickly cooled 

(stabilized) to prevent bacterial growth. 

Partially cooked battered, breaded poultry products are another product in this 

category. The raw poultry pieces are coated with batter, a liquid mixture of flour, 

egg, milk, or water; or with breading, a powder or granular mixture of cereal 

products, like breadcrumbs; or they are both battered and breaded. The pieces 

are then heat treated to “set” or precook this coating, usually in hot oil. The 

poultry product inside is still uncooked. The products are cooled, usually in a 

special IQF (individually quick frozen) freezer, and packaged.

Char-marked patties are also included in this category. These products received 

a heat treatment on the outside surface that produces a “char-mark” which 

imitates the marks created from cooking product on a grill. The product is still 

essentially raw, and it is important that product labeling distinguish this product 
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from ready-to-eat products. It is crucial that this product be fully cooked by the 

final user, to ensure safety.

Low temperature rendered products are derived from the low temperature 

rendering of fresh meat. The products are usually ground, heated, then treated to 

a process that separates some of the fat from the lean portion. The temperature 

used must not exceed 120 F. The product is then cooled quickly to limit potential 

growth of bacteria at these warm temperatures. The heat treatment is not 

sufficient to eliminate pathogens or to result in a cooked appearance. The 

rendered product is frozen and used in further processing operations. If the raw 

meat trimmings had at least 12% lean meat prior to rendering, the resulting 

product is called Partially Defatted Chopped (species). If the fatty trimmings 

used as raw materials contain less that 12% lean meat, the resulting products 

are called Partially Defatted (species) Fatty Tissue.

There are many other products that you may encounter that would fall into this 

category. The most well-known product is not ready to eat bacon. It is a cured 

and smoked pork product. We will use bacon as an example to look at common 

steps in the process. The common characteristic is that these products receive 

some heat treatment, but not enough to result in a fully cooked, ready-to-eat 

product.

Common Hazards and Controls

The food safety hazards in this processing category are not unique. In general, 

you can refer to the common hazards and controls for Raw Intact and Raw NonIntact products. Many hazards and common controls will be the same. 

Common biological hazards and controls for these products will be similar to the 

hazards for raw products because these products have not undergone a lethality 

step to rid the product of harmful pathogens. Additionally, if the product 

undergoes a step or process using elevated heat, the establishment should 

consider pathogens associated with improper stabilization. See previous 

discussion in other processing categories about this.

See previous discussions about chemical and physical hazards and controls. 

Hazards and controls will vary based on the product and how it is processed. 
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Common Steps - Heat Treated But Not Fully Cooked – NSS Process

- Bacon as the example

Bacon is an example of a product that is cured and smoked. Let’s study the 

process flow diagram for this product. This is just to give you some familiarization 

to a Heat Treated but Not Fully Cooked, Not Shelf Stable process. This is only 

one example and is simplified from the flow diagram which follows. This process 

will vary from establishment to establishment.

Receiving

First, raw meat ingredients are received, either from another establishment, or 

from the fabrication department within a large establishment. In this case, the 

raw meat ingredient used is the pork belly.

Weighing and Mixing

The non-meat ingredients are weighed and combined. Bacon is a cured product,

which means that additives are used to preserve the product and stabilize the 

color. Following are some of the most common additives:

 Salt is used for flavor and because it preserves the product by inhibiting 

bacterial growth. 

 Sugar is sometimes used as a sweetener. It can counteract the harsh flavor 

of the high levels of salt used in some products. 

 Nitrite (or less commonly used nitrates) stabilizes the color of the meat, 

contributes to the characteristic flavor of cured meat, inhibits the growth of 

both pathogens and spoilage microorganisms, and retards rancidity 

(deterioration of the fat). 

The amounts of nitrite and nitrate allowed are restricted by FSIS regulations. 

Additives that have regulatory limits are known as restricted ingredients. 

Because nitrates are reduced to nitrites and is further converted to nitric oxide 

which react with amines present in muscle fibers to form nitrosamines (are 

known to cause cancer), the nitrite and nitrates levels must be closely monitored. 

Nitrite is most important because of its role in the developing the cured meat 

color. A series of chemical reactions results in the formation of the stable pink 

color of cured meat.

These are just some of the most common curing ingredients. Many other 

ingredients are used by industry, and will contribute to the variety of formulations 

that you may encounter.
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Curing 

These cure ingredients are sometimes mixed with water to form what is known 

as a pickle, or a curing solution. The solution is often injected into the meat using 

an injector. This equipment carries the meat past a series of needles that pierce 

it and force the pickle solution into the interior of the meat pieces. This process 

is called pumping. This results in a fast and even distribution of the pickle. 

There are many other means of introducing the pickle; sometimes meat pieces 

are simply placed into a barrel or vat of the pickle. This is a much slower process 

than injection.

Draining/Chilling

After injection, the meat pieces are hung onto racks called trees or cages, which 

hold the meat while it is further processed. The meat hangs in a cooler for a 

period of time to ensure that the cure ingredients have time to react with the 

meat, and to allow some of the solution to drain out, if necessary. 

Smoking

The next step is the smoking process. The racks of meat are loaded into a 

smokehouse. The establishment operator carefully controls the smokehouse. 

Time, temperature, and humidity are parameters that effect product. These 

parameters are usually carefully monitored to ensure that the smoking step 

proceeds as designed by the establishment. 

One common type of monitoring equipment used is the dry bulb/wet bulb 

thermometer. This device monitors the temperature inside the smokehouse with 

two thermometers set right next to each other, one dry, and one inside a moist 

piece of cloth. The difference between the two temperature readings is used to 

calculate the humidity of the environment. 

The operator sets the smokehouse controls to run through a series of processes, 

in which the addition of steam and smoke will change the conditions inside the 

smokehouse. Although bacon receives some heat treatment in the smokehouse, 

it is not fully cooked. The smokehouse treatment is primarily designed to deposit 

the smoke onto the surface of the meat. 

Smoke has several important effects on the meat product: 

 It develops the characteristic smoke flavor. 

 It results in a color change (browning effect), on the surface of the meat. 

 It has some preservative effect.

 It protects the meat from oxidation, which is the development of off-flavors. 
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Smoke is a complex mix of chemical compounds, including phenols, alcohols, 

organic acids, carbonyls, hydrocarbons, and gases. The phenols and carbonyls 

produce the color and flavor of smoke. Smoke has a bactericidal action; that is, it 

kills some of the bacteria present. This is due to the combined effects of heating, 

drying, and depositing the chemical components of the smoke. Smoke is often 

produced from hardwood sawdust in a smoke generator. Liquid smoke is also 

used. 

Cooling

After the product has been smoked according to the establishment’s desired 

process standards, it must be cooled down to safe product storage temperatures. 

This is often done initially in a blast cooler for maximum cooling effect. This 

cooler forces cold air at a very high velocity around the bacon pieces, quickly 

cooling them.

Shaping

After the product is properly chilled, it may be sold in the bulk form. Most bacon, 

however, is sold as sliced product. The meat pieces are usually shaped in a 

press, or blocked, in order to produce uniform slices. 

Packaging and Labeling

The product is sliced, and packaged. Net weights are checked by establishment 

personnel to ensure that the net weight statement on the label is accurate. Other 

quality checks are often performed by the establishment on the finished product. 

The product is now ready for final distribution.
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HEAT TREATED BUT NOT FULLY COOKED- NSS

FLOW DIAGRAM

Example product: Bacon

Cooling

Packaging,

Labeling

Inserting 

combs,

Hanging on 

trees

Pickle Injection

formulation

Receiving & 

Storage -

Meat

Receiving & 

Storage -

Packaging 

materials

Storage,

Shipping,

Distribution

Receiving & 

Storage -

Non-meat 

ingredients

Smoking

Cooler –

(Curing, 

draining, & 

surface drying)

Shaping

Slicing

(Net weight 

and Quality 

Check)
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Products with Secondary Inhibitors – Not Shelf Stable

Processing Category

This process category applies product that has been further processed by curing 

or using other ingredients that inhibit bacterial growth. These products are 

generally refrigerated or frozen throughout the product’s shelf life. Depending on 

the process and ingredients, these products may or may not meet the definition 

of ready to eat product as defined in 9 CFR 430.1.

Finished products in this regulatory processing category may or may not have 

had heat applied to the product. The finished products in this category are not 

shelf stable and require special handling to maintain safety. 

Some examples of products that may fall into this processing category include 

products that are uncooked, cured, fermented, dried, salted, or brine treated, 

which are not shelf stable but can be ready to eat or not ready to eat, such as 

sliced country style ham, salt pork, and semi-dry fermented sausage. The 

product standards, processing methods, and labeling are all factors that must be 

considered in determining the regulatory processing category.

Secondary inhibitors are usually ingredients or processes such as fermentation 

or drying that when used, in combination or alone, assists in inhibiting, or slowing 

the growth of possibly harmful bacteria. Primary microbial growth inhibitors 

include lowered water activity (aw) and higher acidity. Salt or sugar in quantities 

that effectively lower the water activity of the finished product is an example of a 

secondary inhibitor. We will discuss each of the inhibitors and then concentrate 

on one product example - country-style ham. 

Water activity (aw) - Microorganisms in food need water in order to live and grow. 

The water must be in a form that is available to the microorganisms. Water 

activity is a measurement of how much water is available in a product. The water 

activity can be reduced by removing water (drying) or by increasing the 

concentration of solutes dissolved in the water (adding salt or sugar). 

Acidity - Most bacteria grow best in a medium that is neutral or slightly acidic, 

and the growth of most bacteria is significantly inhibited in very acidic foods. The 

ionic hydrogen concentration (pH) is measured on a scale from 1 to 14, with 7 

being neutral; pH levels above 7 are basic, or alkaline, while those below 7 are 

acid. Foods that are highly acidic are seldom the vehicles for pathogens. Many 

foods are acidified to prevent the growth of undesirable microbes. This may be 

done by adding acidic ingredients, like tomatoes, or by adding the acid directly, 

like vinegar. The acidity of products may also be increased by the process of 

fermentation. 
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The process of using secondary inhibitors is a very complex system. Often 

several different inhibitors are used, each depending on the others in order to 

result in a safe product. 

Common Hazards and Controls

Biological hazards which are common to these products depend mostly on if 

the product is still essentially raw; or, if the product undergoes a process that 

makes it shelf stable, or ready to eat. Common biological hazards for not ready 

to eat product would be consistent with common biological hazards for all raw 

products. Additional consideration for potential pathogens of concern for intact or 

non-intact product, respectively, depends on the species and the degree of meat 

surface penetration. If the product undergoes a step or process using elevated 

heat, the establishment should consider pathogens associated with improper 

stabilization. See previous discussion in other processing categories about this.

See previous discussions about chemical and physical hazards and controls. 

Hazards and controls will vary based on the product and how it is processed. 
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Common Steps - Products with Secondary Inhibitors – NSS

Country-Style Ham (Not Ready to eat) as an example

Let’s look at the example of the perishable sliced country-style ham.

Receiving

Sliced country-style ham or shoulder is traditionally made from a single piece of 

raw meat from a pork shoulder. 

Weighing/Mixing

All ingredients added are carefully weighed, in order to conform to the product 

formula. Ingredients include meat and non-meat ingredients, such as spices, 

flavorings and items for curing.

Dry Curing

Dried whole muscle products are mostly dry cured. An initial process for 

manufacturing whole muscle products consists of dry mixing the non-meat 

ingredients with the meat. Curing is the addition of salt, saltpeter, nitrites, 

sugars, spices, and flavorings. Nitrate and nitrite contribute to the characteristic 

cured flavor and reddish-pink color of the cured pork.

The entire exterior of the ham or pork shoulder is coated or rubbed by the dry 

application of salt combined with the other ingredients. The high salt level and 

the colder temperatures are the only measures protecting against the growth of 

pathogens. 

Refrigeration 

After the initial salting, the product is held for some period of time at refrigeration 

temperatures (at 40  ̊F) for the salt mix penetration and equilibration. This period 

often takes many weeks, with the goal of lowering the water activity sufficiently to 

inhibit microorganisms.

Maturation

The product undergoes a maturation period (during this stage, the product is held 

at elevated temperatures for drying and flavor development), air drying and 

smoking (if desired), and storage. During these periods at higher temperatures, 

the humidity and air circulation is lowered, with further moisture loss. 
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Packaging and Labeling

The final product is then sliced and vacuum packaged for sale. 

This is an example of a system of inhibitors. The nitrite and the salt are both 

inhibitors, they work together to achieve a certain amount of preservation of the 

product. The lethality of the process for pathogens achieved in a salt-cured 

product will depend on the interaction of salt content, time and temperature of 

curing, drying, and aging. 
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PRODUCT WITH SECONDARY INHIBITORS – NSS 

FLOW DIAGRAM

Example product: Sliced Country-Style Ham

Packaging,

Labeling

Receiving/ 

Storage -Hams

Storage,

Shipping,

Distribution

Weighing of 

non-meat 

ingredients

Receiving/Storage -

Non-meat 

ingredients

Curing 

application

Cure diffusion/ 

additional 

application of 

Cure

Cure removal/ 

stock in net/hang

Dry aging/ Storage

Salt 

equilibration/ 

Equalization/ 

drying

Receiving, 

Storage -

Packaging 

materials

Slicing, boning
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Inspection of Fish of the Order Siluriformes

Background

The program covers domestic slaughter and processing establishments and 

import reinspection. In 2008, Congress made amendments to the FMIA to 

transfer inspection of “catfish” from FDA to USDA/FSIS. Congress made further 

amendments to the FMIA in the 2014 Farm Bill to clarify that “all fish of the order 

Siluriformes” (which includes catfish) are subject to inspection by FSIS. This 

includes several fish species that are imported including Swai and Basa.

The Dec 2015 Final Rule created regulations 9 CFR 530-561 which requires 

mandatory inspection of official establishments that prepare or process fish 

There was an initial 18 month transition period so that establishments could 

become familiar with FSIS regulatory requirements, develop HACCP plans, train 

staff, and make any necessary changes. The full FSIS enforcement period began 

on Sept 1, 2017 for both domestic and import inspection programs. The 

inspection program is similar to processing establishments, once daily.

Recently several countries were approved to import Siluriformes fish and fish 

products to the U.S. (Vietnam, China, and Thailand)

Amenable Fish Species

Section 601(w)(2) was added to the FMIA and specified all fish of the order 

Siluriformes as amenable species under the act. FSIS has regulatory jurisdiction 

over all fish of the order Siluriformes produced for human food. The order 

Siluriformes includes the family Ictaluridae (e.g., channel catfish and blue catfish) 

(historically grown in United States) as well as other catfish-like fish species 

(historically imported.) Common names for some of these other catfish-like 

species are basa, tra, and swai. 

Organisms are classified according to the following hierarchy: Domain, Kingdom, 

Phylum, Class, Order, Family, Genus, and Species. 

Siluriformes is an order of bony fish that includes all catfish and catfish-like 

species. As you may know the name catfish refers to the long barbels, or feelers, 

which are present about the mouth of the fish and resemble cat whiskers. 

Altogether, the Order Siluriformes comprises nearly 2,900 species in about 35 

Families. Several species within the families Ictaluridae, Pangasiidae, and 

Claridae are important food fish. 
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This table is a partial listing of various Siluriformes species along with common 

names. Order Family

Acceptable Common/Usual Name Genus species

Siluriformes

Ictaluridae

Blue Catfish, Catfish Ictalurus furcatus

Channel Catfish, Catfish Ictalurus punctatus

White Catfish, Catfish Ameiurus catus

Black Bullhead, Bullhead, Catfish Ameiurus melas

Yellow Bullhead, Bullhead, Catfish Ameiurus natalis

Brown Bullhead, Bullhead, Catfish Ameiurus nebulosus

Flat Bullhead, Bullhead, Catfish Ameiurus 

platycephalus

Clariidae

Whitespotted fish, Chinese fish Clarias fuscus

Sharptooth Clarias Fish Clarias gariepinus

Broadhead Clarias Fish Clarias microcephalus

Walking Clarias Fish Clarius batrachus

Pangasius

Swai, Sutchi, Striped Pangasius, Tra Pangasianodon 

hypothalamus

Basa Pangasius bocourti

Mekong Giant Pangasius Pangasius gigas

Giant Pangasius Pangasius 

sanitwongsei
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Products labelled as “catfish” must be of the family Ictaluridae. Other species 

may only be labeled by their common or usual name. All of these fish are

desirable food fish. Once a fish has been deheaded, eviscerated, and skinned or 

filleted, it is difficult to accurately distinguish one family or species from another 

on visual exam. The agency has genetic-based species testing for that purpose.

Statutory Exclusions for Fish

Siluriformes fish are excluded from the FMIA statutory provisions regarding 

antemortem inspection and humane handling. Siluriformes fish are excluded 

from the statutory provisions regarding the postmortem, carcass-by-carcass 

inspection of meat. FSIS did provide a regulatory exemption for retail stores and 

restaurants based on 21 U.S.C. 661(c)(2).
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Product Types

Whole Fish

Fillet

Steaks

Strips

Nugget

Whole Dressed Fish- has been deheaded , eviscerated (or gutted), and 

skinned. May be referred to as HGS fish for headed, gutted, and skinned

Steaks (chops) are cross-sectioned, bone-in cuts from whole, dressed fish. 

These are generally produced from fish larger than those used to produce 

typical fillets.

Shank fillets- the boneless fillet with the belly flap removed.

Nugget- the boneless belly flap portion of the fillet

Strips- portions cut from shank fillets. 
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FSIS began to fully enforce the fish regulatory requirements (CFR 530-561) 

starting Sept 1, 2017. Many of the fish regulations mirror the regulations for 

livestock in parts 300 and 400.

Sanitation Regulations, HACCP and Notifications – 9 CFR 537

537.1 Basic Requirements

537.2 Hazard analysis and HACCP plan

537.3 Notification of adulterated product

Fish Inspection Directives

These directives cover inspection and sampling at domestic and import fish

establishments.

14,000.1 – CSI Responsibilities at Fish Establishments

14,010.1 – Speciation, Residue, and Salmonella Testing of Fish of the Order 

Siluriformes from Domestic Establishments

14,100.1 - Speciation, Residue, and Salmonella Testing of Fish of the Order 

Siluriformes at Official Import Inspection Establishments

14950.1 – IPP Responsibilities at Official Import Inspection Establishments that 

Receive Shipments of Fish Products

Fish Sampling

In raw fish and fish products, the food safety hazards of concern are primarily 

chemical residues. FSIS considers fish products adulterated if they are 

contaminated with chemical residues.

Possible misbranding can occur if fish product is of a different species than 

labeled. Speciation testing will determine the species.

Salmonella testing initially will be used to collect baseline prevalence data. There 

is no regulatory control action taken for a positive Salmonella result.
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Additional references

www.fsis.usda.gov/siluriformes

FSIS Compliance Guideline for Establishments that Slaughter or Further Process 

Siluriformes Fish and Fish Products (Mar 2017)

Food Defense Guidelines for Siluriformes Fish Production and Processing

www.fsis.usda.gov/wps/wcm/connect/fc8c5e29-acf2-4636-8963-

5f0011075f08/Food-Defense-Guidelines-Catfish.pdf?MOD=AJPERES

(April 2017)

Fish Inspection Summary

1. Congress amended the FMIA to transfer jurisdiction of all fish of the order 

Siluriformes to FSIS

2. Products labelled as “catfish” must be of the family Ictaluridae

3. Congress excluded Siluriformes fish from certain statutory provisions

4. Full enforcement period began Sept. 1, 2017.