REGULATIONS AND DIRECTIVES DEVELOPMENT
Determine Whether the Product Is a Deli or Hotdog Product
Now that you know which of your products is applicable to the new
Listeria rule (i.e., post-lethality exposed RTE), determine whether your
product is a deli or hotdog product, as defined in the rule.
Deli products are RTE meat or poultry products that are typically sliced,
either in an official establishment or after distribution from establishment,
and typically assembled in a sandwich for consumption, e.g., spiral cut bone-in
hams; bologna; boiled/baked ham; roast beef; turkey breast; chicken roll.
• Typical hotdogs are RTE meat or poultry franks, frankfurters, weiners per 9 CFR 319.180 standard (thus, does not include products like bratwurst, polish sausage, other cooked sausages covered by 9 CFR 319.140).
Determine the Control Measures Used for the Product and
the Alternative Into Which Your Product Fits
Now that you know which of your products are covered by the new
Listeria rule (i.e., post-lethality exposed RTE), determine which
alternative control measure your product fits into.
• Alternative 1 Product
-- Post-lethality treatment and antimicrobial agent/process.
-- The Post-lethality treatment and
antimicrobial agent/process must each be
• Alternative 2 Product
-- Post-lethality treatment or antimicrobial agent/process
-- The Post-lethality treatment
or antimicrobial agent/process must be documented to be sufficient
• Alternative 3 Product
-- Use of sanitation measures only (in accordance with 9 CFR 430.4 (b)(3)
* May have post-lethality treatment and/or antimicrobial agent/process but not documented as being sufficient to provide enhanced safety
-- Special restrictions regarding potential
adulteration of deli and hotdog products.
• Claims Based on Use of Antimicrobial Ingredients and Post-Lethality Treatments
e.g., Hotdog Ingredients: pork,
water, beef, dextrose, salt, corn syrup, sodium lactate, flavorings
(spice extractives, garlic powder), modified food starch, sodium phosphate,
sodium diacetate, paprika, sodium erythorbate, sodium nitrite.
• Modifying an ingredients statement to add a safe and suitable antimicrobial agent may be done generically
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