Resource 2
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
documented to be sufficient to provide enhanced safety.
•
Alternative 2 Product
-- Post-lethality treatment or
antimicrobial agent/process
-- The Post-lethality treatment
or antimicrobial agent/process must be documented to be sufficient
to provide Enhanced safety.
•
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.
•
Ingredients Statements
•
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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