Back in September, the USDA rolled out a new Listeria Compliance Guideline. At first glance this Guideline seems to be only for RTE foods. Fair enough, that's where Listeria is most problematic.
But, Attachment 1.2 updates how they consider products that receive a full lethality treatment that are not RTE, and are not defined as such by 9CFR 430.1. Value added products that are not hot dogs or deli meat can now be "labeled out" of RTE status. Producing those products under a Heat Treated, Not Fully Cooked, Not Ready To Eat, then labeling them as NRTE, and clearly marking them with cooking instructions, now seems to be an acceptable way to put cooked product into the marketplace, without having to comply with Listeria controls.
This means that plants that have hesitated to put smoked meats, pot pies, or frozen dinners into the marketplace, now have clear and concise guidelines on what to do and how to justify their decisions. Thanks USDA!
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