Labeling out of RTE

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!

Do you have a product that you are wondering about?  I offer free initial phone consultations on HACCP and other food safety plans.

Labelling

One of the most complex process in putting food into the retail market is labeling.  How to tackle the labeling problem?

Label is a broad term, answer these questions BEFORE you spend money with a designer doing packaging.

1. Are you big enough that you need nutrition labels?  
2. How about safe handling instructions?  
3. Cooking instructions?  Are they validated?
4. Are you making a ready to eat (RTE) or a Not Ready to Eat (NRTE)?
5. Any allergens in your product?
6. How are you going to determine your ingredients list?
7. Are you a USDA product, and thus need to go through LSAS?

Once all the regulatory stuff is squared away, only then can you go to town on package design!

Listeria control

Listeria.  It's in the drains, it's in the soil, it's on the shoes of the workers that walk into your building.  And if you are making a Ready To Eat (RTE) product, it can be a really big problem.  USDA guidelines  gave some great advice to processors on how to approach their listeria control program.  In short, if you are producing a product that is readily identifiable as RTE and they have risk for environmental exposure you must implement one of three regimens to control Listeria.

Alternative I- Post lethality treatment (PLT) and antimicrobial agents or processes (AMA and AMP respectively).  This option works for conventional products that can be preserved and cooked in their packaging

Alternative II- PLT or AMA/AMP

Alternative III- Implementation of a sanitation program to control Listeria

So, does your product require listeria control?  Ask yourself these questions:

1. Is it Ready to Eat?  Or, if it is on the fence (like frozen dinner) are you planning on labeling yourself out of a RTE category?
2. Is it exposed to listeria after the final pathogen control step in your HACCP?

If the answer is yes to both of those questions, then you need to implement the Listeria Rule.