Drop That Temp And Put Your Hams Up

Don’t let your product fail to comply—new USDA regulations are coming soon

Another holiday is in the books, and Easter Ham and side dishes aplenty have been enjoyed by many. As difficult as it may be to think about, summer, fall, and winter gatherings will arrive before we know it, and the rush to the stores for holiday meal fixings will resume. 

Fully cooked meats are a convenient addition to family gatherings, with the option to heat and serve all or part of your protein of choice. The internal temperature during cooking is probably the most commonly referenced food safety aspect for preparing meats. Still, as many food processing companies know, the cooking temperature is the tip of the iceberg in ensuring safe products for consumers.

One such food safety consideration is the stabilization of a fully cooked meat or poultry product – in other words, how do manufacturers maintain food safety when cooling particularly large portions of beef, pork, or poultry after cooking? While cooking kills many pathogens, more heat-resistant, spore-forming bacteria like Clostridium perfringens and Clostridium botulinum will survive a cooking process and pose a risk if allowed to grow during cooling or hot holding. If not cooled quickly enough, Clostridia spores may germinate and grow when a product is held in the so-called “danger zone,” a temperature range in which microbial germination and growth are most rapid. This is especially concerning when a product remains in the range of around 120/130°F to 80°F for extended periods.

In December 2021, USDA/FSIS released revised versions of the agency’s Cooking Guideline for Meat and Poultry Products (Appendix A) and Stabilization Guideline for Meat and Poultry Products (Appendix B). Additional information about the revisions can be found in FSIS Notice 59-21, in which the new standards and timeline expectations were announced to inspection program personnel (IPP). Although establishments may continue to use 1999 or 2017 versions as scientific support for their HACCP plan for a few months, USDA/FSIS has stated a deadline of December 14, 2022 to begin using 2021 guidelines or provide alternative support.

One key change outlined within Appendix B includes a reduction in 1st stage cooling time for one commonly used option, which now requires a decrease in temperature from 120°F to 80°F in ≤ 1 hour. Meanwhile, more cooling options have been added to accommodate products formulated with certain controls in place based on the formulation or intrinsic properties like pH and water activity.

Without formulation control, some large format products may not be feasible to cool quickly enough to be covered under Appendix B as a safe harbor. As with earlier versions, establishments may opt to conduct an inoculated challenge study to provide supporting scientific documentation for a stabilization procedure. Under this provision, no more than 1-log increase in C. perfringens is permitted when using the establishment’s worst-case product intrinsic factors and cooling procedure. FSIS has indicated this acceptance criterion as a reasonable control for both C. perfringens and C. botulinum, and those parameters used in the challenge study would define the critical operating parameters for the product and process. While this option provides a much-needed alternative for processors unable to meet the new cooling requirements, proper prior planning will be necessary to allow time to set-up and perform an inoculated challenge study and incorporate process or formulation controls into production.

USDA’s compliance deadline is rapidly approaching. Contact us to secure your place in line for a challenging study.