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Under GFSI /FDA can you repack finished meat products in a snack manufacturer?

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Gracezy

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Posted 05 March 2020 - 03:49 PM

Hi Guys,

 

Can you repack finished  meat products in the snacks manufacture? On the USDA side, I know that I might have to get the inspection and get the establishment number.

However, Is there any requirements that I need to be aware of in order to meet Grobal food safety standard or even on FDA side. Please kindly advise.

 

 



pHruit

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Posted 05 March 2020 - 04:09 PM

Can't help on the FDA (or USDA) bits as I'm on the wrong side of the pond, but in general GFSI isn't really a standard in and of itself.

Which scheme(s) are you certified under?
They each have slightly different requirements (and very different ways of going about those requirements ;) ) but in general you'd be expected to have the right facilities, systems, HACCP plan etc, and any regulatory approval if and where required.



Gracezy

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Posted 05 March 2020 - 04:38 PM

Thank you pHruit for the fast respond. We are SQF Certifed. We do have all the HACCP plan etc.. So I guess I have to creat the new HACCP plans for the project if we really do decide to move forward. My concerns are that I'd be missing something important that I need to be aware of. I want to make sure that it will be aompliant with all the regulations. 



pHruit

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Posted 05 March 2020 - 06:25 PM

Aside from the obvious like the HACCP plan, the regs side would very much be my focus too - hopefully someone from the US will be able to provide more specific input on this element.



kfromNE

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Posted 05 March 2020 - 06:42 PM

Thank you pHruit for the fast respond. We are SQF Certifed. We do have all the HACCP plan etc.. So I guess I have to creat the new HACCP plans for the project if we really do decide to move forward. My concerns are that I'd be missing something important that I need to be aware of. I want to make sure that it will be aompliant with all the regulations. 

You're right, you'd need a new HACCP plan. You don't have to follow the FDA regulations unless you plan on making a FDA product. So to your first question - no there aren't any other requirements.



The Food Scientist

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Posted 05 March 2020 - 07:36 PM

May I ask what the finished meat product is? Is it beef jerky? Or something similar? Because they are mixed with snacks in many products (trail mixes). You do need a new HACCP plan as everyone mentioned above.


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


Gracezy

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Posted 05 March 2020 - 08:11 PM

You're right, you'd need a new HACCP plan. You don't have to follow the FDA regulations unless you plan on making a FDA product. So to your first question - no there aren't any other requirements.

Thank you! what do you mean by FDA product?



Gracezy

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Posted 05 March 2020 - 08:32 PM

May I ask what the finished meat product is? Is it beef jerky? Or something similar? Because they are mixed with snacks in many products (trail mixes). You do need a new HACCP plan as everyone mentioned above.

Yes, it is something similar to Beef Jerkey. 

I just have to update the HACCP plans for all the products that we are currently have and create a new HACCP plan for the new product, right?



kfromNE

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Posted 06 March 2020 - 01:23 PM

Thank you! what do you mean by FDA product?

FDA product, the simple answer: a product that doesn't contain meat. The complicated answer: a FDA product could contain meat if it's a very low percentage of the product (you'd have to look that up). When in doubt - ask the USDA inspector, they'll be able to tell you.



KTD

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Posted 06 March 2020 - 02:53 PM

Gracezy -

     Your first step is determining where you are shipping and/or selling your product. Interstate is covered by USDA FSIS, in-state may well be covered by a state food safety entitiy.

     Go to www.usda.fsis.gov/ and search for "Grant of Inspection". There are multiple program requirements (HACCP, SSOP, recall) that must be available. There are also physical requirements around an on-site dedicated USDA FSIS office. You will also likely undergo a Food Safety Assessment (FSA) where you will have to review your programs, procedures, forms, and supporting scientific information. Depending on your process and HACCP category(s), you will have an inspector on-site either part or all the time that you conduct a covered process...which you will have to pay for.

 

     Dig deep and go slow. It can be a cumbersome and frustrating process. You might consider contacting the USDA FSIS District office that covers your state and ask if they have an EIAO (Enforcement, Investigation, and Analysis Ofifcer) who can provide outreach servivces. Search for "District Offices" on the saem website.

 

Keith



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Posted 06 March 2020 - 05:13 PM

 

IF what you are repacking is RTE product, and you are opening it up from its original container then you will be falling under USDA jurisdiction (if selling across state lines).  Not only will you need HACCP plan, but the USDA version of SSOPs, allergen programs, listeria monitoring program, an establishment number (which you will get by submitting the application), an approved label, a LOTO agreement, hope this helps



Gracezy

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Posted 06 March 2020 - 05:33 PM

Gracezy -

     Your first step is determining where you are shipping and/or selling your product. Interstate is covered by USDA FSIS, in-state may well be covered by a state food safety entitiy.

     Go to www.usda.fsis.gov/ and search for "Grant of Inspection". There are multiple program requirements (HACCP, SSOP, recall) that must be available. There are also physical requirements around an on-site dedicated USDA FSIS office. You will also likely undergo a Food Safety Assessment (FSA) where you will have to review your programs, procedures, forms, and supporting scientific information. Depending on your process and HACCP category(s), you will have an inspector on-site either part or all the time that you conduct a covered process...which you will have to pay for.

 

     Dig deep and go slow. It can be a cumbersome and frustrating process. You might consider contacting the USDA FSIS District office that covers your state and ask if they have an EIAO (Enforcement, Investigation, and Analysis Ofifcer) who can provide outreach servivces. Search for "District Offices" on the saem website.

 

Keith

 

Totally needed this guidline. It is interstate so I will contact our district USDA FSIS. Thank you so much Keith! Appreciate your advice.



Gracezy

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Posted 06 March 2020 - 05:35 PM

 

 

IF what you are repacking is RTE product, and you are opening it up from its original container then you will be falling under USDA jurisdiction (if selling across state lines).  Not only will you need HACCP plan, but the USDA version of SSOPs, allergen programs, listeria monitoring program, an establishment number (which you will get by submitting the application), an approved label, a LOTO agreement, hope this helps

Thank you so much. I appreciate it.

 



Gracezy

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Posted 06 March 2020 - 05:49 PM

FDA product, the simple answer: a product that doesn't contain meat. The complicated answer: a FDA product could contain meat if it's a very low percentage of the product (you'd have to look that up). When in doubt - ask the USDA inspector, they'll be able to tell you.

 

Ahh yes. I understand. Thank you so much.





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