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USDA Permit to ship non-denatured inedible meat byproducts

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Posted 10 February 2023 - 06:40 PM

My company produces frozen food (some SKU's with meat toppings), so we fall under both USDA and FDA jurisdiction. 
We recycle our food waste through a third party that further processes the waste into animal feed. We remove the waste from the productions area, compact it, and then the third party picks up the waste from the compactor to further process. 
Our USDA inspector told us we are not complaint with 9 CFR 325.11 as we do not denature the meat food waste before pickup by our third-party vendor. The meat product in question is ready to eat pepperoni toppings composing about 5% of the waste genreated. The inspector informed us to be complaint with the regulations we must obtain a permit from the district office to shipping without denaturing, which we had never needed in over 20 years of conducting this food-waste recycling process. 
We were able to obtain the permit from the district office, but it had some additional requirements that must be met before waste can be shipped without denaturing: 
"Such inedible products shall be transported from an official establishment or in commerce as required by 9 CFR 381.194 only in railroad cars, trucks, or containers which bear unofficial seals applied by the shipper, which shall include the identification number assigned to the permit holder (04264-12-FY2023) and an individual seal serial number assigned by the shipper; and the product so transported shall be accompanied by an invoice or bill of lading specifying the permit holder’s identification number. The consignee in the United States must retain a record of the identification and serial numbers shown on the seals in his records as prescribed in 9 CFR 320."
Does anyone have any experience with this type of permit? We put our waste in a compactor outside and the third-party loads the compactor on the back of their truck and issues us a monthly invoice for all the compactors collected that month. So, we don't have a bill of lading or invoice for each shipment, nor do we currently apply any seals. 
Any insight appreciated! 



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Posted 16 February 2023 - 03:49 PM

I'll ask the obvious------------wouldn't it be easier to denature your waste??????????????

Please stop referring to me as Sir/sirs


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Posted 16 February 2023 - 04:33 PM

To me, looks pretty straight forward...in order to continue to do the practice you are, you'll have to have someone in your facility watch this hauler load it, then place a seal on the truck, mark the number on a BOL or invoice (that should have your establishment number) and have the driver sign off and you keep a copy on record.


Honestly kind of makes sense to have this documentation and process as it is showing that your company is essentially passing it off and it is no longer in your control.  


To Scampi's point above, is the revenue you are getting from this hauler worth the extra work?

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