USDA Guidance on Handling Ends and Pieces in Sliced Deli Meat Facilities

Hi, can anyone explain to me ends and piece management from USDA/FSIS point of view?

We are setting up a new slicing facility of deli meat (only slicing step will be carried out in this facility).

HACCP categories are: NHT-SS, HT-SS, FC-NSS. All of them are RTE (deli meat in trays such as salami, prosciutto crudo, cooked ham and so on).

With Ends and pieces I'm referring to Slices out of specifications, ends etc.

So my questions are:

-Can we sell these by-products as NRTE by labelling them according to regulations to other plants?

-Otherwise, do we need to handle them as they would be RTE?

Any further explanations or tips would be really appreciated.

My background and know-how comes from Italy where we put "for further processing" on the labels and sold them to other facilities (filled pasta etc) in where they would be re-processed. 

If they're going onto any human food chain use, I'd handle them as ready to eat.  Otherwise you may find staff treat them with less care and attention and could result in contamination which is not resolved through heat treatment.

Thank you.

So you would handle any ends and pieces as RTE products. 

How would you manage that in a clearoom? Would you install a vacuum machine inside the cleanroom? Maybe I omitted that ends and pieces will be vacuum packed. 

I'm concerned about how long that products would remain in cleanroom (<45F but it's not a CCP) and how to manage the metal detector step later...

Yes, I think it's an important factor in your team recognising these are foods which are going to stay in the human food chain, not waste.  

I'm assuming you have a high care / high risk type environment and that's what you mean by cleanroom?  Yes I'd absolutely have a vacuum packer in there.  They're inexpensive and then metal detect them much as I would anything else.  I'd process them as they were created to avoid temperature abuse or presumably you have some refrigerated areas in your high care/risk for that kind of process?

Two of the roles I've had have included sustainability and I'm absolutely down with reducing food waste but it's vital that people see the potential food waste which is being saved as food not waste.  Otherwise a contamination incident in your by-product stream is as much a food safety and financial risk to your company as in your normal stream.  Of course this process needs to be managed and recorded in your HACCP / food safety plan just as any other product would.

It might be worth visiting or talking to cheese packers or manufacturers if you can?  The cheese industry (out of necessity) has been great over the years at preventing waste including whey protein extraction, grating of offcuts etc.  If you work in cheese everything is seen as a potential food because it's so expensive.  Or at least it is in UK factories I've visited.

The byproduct (ends and pieces) should be held to the same safety standards as the primary product.  The only difference between them is quality (and trivial distinctions in labeling that are primarily about economics).