Can RTE Deli Meat Trays Be Reworked? USDA Guidance on Slicing Facility Procedures

Hi everyone, 

some questions for you guys. Below the procedure I've developed about reworking. The facility is under alternative 3.

Reworking of products may be necessary during production. Cases in which reworking is allowed are:

- “dirty” tray sealing i.e., the product has slightly come out of its seat and occupied parts below the seal, resulting in a poor seal;

- trays used for gas testing;

- non-compliant weight.

Recycling is done only on the trays during processing within the same lot.

During processing, the trays are passed through a bush that feeds them into the production area (clean room) where they are repacked. In the clean room, the trays awaiting reprocessing are placed in colored containers.

Inside the cleanroom, an operator sprays the trays with alcohol-based sanitizer. One operator, without touching the product, proceeds to open it while a second operator handles the product removed from the package

According to USDA point of view, dirty tray sealing and trays used for gas testing (e.g. pierced) may be re-packaged? These trays are collected at the end of the line (outside the clenaroom, the only environment where products are exposed). I'm not concerned about non-compliant weight because of the integrity package is ensured. 

Correct me if I'm wrong.

We rework a comparable RTE product.  Packages returning from a warehouse like environment to the RTE exposed area are sanitized and poured into a small container by one group, and another set of people handle the contents inspecting them and return them to the packaging equipment.

thank you.

Are the packages returning from warehouse completely sealed? What if packages are not completely sealed and exposed to environment which is no RTE exposed area?

Thank you in advance

Secondary packaging (carbdoard) is removed in the warehouse.  During this the primary packaging is given an organoleptic inspection.

Primary packaging that is not observably compromised is taken to be sanitized and reworked.

If primary packaging is observably compromised, packages are segregated and discarded as inedible.

Thank you!

Last thing: how do you discard them? 

Once they're condemned to inedible we have team members in sanitation colors open them.  Packaging just gets baled with similar garbage. The inedible product gets weighed and disposed of with everything else going to the renderer, such as floor loss, tankage, etc.

All the tubs, tables etc. that the inedible packages came into contact with gets cleaned and sanitized and inspected before it can return to production use.

Personally I'd have the decontamination process at the transfer back into your clean room (we'd call it "high risk" in the UK).  That's normal practice in my experience.  But additional to that, I'd consider how you've laid out your line.  So for example, if you moved your gas testing checks into your clean room, you could then rework those packs.  If you had your weight rejects in the clean room side, that's going to be a transfer process you don't need to do.

It's interesting you're asking all this considering another question on Listeria monocytogenes but every time you transfer a pack, you are introducing risk of Listeria monocytogenes into your clean room.  Even more so if the pack is damaged, not fully sealed or open.  I'd have really clear guidelines on what is and isn't acceptable but to my thinking, any compromised pack, whether that's testing or product in seal doesn't go back in.  Ultimately transfers back are things you should be minimising as much as you can.  Every time you do so, you have a risk of breaking that barrier.