Can Label Application Cover Multi-Plant Processing for Salami Logs?
Hi!
Plant A and plant B are sister establishments, both under 9CFR.
Plant A make salami logs to be sliced at plant B.
Can the owner send over one (only one) label application including the entire processing methods from raw material at plant A to finished pre-.sliced products at plant B together?
Only if you want to list out two es numbers on the label.
I want to list only plant B on the label.
I've never seen two #est on a label.
I have seen that and is was for the same situation.
It can cause some confusion.
But can I list only plant B on the label or is it inaccurate?
You must include the establishment number Est#B on the final product label.
If the label qualifies for generic approval, meaning it doesn’t include special claims or require LPDS (Labeling and Program Delivery Staff) stamping, you simply need to update the establishment number on the label and list Est#B on the Application for Label Approval.
However, if the label includes a claim and has already been stamped and approved by LPDS for another sister establishment, you’re allowed to use a copy of that approved label. In this case, you still need to ensure Est#B appears on the final label applied at the sister facility. This process is referred to as a “blanket” label approval, and it’s described in the FSIS Compliance Guideline for Label Approval.
As for including two establishment numbers, that scenario I have only seen in the following scenarios. Scenario#1, if Est#A ships a case containing ten ground beef logs to Est#B, and Est#B repackages only two logs, the logs may retain Est#A on their individual labels. Est#B must then appear on the shipping container or outer box. This labeling approach follows FSIS Directive 7220.1 and is outlined in Policy Memo 090 & 090B.
Scenario#2: When a product is not intended for retail sale and thus wholesale, the use of multiple establishment numbers is allowed. While this practice is not common and I wouldn't not recommended, it is allowed under current guidance. You can find further clarification online if you search askFSIS Public Q&A: Multiple Legends
Research the documents mentioned for further clarification.
This is my case:
Establishment A and establishment B are sister establishments (same owner but with different #Est).
Plant A produces salamis (from raw meat) which are then shipped to plant B where they are sliced and packaged.
In the label approval I have included the processing methods from the grinding of the meat (occuring at plant A) to the slicing and packaging stage (occuring at plant B).
Is the label approval okay to be shown to IPP?
Thanks,
As long as your Processing Procedures are clear to what is done at Plant A and what is done at Plant B then yes.
Plant A's Processing Procedures should state something in the lines of:
Receives Raw Meat
Grind Meat
Mix spices and meat
Stuff Meat into Casings
Curing of Salami
Packages and Labels Product
Ships Final Product
Plant B's Processing Procedures should state something in the lines of:
Receives Salami
Slices Salami
Packages and Labels Product
Ships Final Product
I’ve seen Processing Procedures that range from very detailed to quite basic. In my experience, IPP rarely questions their level of detail, as long as the procedures are included as part of the label approval.
What if the Processing Procedures are not that clear? I haven't listed the operations carried out in each plant respectively.
Plant A is in front of Plant B and they share shame Inspector.