Source: Tom Johnston, MEATINGPLACE, 1/22/19


USDA’s Food Safety and Inspection Service (FSIS) is expected to post a notice this month informing inspectors that the agency will, sometime in the next few months, publish new revisions to Appendix A & B heating and cooling requirements and push back the compliance date to one year after the new document is published.

This, according to Chris Young, executive director of the American Association of Meat Processors, who met FSIS policy and science staff in December to discuss the revisions and reported the development in his organization’s AAMPlifier newsletter.
Appendix A & B outlines for processors compliance guidelines for heating (A) and cooling (B) thermally processed meat products to achieve pathogen lethality performance standards and product stabilization.

FSIS began revisions to Appendix A & B, first published in 1999, more than a year ago, which shocked processors nationwide because they say the original guidelines were effective and the agency’s rationale for changing them wasn’t clear.

“[I]n Appendix A, there are now some new stipulations as far as cooking with humidity and the amount of humidity you need to have and recording that humidity,” Young told Meatingplace in an earlier interview. “It puts a pretty big burden on small processors when it comes to the money it would take in order to equip themselves to do things the way USDA would like it done through Appendix A, as well as with Appendix B. The cooling times on large-diameter products would be really difficult to meet.”

Technically, Appendix A & B are only guidance documents. However, when a processor uses those guidance documents as supporting documentation to validate his cooking and lethality step or cooling and stabilization step, it is then considered a regulation, Young notes.

“I think what FSIS failed to realize was the amount of plants in the country that use it specifically for that,” he said. “And so, I would say that 95 to 100 percent of my small plants use both documents for lethality and for stabilization. When you change those things, the plant doesn’t have a choice. …[I]f they’re using it for supporting documentation, now it does become regulation and they have to follow it.”

With the delayed compliance date to be announced in a new FSIS notice, processors now will be able to continue to use the 1999 versions of both A & B guidance documents until early 2020.

“FSIS has been willing to sit and talk with us, and it’s actually been probably one of the best collaborations between industry and FSIS that’s happened in a long time,” Young said. “We’re going to see industry and FSIS work together to try and come up with a final document that takes care of what they would like to take care of but also does not cripple small processors.”

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