HACCP: rules, rules, rules…

January 28, 2010

“Rancidity is a quality issue, not a safety issue.”

That’s what the USDA says. Who knew? Is that quote worthy of a printed T-shirts? Beer cooling huggies? These just seem like great words to live by….or at least be aware of. The government oversight of charcuterie and uncooked/shelf-stable (aka DRY) meat production is in place to keep you from becoming extremely sick and/or dead. The USDA is not in the business of ensuring that you have a euphoric small-plate dinner pairing of melon and cured meat, comparable to a distant dinner memory  in Foligno, Italy.  The USDA has a lot of rules and codified expectations about how meat is stored, prepared, and shipped because they don’t want botulism, Listeria, e coli, or other nasty critters to anonymously endanger the lives of taxpaying American carnivores. From a distance, this seems reasonable. But following the rules can be very expensive for an artisan butcher who doesn’t plan to produce or sell as much as “Hebrew National” or other mega-meat corporations.

So, is there any balance between keeping the public safe through government regulations, and allowing entrepreneurial artisan meat enthusiasts entry into the marketplace?  The prospects of a small artisan butcher preparing and selling salami, coppa, or prosciutto sounds nice, but in the United States, this butcher has a lot of homework , paperwork, and costly construction to do if they intend to take this little piggy to market.

The USDA’s  “Food Safety and Inspection Service” (FSIS) is responsible for overseeing and ensuring that the production of uncooked edible meat (meat that’s never been heated to over 160 degrees F, which would render it safe of harmful bacteria) products are safe and free of pathogens that could harm the meat-eating consumers of the United States.

One of the primary tools used to create awareness and to monitor the risks during meat production is a Hazard Analysis Critical Control Point Plan (HACCP….pronounced “hassup”). The HACCP Plan includes a flow chart and a work-flow process detailing the entire production process, and identifying each point in the process where a dangerous mistake/risk (physical, chemical, or pathogenic) is likely to occur. The HACCP Plan outlines the risks, and the action that must be taken to control the risk and to keep things sterile, safe, and “acceptable” to the consumer’s health. Fresh pork doesn’t just show up and get stored in a walk-in cooler. There must be documented verification that the meat was handled safely upstream (when it left the slaughter house). It is not enough to just put your pork shoulder in refrigerator. The cooler’s thermometers and cooling system must be tested and confirmed to be accurate on a regularly and well documented schedule. It is not enough to grind the meat through a “clean” grinder, or slice the meat through a “clean” slicer. The stainless steel parts must be cleaned with a proven anti-bacterial cleaning solution with no more than 120 minutes passing between cleanings. The critical control points (CCP from “HACCP“) becomes a lengthy list to understand, monitor, and plan for.


This post is about to resemble a meat science textbook, written by a non-professional food person. 

I think its interesting and accurate. But consider yourself warned.


Anyone who thinks they’re simply going to make a pile of salami, package it for resale, and sell it to the public is in for a startling surprise of prerequisite work to do. A high level view of the process involves:

  1. Creating a flow diagram of the entire process used to make each unique type of uncooked meat product.
  2. Write a Hazard Analysis, identifying every step in the process, and determining if there is a food safety hazard likely to occur with each of these  steps. Biological risks, chemical risks, and physical risks are the red flags that can occur along the way as you make cured meat. Not every step along the way necessarily presents any risk, but the risk is very real during certain actions, and this is the time to identify if it is reasonably likely to occur, what the risk is, and what action can be taken to eliminate the risk.
  3. After the complete Hazard Analysis is documented, it is time to create a HACCP Plan getting very specific about what, when, and how to manage the critical control points.

A Hazard Analysis (master list of tasks) for salami likely includes the following process steps:

  1. Receiving raw meat
  2. Receiving non-meat food, casings, starters, and casings
  3. Storage of non-meat materials
  4. Storage of raw meat
  5. Tempering frozen meat
  6. Weighing raw meat
  7. Weighing non-meat materials
  8. Combining ingredients (includes mixing, stuffing, etc)
  9. rework (if /when things go wrong)
  10. Fermentation (reducing the pH in salami)
  11. Drying
  12. Slicing
  13. Packaging
  14. Storage of finished product
  15. Shipping

After evaluating the Physical, chemical, and pathogenic risks that can likely occur at all 15 steps above, there are only a few where things can go horrifically wrong if the critical control points are not met, and which need to be fully detailed in the HACCP plan. I typed these critical points in bold text above.  If things go badly at a critical control point, people will likely get sick. If things go wrong at a non-critical control point, it may be costly or time consuming, but nobody gets ill. Remember the quote above about “rancidity is a quality issue, not a safety issue”. The HACCP is all about safety. USDA does not care if you overspice a sausage, or if the fat becomes yellowed, rancid, and not pleasant. All they care about is ensuring that you don’t make people sick or dead.

The shorter list of  actions affected by the critical control points (bold items from above list) now get fully evaluated in the HACCP Plan

  1. Receiving raw meat
  2. Storage of raw meat
  3. Combining ingredients (includes mixing, stuffing, etc)
  4. Fermentation (reducing the pH in salami)
  5. Drying
  6. Slicing

Each of these six critical control points now needs an adequate answer for ALL of the following questions:

  1. What are the critical limits? (Critical limit might be the answers to, “How warm may the room be?”, “What humidity must the fermentation chamber maintain?”, “Are there any metal pieces that have fallen off the grinder into the ground meat?”)
  2. Exactly how will you monitor these procedures, and how frequently?
  3. What types of record keeping will be in place to document the HACCP records?
  4. How will you verify the procedures, and how frequently will this verification occur?
  5. What corrective action will be taken if the critical limits are not within the range of acceptable safety?

I left out a lot of detail, but the general path to controlling the risk is accurately described above. As I work on my own HACCP Plans, I’ve learned that nothing is extremely difficult to do. But gathering the accurate details regarding everything from construction, to scientific measuring tools, to basic microbiology of good & bad bacteria makes for a complex project.

Washington State University Extension Program offers a HACCP certification class, which helps individuals learn about and get through the process. It also “qualifies” someone to be the official on-site HACCP lead, and contact person, which is a requirement by the USDA in any meat producing operation. I’ll get signed up for this class next time it’s offered in the state of Washington. And after taking the class, I may need to re-write this entire blog entry. But for now, I’m pretty confident that my understanding of HACCP plans and USDA expectations is accurate enough to keep working, and eventually get a nod of approval from the USDA. We’ll see.

Let’s talk about bacon and donuts again sometime soon. All this HACCP stuff  is important, and logical, and burdensome, and I’d vote for interesting….but not as much fun as eating pork.

And as for Herschel, as of today, we’ve completed: 30/30 days of  salting, 52/90 drying, 0/360 days of aging.


Bacon in the Rose City

January 18, 2010

I am usually a bit behind the curve regarding pop culture, but this weekend I had a pork related revelation. The entire Pacific Northwest may already know about this little breakfast miracle, but if not, read on.

I traveled to Portland, Oregon this past weekend only to discover that maple bar donuts will never be the same again. In an act of over-the-top enhancements to everyone’s favorite “small round breakfast cake with a hole in the middle”, Voodoo Donuts http://voodoodoughnut.com/ placed 2 slices of thick cut crispy bacon on top of their maple glazed donut bar.  And yes, it was exactly as rich and greasy and salty and perfect as it seems like it would be.

Growing up consuming a lot of Montgomery Donuts in Maryland, I thought I had experienced a good donut. Maybe even a great donut. But I was wrong.

Whoever places a fried egg on top of this masterpiece will have an award winning breakfast of champions. Chef Tony at Visions Bethesda? You should run with this idea!

As for Herschel, and my other basement meat ornaments, everything is moving along in the right direction. The prosciutto is on day 42 of 90 for the drying stage. Coppa is about 10 days out until it is ready to eat. And later this week, I plan to start some Speck (cured boneless leg muscle with a strong juniper spice rub)  using a 7lb piece of Mangalitsa leg. Pictures and details will be shared as the work begins.

Until then, I’ll keep dreaming of donuts for a few more days.

Charcuterie Drug Dealer

January 8, 2010

I bought a new scale the other day.

After years of using an inexpensive kitchen scale that measures pretty accurately down to a single gram, I decided to take the $40 plunge and purchase a scale that could give me a useful reading to the one-hundredth of a gram. Too often, a home sausage-making effort involves a pretty small quantity of herbs, spices, and or sodium nitrite. In most cases, it worked just fine to get close to the nearest gram, but in an effort to finalize some recipes that will accurately scale up for mass production or down for home-hobbiest efforts, I wanted to get a new toy and measure more accurately.

The new scale showed up the other day, and I am pretty sure that my name has been added to a list of potential drug dealers. From the outside, this thing is designed to look exactly like a CD jewel case with very hip and cryptic urban graffiti logo, entitled “Street Anthem”. Open the package, and there are 6 alternative “CD album covers” to replace “Street Anthem”, if you want to pretend that your super-precise scale is a CD from a different musical genre. Take a look at the case below.

My plans are to measure small quantities of spices, herbs, and salts. I don’t really need my scale to blend in with the other music collection in my car. But if I were measuring and selling drugs, this sure would be the perfect tool and disguise. Actually, if I were selling drugs, I would be making a lot more money and worrying A LOT LESS about USDA and the safety regulations required to sell uncooked meat to the public. Drug dealers have such cool gear……and such a solid business model. I’m glad we can share some of the same dreams. Someday, I hope to sell dime bags of Coppa out of my El Camino. If not, I hope to find a faux CD cover for my herb scale which has more of an old-time music look and feel to it.

Below is the scale. It works beautifully. And there is a 100g calibration weight (shown at top left) to keep everything tuned up just right.

And, since this is a blog about Herschel the prosciutto, I should share an updated picture. Below is the leg at day 61. (30 days of salting, and 31 out of 90 of drying). Everything is looking, smelling and feeling very good. There’s a long way to go still, so I’ve added a few treats to the room decoration. The pic below shows a Tuscan salami to the far right (nearest the camera). A deep ruby-red and newly hung Coppa (14 days of curing, and only 5 days out of 17’ish of drying) in the middle, and a Chorizo hiding toward the back of the room. Bundles of rosemary are perfuming the room, and definitely making the space smell like I want it to smell.