There are four types of inspection a meat processor can operate under, or some combination thereof:
Federal Inspection (USDA)
The United States Department of Agriculture’s Food Safety and Inspection Service (USDA FSIS) is responsible for this type of inspection. Federally inspected products can be shipped over state lines (interstate commerce) and internationally to many countries. Federal inspection requires a HACCP plan, SSOPs, daily inspection of processing facilities, and, if the plant slaughters livestock, antemortem and postmortem inspection of every animal. As of 2013, all inspected plants must also have a recall plan in place.
Federal Inspection Steps:
State inspection is required by law to be “at least equal to” federal inspection in terms of regulatory rigor. However, state inspected meat and poultry products cannot be sold across state lines (restricted to intrastate commerce) unless the state and the plant both participate in the new Cooperative Interstate Shipment program (see below).
Twenty-seven states offer state meat inspection programs in the U.S. USDA FSIS maintains a listing of these programs. Only 25 of these states offer state poultry inspection in addition to red meat inspection.
A NMPAN webinar, presented in collaboration with USDA’s Food Safety and Inspection Service.
Date: February 4, 2014
Duration: 1 hour
The Cooperative Interstate Shipment Program, authorized by the 2008 Farm Bill and launched by USDA-FSIS in 2012, allows state-inspected meats from qualifying plants to be shipped across state lines. The goal of the program is to expand market opportunities for small meat and poultry processors.
Ohio, Wisconsin, and North Dakota were the first three states to qualify, and Indiana is working on it. On this webinar, we heard from state inspection program directors, processors, and others about their experiences with the program so far and what it took to qualify. An official from FSIS provided background on the CIS program.
A Food Safety and Inspection Service Webinar.
Date: Sept.18, 2014
Duration: 1 hour
On this webinar FSIS discusses the current status of the Cooperative Interstate Shipment program in Ohio. Speakers and representatives from the Ohio Department of Agriculture, FSIS, and USDA Know Your Farmer, Know Your Food (KYF2) initiative provide an overview of CIS and information on USDA assistance and available resources for small and mid-scale meat and poultry processors.
Retail exemption allows a meat processor to sell meat at its own retail storefront (or direct to consumer via other methods such as farmers market sales or a restaurant) without developing a HACCP plan or being inspected daily by USDA FSIS. However, the processor is still subject to periodic, risk-based inspection by USDA FSIS and/or state and county authorities (e.g. county health departments). In addition, the meat used to produce retail products (fresh cuts or processed meats) must come from livestock inspected by USDA FSIS or the state inspection agency in the processor’s own state. See the full CFR 303.1 regulations here.
If the retail exempt product is derived from state inspected product, the retail exempt product can only be sold within the state where the meat / poultry was inspected. So if, for example, the state of Iowa inspected meat / poultry was used for in the production of a retail exempt product, the retail exempt product could only be sold within the state of Iowa.
If the retail exempt product is derived from a USDA FSIS inspected product, the retail exempt product can be sold in other states. So if, for example, a retail exempt operation in Iowa uses USDA FSIS inspected product for its retail exempt production, the retail exempt product could be sold anywhere in the 50 states.
Retail exempt processing include operations of types traditionally and usually conducted at retail stores and restaurants, such as:
(a) Cutting up, slicing, and trimming carcasses, halves, quarters, or wholesale cuts into retail cuts such as steaks, chops, and roasts, and freezing such cuts;
(b) Grinding and freezing products made from meat;
(c) Curing, cooking, smoking, rendering or refining of livestock fat, or other preparation of products, except slaughtering or the retort processing of canned products;
(d) Breaking bulk shipments of products;
(e) Wrapping or rewrapping products.
Only (a), (b), (d), and (e) are allowed for wholesaled products (meaning that the processes listed under (c) above are NOT allowed for wholesaled product). Retail-exempt wholesaling is limited to only 25% of the dollar value of the processor’s total sales or $75,700 for red meat and meat products and $56,600 for poultry products per calendar year, whichever is LESS (Federal Register 8/15/18). The dollar value limit is reevaluated annually by FSIS.
- Further Reading: A Guide to Retail Meat Sales in Tennessee. While this document was written for TN specifically, we think it is valuable for all looking to market local meats. Basic Regulatory Considerations for Retail and Non-retail Meat Sales in Tennessee discusses retail meat sale regulations, non-retail meat sales and custom-exempt processing. While regulations from state to state are often quite similar, they can vary: if you are outside of TN, double check with your state regulators before moving forward with any information found in the guide.
A custom-exempt plant can only slaughter and process livestock for the exclusive use of the owner(s). Like a retail exempt plant, the facilities will still be subject to periodic, risk-based inspection by USDA FSIS and/or state authorities. Custom exempt plants still have to comply with the Federal Meat Inspection Act (FMIA) and Poultry Products Inspection Act (PPIA), along with Humane Methods of Slaughter Act (HMSA). This directive 5930.1 explains more how USDA FSIS reviews custom plants. Custom exempt plants may also operate a retail exempt butcher counter in which they sell meat they processed from USDA (or state) inspected carcasses that were not slaughtered at their custom exempt plant. Custom-exempt slaughter may happen on a farm using a licensed mobile slaughter trailer or at a brick and mortar facility. Custom exempt meat is marked “not for sale”.
A red meat plant can simultaneously do work that is custom-exempt, retail-exempt and state or federally inspected; a poultry plant cannot. Depending on the state, a plant may or may not be both state and federally inspected. There are several federal poultry processing exemptions, all of which are complex and only exempt facilities processing less than 20,000 birds per calendar year.