Objective: To provide inspection program personnel some thought processes for determining whether a federally inspected establishment producing a Jerky product has appropriately addressed humidity during the lethality process step.
You are a GS-10, Relief Consumer Safety Inspector (CSI) assigned to cover a patrol assignment that includes several small and very small establishments producing jerky products. In one of the establishments in your patrol you are performing a scheduled 03F01 procedure and beef jerky is on the production schedule for the day. You have selected the HACCP recordkeeping regulation for verification at the lethality CCP and have selected the recordkeeping component to verify the requirement.
You find that the establishment has not set a humidity level at the lethality CCP (e.g., the humidity is not held at 90%). The establishment is aware that surface drying alone could result in the inadequate destruction of pathogenic microorganism and, therefore, product adulteration. Instead, the establishment's HACCP plan states that the dampers on the smokehouse remain closed during the lethality step to seal the oven and hold humidity within the chamber. The establishment monitors the humidity using a wet bulb thermometer during the lethality step and verifies the presence of humidity in the smokehouse during at least 50% of the processing time.
Based on this finding, you decide to verify the establishments' validation and decision-making documentation, which would support their use of adequate humidity during the lethality process. You find that the establishment has maintained historical documentation which demonstrates their lethality system has successfully maintained humidity in the smokehouse during at least 50% of the processing time. In addition to the historical documentation, the establishment provided their guidance material, which were copies of the "Compliance Guideline for Meat and Poultry Jerky Produced by Small and Very Small Plants" which was addressed in Notice 02-05, and "Relative Humidity and Time/Temperature for Cooking /Heating for the Production of Other Ready-to-Eat Meat and Poultry Products" which was addressed in Notice 43-05.
You now decide to verify whether the steps included in the HACCP plan are supported. First, you conclude that the historical data is sufficient. So next, you review the guidance document to see whether the material states that closed dampers on the smokehouse effectively seal the oven and hold humidity within the chamber. Upon review of the material you find that the material suggests such a method has a means to provide sufficient humidity to prevent surface drying prior to lethality.
At this time you determine there is regulatory compliance and enter "performed" for the scheduled 03F01.
Please call the Technical Service Center if you have any questions.
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