Raw Product – Not Ground HACCP Process Category

Aligned with USDA-FSIS HACCP Requirements – 9 CFR Part 417

Requirement Overview

The HACCP Raw Product – Not Ground Process Category applies to establishments handling whole cuts, primal cuts, or non-ground portions of meat, poultry, or seafood. Under 9 CFR Part 417, establishments must conduct hazard analyses and implement critical control points to prevent contamination and maintain product safety.

Non-ground products carry lower microbial mixing risk than ground products but require careful handling to prevent cross-contamination, maintain temperature control, and ensure proper storage.

Disclaimer: This content is for educational and compliance support purposes only and is not affiliated with or endorsed by USDA or FSIS. For official guidance, refer to the USDA FSIS website.

Key Compliance Objectives

  • ✓ Identify hazards specific to whole or non-ground products (Salmonella, Listeria, chemical residues)
  • ✓ Validate storage, handling, and trimming procedures as CCPs
  • ✓ Implement monitoring for temperature and cross-contact prevention
  • ✓ Maintain thorough documentation for regulatory and third-party audits

Step-by-Step Compliance Implementation

1. Develop Non-Ground Product HACCP Strategy

  • Core Hazard Areas:
  • • Pathogen contamination during cutting, trimming, or deboning
  • • Cross-contact between raw products and shared equipment
  • • Temperature abuse during storage and transport
  • Intervention Examples:
  • • Pre-chill and proper storage
  • • Equipment sanitation between product types
  • • Cross-contact prevention via separation or color-coded tools
  • Evidence to Maintain:
  • • Hazard analysis and CCP determination
  • • Process flow diagrams for all non-ground lines
  • • Documentation of separation and storage procedures

  • Testing Frequency by Risk Level:

Risk Level Verification Method Recommended Frequency
High (e.g., peanut lines) ELISA + ATP testing After every cleaning cycle
Medium (shared lines) Visual + ATP Weekly
Low (dedicated equipment) Visual inspection only Monthly

  • Intervention Examples:
  • • Steam vacuum applications for localized removal of visible contamination on carcass surfaces
  • • Organic acid sprays (e.g., lactic or acetic acid) applied to reduce microbial load post-dressing
  • • Hot water pasteurization cabinets for whole-carcass thermal intervention prior to chilling

  • Evidence to Maintain:
  • • Hazard analysis documents detailing biological, chemical, and physical risks by product and process
  • • Process flow diagrams and decision trees showing CCP identification and control logic
  • • Scientific, regulatory, and industry supporting documents for intervention effectiveness and CCP selection

2. Validate Handling & CCP Processes

  • Validation Protocol Should Include:
  • • Verification of storage temperatures and handling procedures
  • • Swab testing of contact surfaces for pathogens
  • • Worst-case scenario runs (e.g., high load, peak production)
  • • Calibration of thermometers and monitoring devices
  • Evidence to Maintain:
  • • Validation reports with testing results
  • • Equipment cleaning and sanitation logs
  • • CCP monitoring records
  • • Calibration certificates

3. Implement Routine Monitoring

  • Monitoring Program Components:
  • • Temperature checks during storage, processing, and transport
  • • Sanitation verification of contact surfaces
  • • Verification of separation of product types to prevent cross-contamination
  • • Logging corrective actions for deviations
  • Evidence to Maintain:
  • • Monitoring logs with dates, locations, and responsible personnel
  • • Corrective action documentation
  • • Trend reports for recurring issues

4. Monitor, Analyze & Improve

  • Data Management Best Practices:
  • • Conduct trend analysis for temperature deviations and cross-contamination incidents
  • • Review CCP monitoring records and corrective actions on a scheduled basis
  • • Reassess and update the HACCP plan annually or when process or product changes occur
  • Evidence to Maintain:
  • • Monthly analysis and trend reports
  • • Root cause investigation documentation and corrective actions taken
  • • Updated SOPs and related training records

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Solution
No validation of storage or handling procedures Perform in-plant verification and record results
Equipment cross-contamination Implement dedicated tools, color-coding, and cleaning logs
Temperature monitoring gaps Set up automated or manual monitoring for all critical points
No microbial verification Include swab testing of contact surfaces
Outdated hazard analysis Update annually or after significant process changes

Auditor Verification Checklist

  • Auditors will expect to review:
  • • Hazard analysis and CCP justification for non-ground product operations
  • • Validation files supporting storage controls, handling procedures, and sanitation effectiveness
  • • Monitoring records for temperature management and cross-contact prevention
  • • Corrective action reports demonstrating response to deviations
  • • Process flow diagrams covering all non-ground product pathways

Implementation Roadmap

Build Your Program

  • ✓ Identify hazards and CCPs for non-ground product lines
  • ✓ Map process flow diagrams
  • ✓ Develop monitoring and corrective action procedures

Train and Validate

  • ✓ Train staff in handling, separation, and sanitation
  • ✓ Validate storage and processing procedures
  • ✓ Verify calibration and monitoring competency

Operate and Monitor

  • ✓ Conduct routine CCP monitoring and sanitation checks
  • ✓ Track deviations and corrective actions
  • ✓ Maintain all required logs

Improve Continuously

  • ✓ Perform annual HACCP reassessments
  • ✓ Revalidate CCPs after process or equipment changes
  • ✓ Conduct monthly trend analysis

Why This Matters?

Effective HACCP for non-ground products:

  • ✓ Reduce pathogen and cross-contamination risks
  • ✓ Ensure compliance with FSIS regulations
  • ✓ Protect consumer safety and brand reputation
  • ✓ Demonstrate due diligence during inspections

Raw Product – Not Ground HACCP Services & Pricing

HACCP Service Description Price Action
Non-Ground HACCP Assessment Comprehensive hazard analysis, CCP identification, and process flow mapping for non-ground product lines such as primal cuts, whole-muscle products, or portioned items, with alignment to Codex and FSIS expectations. $599 / session Get Started
Storage & Handling Validation Validation of temperature control, receiving conditions, cold room management, product segregation, and sanitation procedures to support pathogen mitigation and cross-contamination prevention. $899 / project Get Started
Temperature & Sanitation Monitoring Setup Development and implementation of monitoring logs for storage, cutting, trimming, packaging, and distribution stages, including sanitation checkpoints and pre-operation verification. $499 / module Get Started
Corrective Action Program Root-cause analysis and deviation management for CCP failures, sanitation non-compliances, temperature excursions, packaging defects, and response documentation aligned with regulatory requirements. $699 / project Get Started
Verification & Review Periodic assessment of monitoring performance, temperature trends, sanitation validations, and handling controls to support audit readiness and internal compliance evaluations. $999 / month Get Started
HACCP Toolkit Includes non-ground specific flow diagrams, CCP monitoring logs, corrective action templates, sanitation validation worksheets, and audit-ready reference forms. $1,299 one-time Get Started
Implementation Support Guidance for personnel training, CCP execution, monitoring system setup, documentation control, and regulatory alignment for non-ground product operations. $699 / project Get Started

Need Help Developing or Validating Your Non-Ground Product HACCP Program?

Consultare Inc. Group provides:

  • ✓ Non-ground product HACCP plan development
  • ✓ CCP validation and intervention support
  • ✓ Monitoring and sanitation training materials
  • ✓ Audit preparation and documentation templates

GET STARTED NOW

This document is for internal training and compliance use only and is not affiliated with USDA or FSIS.

Please refer to official USDA FSIS guidelines for regulatory requirements.