In response to several meat and poultry recalls associated with the addition of ingredients, spices, or sauce after the lethality- process step, USDA’s Food Safety and Inspection Service (FSIS) has reissued FSIS Notice 01-11 providing Inspection Program Personnel (IPPS) with instructions for verifying that plant HACCP plans:

  1. adequately address all hazards inherent to the production of ready-to-eat products;
  2. include all steps in their hazard analysis; and
  3. consider potential hazards from ingredients added to the product post lethality treatment.

The notice instructs IPPs to not assume that non-meat ingredients are treated to address pathogens of concern and to be aware of possible post-lethality processing environment recontamination through contact with insanitary surfaces; improper handling by establishment employees; the addition of raw materials or ingredients after the lethality step; and contact with insects or animals Additionally, IPPs are to verify that plants have evaluated supplier interventions; checked purchasing specifications; and performed any in-plant testing verification identified by the establishment as necessary.  The notice is available here.