A USDA-inspected meat plant must have a HACCP plan, under 9 CFR part 417: a flow chart, a hazard analysis, critical control points, and records kept a year for refrigerated product. For bacon, the plan turns on two numbers. The cure: pumped bacon is made with sodium nitrite at 120 ppm ingoing and sodium ascorbate or erythorbate at 550 ppm, set by USDA's rule, so the brine formula and the pump weight are a critical control point. And the chill: after hours in a warm smokehouse, bellies have to cool fast enough that bacteria don't grow, within the time the plant's supporting documentation sets. Bacon that's smoked but not cooked is raw, so its label carries safe handling instructions. In the example below, a small smokehouse's pumped bacon comes down to two critical control points: curing and chilling. Below are the rules, the hazard analysis, the plan, a week of records, and a free worksheet.
The short version
- Every USDA-inspected establishment has a hazard analysis, a flow chart and a HACCP plan for each product.
- Pumped or massaged bacon: sodium nitrite at 120 ppm ingoing, or potassium nitrite at 148 ppm, plus 550 ppm sodium ascorbate or erythorbate.
- Immersion-cured bacon: no more than 120 ppm sodium nitrite; dry-cured: no more than 200 ppm.
- Chilling after smoking is a critical control point in this plan, timed by the plant's supporting documentation.
- Raw bacon carries safe handling instructions on the label.
- The plan is written and reassessed by someone who completed a course in the seven HACCP principles.
- Records: 1 year for refrigerated product, 2 years for frozen, preserved or shelf-stable.
- TaroStack keeps each batch's pump weights and chill readings on its batch record. More below.
The rules
| Rule | What it says |
|---|---|
| HACCP plan | Every official establishment conducts a hazard analysis, prepares a flow chart, and has a plan for hazards reasonably likely to occur |
| Records | Kept at least a year for refrigerated product and two years for frozen, preserved or shelf-stable; offsite after six months if retrievable within 24 hours |
| Training | The plan's developer completed a course in the seven HACCP principles applied to meat, poultry or egg products |
| Pumped bacon | 120 ppm sodium nitrite ingoing, or 148 ppm potassium nitrite; 550 ppm sodium ascorbate or erythorbate |
| Immersion-cured bacon | Sodium nitrite not more than 120 ppm ingoing |
| Dry-cured bacon | Sodium nitrite not more than 200 ppm ingoing |
| Raw meat label | Safe handling instructions for meat that isn't ready to eat |
The HACCP rule is 9 CFR part 417; the bacon cure rule is 9 CFR 424.22(b); and the label rule is 9 CFR 317.2(l). A custom-exempt or retail operation follows different rules, explained in custom exempt meat processing. This is general information, not legal advice.
An example: the hazard analysis
Root River Smokehouse, a made-up USDA-inspected smokehouse in Lanesboro, Minnesota, I use in these examples, makes pumped, hickory-smoked bacon for grocers:
| Step | Hazard | Reasonably likely? | Control | CCP? |
|---|---|---|---|---|
| Receiving pork bellies | Pathogens on raw pork | Yes | Received cold; raw product, cooked by the consumer, with safe handling instructions | No |
| Cold storage | Growth | No | Cooler at 40°F or below | No |
| Curing: brine injection | Nitrite outside the regulated amount | Yes | Brine by weight; pump weight checked each batch | CCP 1 |
| Smoking | Growth while warm | Yes | Smoke schedule, then chilling at CCP 2 | No |
| Chilling | Growth while cooling | Yes | Chill to 40°F within the documented time | CCP 2 |
| Slicing and packaging | Contamination; metal | No | Slicer cleaned and checked | No |
| Labeling | Missing safe handling instructions | No | Label check | No |
The plan
| CCP | Critical limit | Monitoring | Corrective action | Verification |
|---|---|---|---|---|
| CCP 1 Curing | 120 ppm sodium nitrite and 550 ppm sodium erythorbate ingoing, from the brine formula and the pump weight (example pump target 10%, 9.5% to 10.5%) | Weigh bellies before and after injection; compute pickup and ingoing nitrite | Hold, recalculate, adjust or divert; find the cause | Scale checked daily; formula and records reviewed before release |
| CCP 2 Chilling | 40°F or below within the documented time (example: 10 hours) | Probe the thickest bellies at set times after smoking | Hold and evaluate; condemn if it can't be shown safe | Thermometer checked daily; records reviewed before release |
The pump range and chilling time are examples; the real ones come from the plant's formula and supporting documentation. How a monitoring record is kept is in HACCP record keeping form example, and a dried meat plan in jerky HACCP plan.
A week of records
| Date | Lot | CCP | Reading | Limit | OK? | Action |
|---|---|---|---|---|---|---|
| Oct 5 | BCN-1005 | Curing, pickup | 10.1% | 9.5% to 10.5% | Yes | |
| Oct 5 | BCN-1005 | Chilling | 38°F | 40°F or below | Yes | |
| Oct 7 | BCN-1007 | Curing, pickup | 11.2% | 9.5% to 10.5% | No | Injector pressure high; nitrite recalculated at 134 ppm; bellies diverted from bacon; injector reset |
| Oct 7 | BCN-1007B | Curing, pickup | 10.0% | 9.5% to 10.5% | Yes | |
| Oct 7 | BCN-1007B | Chilling | 39°F | 40°F or below | Yes |
Get the worksheet
Download the bacon HACCP plan worksheet. Four sheets: the hazard analysis, the HACCP plan with a place to sign, a monitoring log that checks each reading against its limits, and a read-me. It's a worksheet to organize your own plan, not a plan to copy. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
Every batch has belly weights before and after injection, a calculated nitrite, chill readings, and a review before release. A clipboard holds a week; the inspector can ask about any batch from the last year.
How TaroStack does it
TaroStack keeps each batch's pump weights and chill readings on its batch record.
Readings on the batch. Fields of your own on the batch record hold the green weight, the pumped weight, the pickup and the chill readings, and printable batch-record forms carry the sign-off for the pre-shipment review.
Held until reviewed. A batch can be held, kept out of what can be sold, until its records are reviewed.
Where it went. Each grocer's order records the lots it got, so one recall report shows every store a batch reached.
| The job | Clipboard | In TaroStack |
|---|---|---|
| A batch's pickup and chill | Written on the cure sheet | Fields on the batch record |
| A batch waiting for review | A tag on the rack | A hold until released |
| Which grocers got a batch | Invoices | One recall report |
Lots, batches and orders are on every plan, from $49 a month. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.