The following is a file containing two USDA FSIS authored guidance documents on cured, fermented, and dried meats including the USDA FSIS model HACCP plan.  It is recommended that retail operators wanting to produce dry and semi-dry sausage and dried whole muscle meats use this guidance to educate themselves before they consider writing a HACCP plan. Secondly, operators should become familiar with the formatting and required elements of a food code HACCP Plan as specified in the latest edition of the food code section 8-201.14.


Categorization of Special Process: Basturma is a dried whole muscle meat product. It is made in a similar manner to dried ham (prosciutto, parma and country ham), dried pork belly (pancetta), dried pork shoulder (coppa), and dried beef round (bresaola, beef prosciutto, and basturma).

Product Characteristics: Boneless beef, usually a high quality cut (incl tenderloin); salt (to dry cure – sodium nitrite recommended); spice paste (to cover surface).

Flow of foods: Intact beef rounds are trimmed of fat.  About 5 kg salt (or salt cure) is dry rubbed onto the surface of 50 kg meat.  The salt cure meat is placed into refrigeration for several days allowing meat juices to drain.  Some traditional Turkish processes include a several hour pressing step here to shape the meat and press out meat juice.  After the first dry salting (and pressing) the meat is again salted and dry cured for several more days at refrigeration (termed “burning”).  When the meat has a WPS ≥ 4.5% and/or an Aw of ≤ 0.96, rinse off salt. Optionally, press again at refrigeration.  Cover the surface with the spice paste.  Hang and dry Basturma at 60-75°F to Aw ≤ 0.85.  Refrigerate the Basturma as a non-RTE product. The final product is either sliced and packaged for sale, or sold in the whole form for slicing by the final customer. Cook slices before consumption. Basturma is cooked with scrambled eggs, cut into slices and fried, grilled lightly over a charcoal fire, or added as an ingredient to various stews and cooked.

Alternatively, whole beef Basturma can be vacuum packaged and pasteurized to become RTE.  The meat must obtain an internal minimum temperature of 145°F or 130°F for 30 minutes to be considered pasteurized and safe for RTE status. Even as a RTE dried food, it should still be refrigerated for best quality.  Note that under the US FDA model food code, once the meat reaches ≤ Aw 0.88 it is considered a non-PHF/TCS food and refrigeration is not “required” for safety.  Vacuum packaging of the non-PHF meat would not need additional HACCP controls under reduced oxygen packaging special processes.

Raw meat >>>> Trim fat,
trim width
>>>> Dry-salt-cure
@ ≤ 41°F
>>>> Salt penetration cure
@ ≤ 41°F to 4.5% WPS
(Aw ≤ 0.96)
Rinse off
Surface salt
>>>> Cover surface
with spice paste
>>>> Dry @ 60-75°F
(15-24°C) to
≤ Aw 0.85
>>>> Refrigerate as a
not RTE product
(cook before use) or
for a RTE Basturma…
>>>> Immerse in 145.5°F
water until center
is 145°F or
>>>> Immerse in 130.5°F
water until center
is 130°F for 1 hour
>>>> Refrigerate as a
RTE product


CCP 1&2: Refrigerate while dry salt curing ≤ 41°F.
CCP 3: Dry ≤ 75°F to ≤ Aw 0.85
RTE CCP 4: Pasteurize to internal temperature ≥ 145°F.

Food Safety Notes:
For dried intact meat products, preservation is mostly due to the slowing or complete inhibition of surface growth, although inactivation of pathogens such as Salmonella, Listeria monocytogenes, and E. coli O157:H7 is desired. In the Basturma process, salt and refrigeration are the first hurdles that slow pathogen growth. A 6-7% WPS in the final dried product is desired.  Sodium nitrite is highly desired to inhibit C. botulinum and C. perfringens.  The USDA FSIS recommends a starting raw meat pH ≤ 5.8 as another hurdle.  Fermentation (acid production or pH drop) is not a control factor in Basturma, so the finsihed product pH will be similar to the starting raw meat pH.  A final moisture content of 40-45% is a hurdle.  An Aw 0.90 prevents growth of all pathogens (including S. aureus anaerobically) if the meat is vacuum packaged. If oxygen is present then an Aw ≤ 0.85 is required to prevent growth of all pathogens.  Lastly, the spices and spice extracts in the spice paste have pathogen inhibitory affects.

Aksu et al 2016 – Using sodium nitrite significantly increased both the safety and quality (color and oxidation) of Basturma.  Aksu noted that Turkish Food Safety law (2012) states that minimum moisture content for Basturma is 45% (not RTE) and 40% RTE.  The WPS of the finished product was 6-7%.

Ingham et al 2005 – Food Safety of the Basturma process.

Genigeorgis, C. and S. Lindroth. 1984. The safety of basturma, an Armenian-type dried beef product with regard to Salmonella. Proceedings of the 30th European Meeting of Meat Research Workers. 30:217-224.

Some chefs and retailers are turning to “natural” sources of nitrate or nitrite when curing meats.  The most common reason is to retain a claim of “natural” or preservative-free. Traditional nitrite or nitrate salt mixtures (pink salts) are food additives and preservatives that were chemically synthesized.

Some vegetable extracts such as celery juice powder contain naturally occurring nitrites and nitrates. In its natural form the vegetable extracts are mostly nitrate. Some manufacturers may culture (ferment or enzymatically convert) the nitrate into nitrite. A careful analysis of the product label is required.

When used correctly, a vegetable extract can provide the same culinary objectives as synthetic sodium nitrite/nitrate. There are no USDA standardized limits, procedures, or contact times for vegetable based nitrates or nitrites.

USDA FSIS | Are celery powder and other natural sources of nitrite approved for use as curing agents?
No, neither celery powder (whether in a pre-reduced form or with a bacterial nitrate-reducing culture) nor other natural sources of nitrite are approved for use in 9 CFR 424.21(c) as curing agents. Therefore, products that are formulated with celery powder or other natural sources of nitrite instead of curing agents in 9 CFR 424.21(c) (e.g., hot dogs and corned beef that contain celery powder instead of sodium or potassium nitrite) must be labeled as “uncured” under 9 CFR 319.2. In addition, the label must also contain the statement “no nitrates or nitrites added” per 9 CFR 317.17 that is qualified by the statement “except for those naturally occurring in [name of natural source of nitrite such as celery powder]” in order to not be considered false and misleading under 9 CFR 317.8.

 How would the use of vegetable-based powders containing nitrate or nitrate be addressed in the food code?  Looking at the ask FSIS answer above the USDA has stated:

  • they are NOT approved for use as [antimicrobial] curing agents
  • they ARE considered flavoring agents
  • labeled (retail) items would be expected to be labeled “uncured; no nitrates or nitrites added except for those naturally occurring in [name of natural source of nitrite such as celery powder]”
Therefore, it is reasonable to conclude that curing meats with vegetable-based powders under the US FDA model Food Code would be permitted for flavoring and texture.  These meat products would need to be held outside the temperature danger zone during production.

 Can an operator under the US FDA model Food Code obtain a variance for use of these products to cure meats for safety? 

Curing agents provide more than color retention; they are also important in the control of growth of Clostridium perfringens as well as Clostridium botulinum and its toxin formation in cured products.  Available research from 2011 had not yet supported that naturally occurring sources of nitrite alone can sufficiently control the growth of these pathogens when compared to products that are conventionally cured with sodium nitrite.  However, in 2016 the USDA cited: “FSIS has determined from expert elicitation that nitrite from natural sources should also control the growth of C. botulinum provided ascorbate or a cure accelerator such as erythrobate is added (askFSIS, 2016)”.

 Under Canadian Meat regulations, curing meats with cultured celery powder is permitted.  

2016. Annex C. Section 2.1 Preformed nitrites: Cultured celery powder (or other cultured vegetable juice powders approved for this purpose) may be used as an alternative source of nitrites in the production of cured or fermented meat products. Cultured celery powder contains preformed nitrites produced by bacterial action on nitrates present in the celery product. The level of preformed nitrites present in the celery powder must be declared by the manufacturer of the cultured celery powder. The producer of the meat product must determine the amount of cultured celery powder to be included in the formulation to achieve the minimum levels of nitrites needed to cure the product without exceeding the maximum allowable limit.

A Food Code variance would likely require lab findings for residual nitrite for verification of cure effectiveness. The same should hold true for nitrite or nitrate usage limits. Unlike standardized curing salts mixtures, there are no standards of nitrite or nitrate content in a celery juice powder. The recommendation would be to choose a vendor for the celery juice powder that can provide a certificate of analysis (CoA) stating the exact content of nitrite and nitrate. They should also provide a suggested usage level based on that CoA. For example, one manufacturer states that an operator should use 1.25 oz. of its powder in 25 pounds of ground meat.  After usage, send samples to a lab to verify that there are residual nitrite levels sufficient to prevent the outgrowth of C. botulinum.

Transglutaminase (Activa)

Transglutaminase is affectionately called “meat glue”. It is sold to Chefs under the trade name Activa™. There may be other brands out there. It was discovered back in 1959 as a component of the blood clotting complement.  A common example of culinary use is to bind a bacon wrap to another protein (steak, salmon, etc).  Another example seen was to bind salmon tips (leftover from fillets) wrapped in a tilapia filet.  Using transglutaminase, proteins will bind in refrigeration and hold after cooking.

None. Is it safe? Yes. This enzyme is GRAS (generally recognized as safe) and has been used for more than 10 years in meats and poultry. For foodservice a “glued” meat product is considered non-intact.

This product would not be considered a “special process”. It would not require HACCP or a food safety plan under the US FDA model Food Code.  However, it is noted above that cooking of these foods must be done to the comminuted or ground temperature for red meats of 155°F or above. Poultry would be 165°F or above. The full strength enzyme preparation is not toxic. Therefore, there is little concern for storing the raw chemical in a foodservice environment.  This product would require consumer disclosure on a label, but not a menu.  It is not a known allergen.

More: USDA Food Safety “Answers” |  Federal Register Notice of GRAS | Ajinomoto Sell Sheet

Dry aging beef (and other meats) is said to enhance flavor and tenderness.  It is often used by upscale purveyors to distinguish their products from others.  Dry aging meat is essentially aging meat without protection is a refrigerator.  Cuts are stored separate from each other to permit air flow to dry them in 1-6 weeks.  Natural enzymatic reactions result in a change of flavor and an increase in tenderness.  Another major change is the loss of moisture resulting in a more concentrated flavor, but with a corresponding yield loss.  Several vendors are selling “dry age” bags.  The intention is to seal the surface of meat while permitting moisture loss (dry aging).  In experiments with the bags the moisture loss is lowered (higher yield) while still permitting the “dry aging” process leading to flavor and tenderness attributes.  The bags will also prevent yeast and mold buildup on the surface of dry aging meats.

cc 2008 Filipe Fortes
cc 2008 Filipe Fortes

Dry aging charcuterie (salami, pepperoni, procuitto) is also possible in dry age bags.  The main benefits would be allowing moisture loss and minimizing yeast or mold surface growth.  However, caution must be used since the traditional process for these meats may not be the same when bagged versus left open.

Regulatory concerns: The main concern regulators have for using these bags under the US FDA model food code is whether the bag results in a reduced oxygen packaging (ROP) process.  The bag is moisture permeable and may or may not be oxygen permeable.  Although the bags are quite thin, an oxygen transfer rate CoA (Certificate of analysis) is needed from the bag manufacturer demonstrating an OTR over 10,000 cc/m3/24h to exclude this process from HACCP (under the food code).  If the OTR is below 10,000 or unknown then a simple HACCP plan is required.  In this case storing the meat in the bag at ≤ 41°F for ≤ 30 days total (packaging to service) or ≤ 34°F for ≤ 60 days total (packaging to service) would be acceptable.  The 30 day limit is considered two barrier packaging (refrigeration and competitive bacteria) and a “safe harbor” process in 3-502.12 of the Food Code.  The 60 day shelf life would require a regulatory variance and is justified by limiting the maximum refrigeration temperature to 34°F using a 24/7 temperature datalogger.

Resources: check out a beef research dry aging white paper here.  No endorsements intended but here are some vendor websites:;;