Jerky under the US FDA food code

Producing meat or poultry jerky is considered as a “Specialized Process” that requires a pre-approved HACCP plan.  There are safety concerns as follows:

• destruction of meat or poultry pathogens in the process
• room temperature storage or refrigerated storage over 7 days
• vacuum packaging
• curing salts use

Q: Can I make Jerky that does not require HACCP?  A: This is debatable, but not likely.  While “drying” foods is not specially called out as a special process in the food code; producing a non-PHF food from a PHF food is.

Q: Could an operator dry jerky and freeze it?  A: As mentioned above, the food code does not specifically address drying meats as a Specialized Process in 3-502.11.  Some regulators view “drying meats” as a specialized process no matter what. The main concern they would have is the drying process chosen safe with regard to the first bullet point above.  Will the drying process demonstrate a 5 log reduction of E. coli O157:H7?   For this reason HACCP is required that contains scientific validation that the chosen process is safe.