Meat and Poultry HACCP Plan: Retail Kitchens vs USDA Plants

A meat and poultry HACCP plan can mean two very different documents, and mixing them up causes a lot of confusion. In a USDA-inspected plant, HACCP is a federal requirement with its own rules. In a restaurant, butcher counter or caterer, meat and poultry safety falls under your state's food code, which is based on the FDA Food Code, and a written HACCP plan is only required for certain processes. This guide explains both, then shows how a retail kitchen should build the meat and poultry part of its plan.

It is written for US restaurant owners, butcher shops, grocery meat departments, caterers and food-safety managers. Whatever you produce is a draft for your health department (or FSIS, for plants) to review.

Two systems: USDA plants and retail food establishments

USDA FSIS official establishments

Slaughterhouses and processing plants that operate under USDA inspection must have HACCP systems under 9 CFR Part 417. That rule requires a hazard analysis, a written HACCP plan for each product where hazards are reasonably likely, critical control points, critical limits, monitoring, corrective actions, verification and record keeping, along with sanitation procedures. Plants also deal with inspection personnel on site, sampling programs and specific product rules.

If you sell meat products wholesale to other businesses, or you process meat that crosses state lines, you may be in this system or a state equivalent. That is beyond the scope of a restaurant plan. Talk to FSIS or your state meat inspection program.

Retail food establishments under the Food Code

Restaurants, caterers, food trucks, and many retail butcher counters are regulated by state and local health departments using the FDA Food Code 2022 or an earlier edition. There are retail exemptions from federal inspection for operations that meet certain conditions, such as selling mostly to household consumers. The exact limits are set by federal and state rules, so confirm your status with your state meat inspection program if you cut, grind or process meat for sale beyond normal restaurant cooking.

Under the Food Code, a written HACCP plan is required when you do a special process such as:

• Curing or smoking meat for preservation.
• Reduced oxygen packaging, including vacuum packing and sous vide, unless you meet the exemptions in 3-502.12.
• Using food additives to make a food non-TCS.
• Any process you request a variance for.

Section 8-201.13 sets when the plan must be submitted. Our post on when a HACCP plan is required walks through the triggers.

For normal cooking of burgers, steaks and chicken, you follow the Food Code's cooking, cooling and holding rules. Many restaurants still put meat and poultry into a HACCP plan because those are the foods with the highest risk on the menu.

Hazards in meat and poultry

Biological hazards

The main ones are bacteria that raw meat and poultry commonly carry:

• Salmonella in poultry, eggs and some meats.
• Campylobacter in poultry.
• Shiga toxin-producing E. coli (such as O157:H7) in ground beef and some intact beef cuts that are tenderized or injected.
• Listeria monocytogenes in ready-to-eat meats and deli products.
• Clostridium perfringens in large batches of cooked meat and gravy that cool slowly.

Chemical hazards

Allergens in marinades and coatings, cleaning chemicals, and curing agents such as sodium nitrite if you cure meat.

Physical hazards

Bone fragments, metal from grinders or slicers, and broken thermometers.

The key CCPs for meat and poultry in a restaurant

Cooking

Cooking is the main kill step. The Food Code limits in 3-401.11:

• Poultry, stuffed meats and stuffing containing meat: 165°F for less than 1 second.
• Comminuted (ground) meats, injected meats and mechanically tenderized meats: 155°F for 17 seconds. The Food Code also lists equivalent time and temperature combinations.
• Whole-muscle intact beef, pork, lamb, fish, and eggs for immediate service: 145°F for 15 seconds.
• Whole-muscle intact beef steaks may be served undercooked if the surface is cooked to 145°F and the steak is a whole intact cut, with a consumer advisory where required.
• Roasts have their own time and temperature table in the Food Code.

USDA FSIS publishes a safe minimum temperature chart for consumers that uses 160°F for ground meat and 145°F plus a 3-minute rest for whole cuts. Restaurants follow the code their health department enforces, which is usually the Food Code numbers. If customers or staff ask why the numbers differ, that is the reason.

Monitor by probing the thickest part of the food with a calibrated thermometer. For burgers, probe a patty from each grill load. For chicken, probe the thickest piece. Record the lowest reading.

Cooling

Cooked meats cooled for later use (roasts, braised meats, taco meat, gravies, stocks) are a classic cause of C. perfringens outbreaks. The Food Code (3-501.14) requires:

• 135°F to 70°F within 2 hours.
• 70°F to 41°F within the next 4 hours, for 6 hours total.

Cut large roasts into pieces, spread ground meat in shallow pans, and use ice baths for sauces and gravies. See our food cooling rules post and print a cooling log.

Reheating

Cooked and cooled meats reheated for hot holding must reach 165°F for 15 seconds within 2 hours (3-403.11). See reheating food to 165°F.

Hot and cold holding

Hot holding at 135°F or above. Cold holding at 41°F or below (3-501.16). Check and log at a set frequency. See cold holding vs hot holding temperatures.

Flow diagram for a restaurant chicken dish

For braised or roasted meats that are cooked ahead, add cool, cold store and reheat steps with their own CCPs.

Hazard analysis example: burgers

| Step | Hazard | Significant? | Control | |---|---|---|---| | Receive ground beef | E. coli O157:H7 present, temperature abuse | Yes | Receive at 41°F or below; reject warm product | | Cold store | Growth above 41°F | Yes | Cold holding checks | | Form patties | Cross-contamination to other foods | Yes, prerequisite | Separate boards, handwashing | | Grill | Survival of E. coli | Yes | CCP: 155°F for 17 s | | Serve | Contamination from hands | Yes, prerequisite | No bare-hand contact with ready-to-eat items |

Write the reasoning in a sentence for each. More in our hazard analysis examples.

Undercooked burgers and steaks

Many restaurants serve burgers medium rare on request. The Food Code allows raw or undercooked animal foods to be served on consumer request with a consumer advisory (3-603.11), except to highly susceptible populations such as hospitals and nursing homes. The advisory has a disclosure (identifying the items) and a reminder (that eating raw or undercooked foods may increase the risk of foodborne illness). Your health department may have specific wording. Make sure the menu and any delivery app listings show it.

Intact whole-muscle steaks are different from ground or tenderized meat, because pathogens are mostly on the surface. Mechanically tenderized and injected meats carry surface bacteria into the center, which is why the Food Code treats them like ground meat.

Preventing cross-contamination

Cross-contamination from raw meat and poultry to ready-to-eat food is one of the main ways meat causes illness, even when the meat itself is cooked properly. Prerequisite programs should cover:

• Storage order: in the refrigerator, store raw meat and poultry below ready-to-eat food, with poultry on the bottom because it has the highest cooking temperature.
• Separate cutting boards and knives, color coded if you can.
• Handwashing after handling raw meat and before touching anything else.
• Cleaning and sanitizing surfaces after raw meat prep.
• Gloves changed between raw and ready-to-eat tasks.

See our sanitation SOP post for cleaning steps.

Butcher counters and in-house grinding

If you grind meat in house, cut steaks, or make sausages, more steps enter the plan:

• Grinding logs. Some jurisdictions and buyers expect a grinding log that records source lots, date and time of each grind, and cleaning of the grinder between sources. This helps trace a problem back to the source if a recall happens.
• Grinder cleaning. Grinders are hard to clean and can carry bacteria between batches. Write a detailed cleaning procedure.
• Temperature during cutting. Keep meat cold during processing. Work in small batches and return product to the cooler.
• Sausage making. Fresh sausages are TCS foods. Cured or fermented sausages are a special process needing a HACCP plan and often a variance. See cured and smoked foods.

If you sell packaged ground meat or sausages wholesale to other businesses, you may cross into FSIS or state inspection territory. Ask before you start.

Vacuum packing and sous vide meats

Vacuum packing raw or cooked meat is reduced oxygen packaging under Food Code 3-502.12. That section allows some ROP without a variance if you meet its conditions and have a HACCP plan, and requires a variance for others. Cooking meat sous vide is covered by the same section. Our sous vide HACCP plan and reduced oxygen packaging HACCP plan pages explain the details.

Receiving meat and poultry

Check every delivery of raw meat and poultry before it goes into the cooler. Probe between packages or into a sacrificial piece for product temperature, which should be 41°F or below under Food Code 3-202.11. Look for torn packaging, leaking cases, and signs of thawing and refreezing on frozen product. Reject anything that fails and write it on the receiving log. Our receiving temperature log post has a layout you can print.

Records for meat and poultry

| Record | Frequency | Notes | |---|---|---| | Receiving temperatures | Each delivery | Reject meat above 41°F | | Cooking temperatures | Each batch or per plan | Lowest reading per batch | | Cooling log | Each batch cooled | Start, 2 h, end | | Reheating log | Each batch reheated | 165°F within 2 h | | Holding log | Every 2 to 4 hours | Hot and cold | | Grinding log | Each grind, if you grind | Source lot and cleaning | | Thermometer calibration | Daily or weekly | Ice point method | | Corrective actions | As needed | What, why, what changed |

Download printable forms from free logs.

Corrective actions

• Cooking temperature not met: continue cooking until it is. Recheck.
• Raw meat received above 41°F: reject the delivery and note it.
• Cooling stage 1 missed: reheat to 165°F and restart cooling, or discard.
• Cooling stage 2 missed: discard.
• Cold holding above 41°F for unknown time: discard.
• Cross-contamination observed (raw chicken juice on salad greens, for example): discard the affected food, clean and sanitize, retrain.

More in HACCP corrective actions examples.

Verification

• Weekly manager review of all logs.
• Calibration of thermometers. See thermometer calibration log.
• Observe cooks probing food during service and compare to the log.
• Review the plan when you change suppliers, add a new cut or product, or change equipment.
• Review after any illness complaint.

HACCP verification and record keeping has a simple schedule.

Where FSIS and Food Code numbers differ

People are often surprised that the numbers are not the same everywhere:

| Food | Food Code (restaurants) | FSIS consumer chart | |---|---|---| | Poultry | 165°F, under 1 s | 165°F | | Ground beef | 155°F, 17 s | 160°F | | Whole cuts | 145°F, 15 s | 145°F + 3 min rest | | Leftovers reheated | 165°F within 2 h for hot holding | 165°F |

The Food Code uses time at temperature because restaurants can measure and control it. Consumer guidance uses simpler numbers with built-in margin. Both are based on killing pathogens; they just serve different audiences. In your restaurant plan, use the Food Code numbers your health department enforces.

Common products and where they go wrong

Rotisserie chicken

Rotisserie birds are cooked whole, held hot for hours and often chilled and sold cold the next day. Cooking is the first CCP: probe the thickest part of the thigh and breast of several birds per load. Hot holding is the second: check product temperature, not the display setting, every 2 hours or as your plan sets. If unsold birds are cooled for later sale, cooling becomes a third CCP, and whole birds cool slowly. Many operators pull the meat or quarter the birds before cooling.

Barbecue: brisket and pulled pork

Low and slow cooking can make it hard to know when the meat has passed the cooking limit, and very large cuts take a long time to cool. Probe the thickest part at the end of the cook. For leftovers, slice or pull the meat and spread it in shallow pans before cooling. Reheat to 165°F within 2 hours for hot holding. If you smoke meat for flavor and then cook it fully, that is cooking. If you smoke for preservation, that is a special process. Our cured and smoked foods post explains the line.

Chicken wings

Wings are small and cook fast, but fryer loads vary in size and frozen wings dropped into oil can come out undercooked at the joint. Probe several wings from each load at the thickest part, not the tip. If wings are par-cooked and finished later, the par-cook step needs its own procedure. The Food Code has specific conditions for non-continuous cooking (3-401.14), and many health departments want those written procedures before you use the method.

Taco and chili meat

Ground meat cooked in large batches and held for service. Cook to 155°F, hold at 135°F or above, and cool any leftover in shallow pans. Chili and taco meat are classic C. perfringens foods when cooled in deep pots.

A sample CCP summary for meat and poultry

| CCP | Item | Critical limit | Monitoring | Corrective action | Record | |---|---|---|---|---|---| | 1 | Grilled chicken | 165°F (3-401.11) | Probe thickest piece each batch | Continue cooking | Cook log | | 1 | Burgers | 155°F for 17 s (3-401.11) | Probe one per grill load | Continue cooking | Cook log | | 2 | Braised short rib (cooled) | 135 to 70°F in 2 h; to 41°F in 6 h | Probe at start, 2 h, end | Reheat and restart, or discard | Cooling log | | 3 | Reheated short rib | 165°F within 2 h (3-403.11) | Probe at end of reheat | Discard if not reached in 2 h | Reheat log | | 4 | Hot hold | 135°F or above (3-501.16) | Probe every 2 h | Reheat if known under 2 h, else discard | Holding log |

Training cooks on meat and poultry

Most failures come from a cook trusting color, time or feel instead of a thermometer. Train each cook to probe properly: thickest part, away from bone, and long enough for the reading to settle. Show them how to calibrate in ice water and when to do it. Make sure they know the three main cooking numbers by heart (165, 155, 145) and where the chart is posted. Our HACCP training post has a simple sign-off format.

Writing a meat and poultry HACCP plan for a restaurant

1. List every meat and poultry menu item and group them by process: cook and serve, cook and hold, cook and cool, special process.
2. Draw a flow diagram for each group.
3. Do a hazard analysis.
4. Set CCPs with Food Code limits and cite the section numbers.
5. Write monitoring, corrective actions, verification and records for each.
6. Add prerequisite programs for storage order, cross-contamination, cleaning and employee health.
7. If you do a special process, add a full HACCP section for it and talk to your health department about a variance.

Our guide to writing a HACCP plan explains each part, and the HACCP plan example shows a finished plan with meat and poultry processes.

Build your plan

The HACCP builder includes cooking, cooling, reheating, hot holding and cold holding for meat and poultry, with Food Code limits and section numbers filled in, plus printable logs. Sous vide and reduced oxygen packaging are covered as special processes. The first process is free and the Plan Pack covers all of them for a one-time price. The output is a draft for your health department to review and approve.

Frequently asked questions

Do restaurants need a meat and poultry HACCP plan?

Not automatically. Under the FDA Food Code, restaurants need a written HACCP plan for special processes such as curing, smoking for preservation, sous vide or reduced oxygen packaging, or when asking for a variance. Routine cooking of meat and poultry is covered by the code's cooking, cooling and holding rules.

What is the cooking temperature for chicken in a restaurant?

The FDA Food Code (3-401.11) sets 165°F for less than 1 second for poultry. Food Code tables also allow some lower temperature and longer time combinations for certain foods, but 165°F is the usual critical limit.

What is 9 CFR 417?

It is the USDA FSIS regulation requiring HACCP systems in official meat and poultry establishments, the plants that operate under USDA inspection. It is separate from the FDA Food Code that covers most restaurants.

Is ground beef cooked to 155°F or 160°F?

The FDA Food Code for food establishments uses 155°F for 17 seconds for comminuted meat. USDA FSIS consumer advice uses 160°F for ground meat. Restaurants follow the code their health department enforces.