Procuring Local Meat, Poultry, Seafood, Game, and Eggs
November 20, 2023
The United States Department of Agriculture (USDA) released a memo that revises previous guidance from 2016 (CACFP 01-2016, SFSP 01-2016). This memo clarifies the regulatory requirements related to food safety and answers specific questions related to local meat, poultry, seafood, game, and eggs. Specifically, this guidance updates questions six, seven, and eight under Game Animals to better reflect opportunities to access domesticated and wild game animals, as well as other minor technical updates throughout.
Why It Matters
Serving traditional Indigenous foods is important, and USDA encourages Tribal Nations and other operators to source locally grown and raised foods. Therefore, it’s necessary to understand the food safety requirements for serving locally caught/sourced foods in your program.
Meat and Livestock
1. How is livestock defined?
According to 9 CFR 301.2, livestock include cattle, sheep, swine, or goat and these animals are subject to the regulations within the Federal Meat Inspection Act of 1906 (FMIA).
2. Do livestock need to be slaughtered under the U.S. Department of Agriculture (USDA) or State-inspection in order to be served in the Child Nutrition Programs (CNPs)?
Yes, all livestock sold for commercial consumption, including for service in CNPs, must be slaughtered under USDA or State inspection in either traditional brick and mortar facilities or mobile slaughter units. There are no exemptions from inspection for the slaughter of livestock to be sold as articles of commerce.
3. Do meat and meat food products such as spaghetti sauce with cooked meat need to be processed in USDA or State-inspected facilities in order to be served in the CNPs?
Not always. The further preparation of the Federal or State-inspected livestock into meat and meat food products must be done under inspection, unless exempted from inspection. The exemptions from inspection of Federal or State-inspected meat and meat food products are found in 9 CFR 303.1.
4. Can livestock slaughtered, and meat or meat food products processed in a Cooperative Interstate Shipment (CIS) facility or State Meat and Poultry Inspection (MPI) facility be served in the CNPs?
Yes, livestock slaughtered in and meat or meat food products processed under inspection in a USDA, MPI or CIS facility may be served in CNPs. These facilities may be traditional brick and mortar facilities or mobile slaughter units. Livestock and meat food products from amenable animals (meaning, species subject to the regulations found in the FMIA or the PPIA) inspected at State MPI facilities are only eligible for intrastate distribution. Animals slaughtered in and meat food products processed in CIS facilities, regardless of where the animal was raised, can be sold in interstate commerce.
5. Do livestock and meat food products donated to CNPs need to follow all inspection and processing requirements?
Yes, Food Safety and Inspection Service (FSIS) inspection and processing requirements must be followed for donated livestock and livestock products. The producer must have the livestock animal slaughtered, under Federal or State inspection. The processing must be done under inspection, unless exempted from FSIS inspection requirements. Exemptions for meat food products are found in 9 CFR 303.1(d).
1. How is poultry defined?
According to 9 CFR 381.1 domesticated poultry are chickens, turkeys, ducks, geese, guineas, ratites, or squabs and these animals are subject to the regulations of the Poultry Products Inspection Act of 1957 (PPIA).
2. What are the inspection requirements for poultry?
Poultry sold for commercial consumption must be inspected at a USDA facility, a MPI program facility, or a CIS program facility in either a traditional brick and mortar plant or a mobile slaughter unit, unless exempted from inspection requirements. Unlike livestock, poultry exemptions do allow poultry slaughter and processing to occur without benefit of Federal or State inspection, within the limitations described in 9 CFR 381.1. Poultry produced under a poultry exemption are restricted to intrastate commerce only, meaning CNP operators cannot serve poultry products from neighboring States that are exempt from inspection.
3. Can CNP operators purchase poultry from a producer that operates under a poultry exemption?
While it is recommended that poultry come from USDA inspected facilities, State MPI, or CIS facilities, CNP operators may purchase poultry from producers that are exempt from inspection, unless restricted by State or local requirements. For example, the Illinois State Department of Agriculture does not allow uninspected poultry slaughtered or processed under a poultry exemption to be served in Illinois schools.
4. Can animals raised by Future Farmers of America, 4H Clubs, student clubs and/or culinary programs on school campuses be used in CNPs?
Yes, as long as the applicable inspection requirements are met. Additional requirements from State or local authorities may apply.
1. How are game animals and game birds defined and/or classified?
There are two types of game animals and game birds, wild and domesticated. Game animals are non-amenable, meaning they are not subject to the regulations found in the FMIA or the PPIA.
2. What are wild game animals and game birds?
Wild game animals and wild game birds are animals and birds that are live-caught or hunter-harvested. Wild game animals may include free ranging animals such as bison, antelope, caribou, deer, elk, moose, reindeer, snake, alligator, rabbit, squirrel and beaver. As noted in 9 CFR 362, wild birds include any migratory water fowl or non-domesticated game bird such as pheasant, grouse, quail, turkey, geese and ducks.
FSIS views “wild boar” as feral swine and amenable to the FMIA. To receive inspection, feral swine typically are captured, fed for a short time, receive ante mortem inspection, and are then slaughtered as any domestic swine.
3. What are domesticated game animals?
Domesticated game animals are raised (typically on a farm or reservation), slaughtered, and commercially sold. Examples of common domesticated game animals are bison and deer. Note that domesticated birds such as turkeys, ducks and geese fall under the jurisdiction of the PPIA and are not considered game animals.
Note: The term animal(s) will be used from this point forward to describe wild or domesticated game birds and/or wild or domesticated game animals collectively.
4. What is voluntary inspection?
Voluntary inspection is when an animal, not covered by FMIA and PPIA (non-amenable animals), is voluntarily slaughtered under inspection and processed under the supervision of inspectors at a USDA or State inspected facility. Since wild and domesticated game animals are not amenable to Federal inspection laws, the ranchers bringing such animals for inspection must pay for voluntary inspection. Voluntary inspection includes an inspection for wholesomeness of each animal and verification by FSIS inspectors that products are produced in a sanitary manner. Voluntary inspection is a value-added service provided by FSIS to facilitate the movement of safe wholesome food not subject to the FMIA or the PPIA in commerce.
States can expand the definition of amenable species. For example, South Dakota considers bison to be amenable; therefore, all bison slaughtered within the State are subject to mandatory State inspection.
Regardless of its origin, an animal killed outside of a State or Federal facility cannot be presented for voluntary or mandatory Federal or State inspection; voluntary inspection requires ante and postmortem inspection of animal carcasses by trained veterinarians. For example, hunter-harvested wild turkeys, ducks and geese that are not live caught, and slaughtered at an inspection facility cannot be inspected.
5. What options are available to voluntarily inspect wild and domesticated game animals?
The two options available to have game animals voluntarily inspected are described below:
Option 1: Voluntary inspection at USDA facilities
FSIS provides voluntary inspection of domesticated and wild game animals on a fee-for-service basis at USDA facilities, upon request. Businesses, ranchers or hunters must request voluntary inspection from the appropriate USDA FSIS Office of Field Operations District Office and pay an hourly fee for the inspection service. The mark of inspection received from USDA voluntary inspection is different than the circular USDA Federal mark of inspection.
Option 2: Voluntary inspection at State Meat and Poultry Inspection (MPI) facilities
MPI facilities may also offer voluntary inspection for domesticated and wild game animals. Some State MPI programs have expanded their definition of amenable animals to include bison and deer. Therefore, the inspection of such animals is mandatory in those States and the business or rancher does not have to pay for inspection services. Voluntary inspection of game animals can occur at a mobile slaughter facility operating a MPI program.
6. *Must domesticated and wild game animals be voluntarily inspected in State MPI or USDA facilities to be served in CNPs?
It depends. Producers selling domesticated and wild game animals to CNPs must meet applicable Federal, State, local and Tribal food safety regulations and inspection requirements. Program operators should work with their local food safety authority to determine whether producers are approved food sources as required by applicable State and local (including Tribal) food safety regulations.
7. *The Food Buying Guide (FBG) States that “game meat must be from [a] USDA inspected establishment;” will this language change?
The FBG footnote has been amended to reflect that purchased wild and domesticated game animals that have met all applicable Federal, State, local and Tribal food safety regulations and inspection requirements can be served in CNPs. The FBG also clarifies that donated, uninspected wild game served by certain Program operators which primarily serve Native Americans is creditable in CNPs as allowed by section 4033 of the Farm Bill.
8. *Can CNP operators use Federal funds to purchase and serve wild and/or domesticated game meat?
Yes, CNP operators can buy wild and domesticated game meat with Federal funds as long as the animals are slaughtered and inspected following all Federal, State, local, and Tribal food safety regulations and inspection requirements. Please note that State and local authorities may have stricter regulations, preventing the service of domesticated and wild game animals.
9. Can game meat inspected at either a State or Federal facility cross State lines and be served in CNPs in neighboring States?
Yes. Domesticated and wild game animals processed in State MPI facilities and Federal facilities via voluntary inspection can enter interstate commerce. Unlike other amenable livestock (cattle, swine, sheep, and goat) processed in MPI facilities eligible only for intrastate distribution, non-amenable animals (as defined federally, regardless of State definition) are not subject to the FMIA or PPIA.
1. What is the definition of an egg?
As defined by the Food and Drug Administration (FDA) Food Code, "Egg" means the shell egg of avian species such as chicken, duck, goose, guinea, quail, ratites or turkey. “Egg Product" means all, or a portion of, the contents found inside eggs separated from the shell and pasteurized in a food processing plant, with or without added ingredients, intended for human consumption, such as dried, frozen or liquid eggs.” Shell eggs come under the jurisdiction of the FDA and have to meet FDA guidelines. Liquid, frozen and dried egg products are regulated by FSIS. Only whole eggs (shell, liquid, frozen or dried) can be credited in CNPs.
2. What egg products need to be inspected in order to be served in the CNPs?
Liquid, frozen and dried egg products used in CNPs are required to be USDA inspected. Before entering commerce, liquid, frozen and dried egg products must meet the regulatory requirements found in 9 CFR 590, which include the requirement to be pasteurized and be found negative for salmonella, before entering commerce.
3. Do shell eggs need to be pasteurized in order to be served in CNPs?
No, shell eggs are not required to be pasteurized to be used in CNPs. As outlined by the FDA Food Code, it is recommended that shell eggs meet at least grade B standards. Information regarding the grade B standards can be found in the U.S. Standards, Grades, and Weight Class for Shell Eggs.
Before using unpasteurized shell eggs in CNPs, Program operators are advised to check with their State agency and/or local health department and to review local health codes as there may be stricter State, local and/or school district restrictions regarding unpasteurized shell eggs. For example, some State agencies require shell eggs come from “approved sources,” some have shell egg handling rules, and some do not allow unpasteurized shell eggs to be served to highly susceptible populations such as very young children.
Read the full guidance: Procuring Local Meat, Poultry, Seafood, Game, and Eggs for Child Nutrition Programs – REVISED (CACFP 01-2016, SFSP 01-2016).