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Uncooked Comminuted Fermented Meat (UCFM) manufacturers

What is a UCFM?

Uncooked Comminuted Fermented Meat (UCFM) is a meat product manufactured by a series of processes including fermentation and maturation (with smoking/heat treatment as an optional step). In addition, the product has not had its core temperature maintained at 65°C for at least 10 minutes or an equivalent combination of time and higher temperature during production.

The range of UCFM products available covers a wide spectrum of water activity (aw) and pH, ranging from the acidic, moist Mettwurst to the dry, high-pH Italian sausages.

Examples of UCFM products commonly produced in New South Wales (NSW) include salami, chorizo, and pepperoni.

UCFM is a high-risk product

UCFM products are not cooked, so any harmful microorganisms present in the raw materials and/or the processing environment could survive and/or grow to cause illness.

Poor quality meat and an uncontrolled manufacturing process can lead to a devastating result (e.g. the Garibaldi incident in South Australia in 1995 – affecting 150 people, some with long-term health effects, and one death).

Businesses that manufacture UCFM products are classified as Priority 1 (P1) – which represents the highest food safety risk – under the Food Safety Risk Priority Classification Framework (RPF).

For more on the production of UCFM products for retail sale, see Ready-to-eat & UCFM products.

Frequently Asked Questions

What hazards can be present in a UCFM?

Standard 3.1.1 of the Food Standards Code (the Code) defines ‘hazard’ as a biological, chemical or physical agent in, or condition of, food that has the potential to cause an adverse health effect in humans.

You must identify all hazards that may be present in your product and establish control systems that focus on preventing or eliminating the hazards. You must not rely on end-product testing only.  

Pathogenic bacteria may be present in UCFM if the process is not properly controlled. This may include (but is not limited to) Salmonella, Escherichia coli, Staphylococcus aureus, Clostridium botulinum, Listeria monocytogenes and parasites.

Chemical hazards may include excessive additives (including preservatives), allergens and other chemical contaminants.
Physical hazards may include plastic from packaging, metal staples or any other foreign objects. 

How do I manage the hazards?

You must identify all hazards that may be present in your product and establish control systems that focus on preventing or eliminating the hazards. 

All control measures must be documented in your Food Safety Program (FSP) and you must follow these strictly for every batch of UCFM you make, because any deviation from established procedures may result in an unsafe product.

As there is not a cooking step to control the survival and/or growth of any pathogenic microorganisms, other hurdles are crucial in making a safe product. These hurdles include (but are not limited to):

  • Reduction of water activity through drying,
  • pH reduction by acid production during fermentation,
  • growth of competitive flora during fermentation,
  • addition of nitrite.

Some controls for UCFM manufacture are:



Important points

Raw meat purchase

Raw meat with low level of E. coli.

Buy a high-quality meat from a reputable supplier.

Conduct raw meat testing at least 5 times a year as part of the supplier management.

Meat receival

  • Carcase meat not warmer than 7°C, and
  • Pieces of meat not warmer than 5°C

* As per AS 4696:2007

Check the temperature of meat upon receipt using a calibrated thermometer.

Meat storage

Does not exceed 5°C.

Raw meat and batter mix used for making UCFM products must be stored at less than or equal to 5°C.

This will prevent the growth of pathogenic bacteria such as E. coli, Salmonella and S. aureus.

Meat tempering

As close to 0°C as possible.

Tempering of frozen meat must be done in the chiller to prevent growth of pathogenic bacteria and to produce a correct product texture.

Meat grinding or flaking

Does not exceed 5°C.

If the batter exceeds 5°C, it must be used immediately or placed in a chiller to bring down the temperature.

Salt addition

Normally 2.5 to 3% salt is added to the batter.

Salt lowers the water activity of the meat and slows down the growth of some pathogenic and spoilage bacteria. 

Sugar addition

The correct type and amount of sugars (e.g. glucose or dextrose) as recommended by the supplier of the starter culture.

The correct type and amount of sugars should be used to optimise the conversion of sugars to acid by the bacteria in the starter culture during the fermentation step.

Nitrite/nitrate addition

Nitrite must be added between 50-150 mg/kg of batter to inhibit the growth of Cl. botulinum

The ingoing amount of nitrite into the product is the important preservation factor. 

Addition of sodium and potassium nitrate/nitrite must not lead to more than the limited permitted in the Code. 

Nitrite is used as an antimicrobial agent and a curing agent. 

The combined effects of nitrite and organic acids, low pH and low water activity effectively control the growth of Cl. botulinum during the manufacture and storage of UCFM products. 

To date, no effective single replacement material has been identified as an alternative to nitrite. 

It is also responsible for the cured meat colour and flavour, and prevents oxidation.

Nitrite can be toxic at excessive levels and its addition to the batter should be controlled. The use of pre-blended curing mixtures is highly recommended as it prevents the addition of excess nitrite into the batter.

Spices addition

Use spices with a low bacterial count. 

(e.g. use irradiated or sterilised spices)

Spices are used for flavour. However, spices sometimes have high bacterial counts and may contain pathogens such as Salmonella.

Starter culture addition

Select a starter culture that is suitable for the fermentation of meat at the temperature range used to manufacture UCFM products.

Starter culture must be used to ferment the meat. 

Different culture strains may work best at different temperatures. 

You must follow the manufacturer’s instruction regarding 

  • storage, 
  • reconstitution, 
  • the amount of starter culture to be added to any given amount of batter,
  • type and amount of fermentable sugars to be added, 
  • fermentation temperature, and 
  • shelf life of the culture. 

Care should be taken when adding alcohol to the batter as this can inhibit the starter culture and slow the fermentation process.


Use sanitised food grade casings. 

The batter should be hygienically filled into food grade casings.

Casings should be filled to the correct diameter. Diameter size influences the rate of drying and ultimately the flavour and texture of the finished product.

Care should be taken to make sure that casings are not contaminated with pathogenic bacteria.


A pH of 5.2 or lower within 48 hours. 

No back slopping is allowed. Back slopping is where fermented meat from one product batch is used as the starter culture for the next batch.

Fast pH drop inhibits pathogenic bacteria. 

In general, higher fermentation temperatures require shorter fermentation times, and faster pH drops prevent growth of pathogenic bacteria. 

Relative humidity needs to be controlled. 

pH of fermenting UCFM and temperature & time of fermentation of UCFM must be monitored and recorded.


(and smoking, if applicable)

The process must continue until a minimum of 2-log E. coli inactivation is achieved. 

Relative humidity and airflow need to be controlled.

Temperature & time of maturation and/or smoking of UCFM and weight loss or water activity must be monitored and recorded.

Slicing and packing

High standard of hygiene practices must be employed.

Ready-to-eat (RTE) products are susceptible to recontamination if further handled after processing. 

Slicing and packing require a high standard of hygiene to prevent contamination from equipment and the environment, cross contamination between raw meat and UCFM product, and other substances that could affect the safety and suitability of the product.

See the NSW Food Safety Schemes Manual regarding controlling L. monocytogenes in the processing environment.

End product testing

E. coli must be less than 3.6 cfu/g in each batch.

A batch means product made using the same process or packaged under the same conditions within a 24-hour period.

See the NSW Food Safety Schemes Manual for a more detailed explanation.

Allergen control

No undeclared allergens

Consider the allergens in the ingredients, added to the product and present in the processing environment.

Metal detection

All products must pass a metal detection


Can I remove nitrate/nitrate from my UCFM products?


If you would like to remove nitrate/nitrite from your product, you must conduct a full validation of the new preservation system in your product/s.

Your alternative process must be approved by the NSW Food Authority before you can manufacture your products for sale.

The Food Standards Code does not specify that I need to add nitrate/nitrite to my UCFM product. Why do I have to add nitrate/nitrite?

Sodium nitrate and sodium nitrite have been used in meat products as curing agents and preservatives for centuries. The Standard was written with an assumption that nitrate/nitrate is added to UCFM products.

To date, no effective single replacement material has been identified as an alternative to nitrite to inhibit Cl. botulinum growth and toxin production.

Why is nitrate/nitrite important?

Sodium nitrate and sodium nitrite have been used in meat products as curing agents and preservatives for centuries. However, nitrate is seldom used today because it must be converted to nitrite to be effective, which is a slow process achieved by microbial reductase. 

Nitrite, in combination with salt and pH, is used in cured meats to ensure their safety with respect to a number of pathogens including Cl. botulinum. Cl. botulinum is responsible for a disease called botulism. Botulism is a life-threatening disease caused by the ingestion of a potent neurotoxin produced during growth of the Cl. botulinum bacteria. This neurotoxin is among the most toxic substances known; even microscopic amounts can cause illness or death. Foodborne botulism can be especially dangerous because many people can be poisoned by eating contaminated food. 

To cause illness, spores of Cl. botulinum must be able to germinate and then grow in the meat product until a point at which botulinum toxin is produced by the bacteria. The addition of nitrite can have an antimicrobial effect in meat products, which can also inhibit the outgrowth of Cl. Botulinum spores. The antimicrobial effect is pH-dependent, increasing ten-fold for each unit fall in pH. In its review of nitrite, the EFSA Biohazard Panel in 2003 concluded that between 50-150 mg/kg nitrite is necessary to inhibit the growth of Cl. botulinum. The panel concluded that the ingoing amount of nitrite into the product was the important preservation factor. To date, no effective single replacement material has been identified as an alternative to nitrite. 

The removal of nitrite can be likened to the removal of a hurdle to the growth of Cl. botulinum. To maintain the safety of the food, another similar hurdle must be used to replace nitrite or otherwise the ‘height’ of the remaining hurdles must be increased to prevent Cl. botulinum from growing. For example, to maintain the safety of the food, you may have to reduce the shelf life; and/or increase the salt level (and therefore decrease the water activity: aw); and/or decrease the pH; and/or add a different preservative. 

The product will have to be reformulated, the shelf life needs to be validated and the HACCP system re-adjusted to ensure the food can be manufactured safely on a consistent basis. 

Can I use an alternative source of nitrate/nitrite?


You can use nitrate/nitrite from natural sources as long as the nitrate/nitrite equivalent content of the alternative source is validated. 

The information on the alternative nitrate/nitrite source must be supplied to the Food Authority when you submit your pro forma.

Can I use other meat besides pork or beef?


If you would like to use a different type of meat, the approval process will take longer (up to 6 months). The Food Authority needs to conduct a literature review and risk assessment for the specific type of meat species to be used and microorganisms that may be present.

There will also be additional conditions (e.g. raw meat testing, additional RTE meat testing) imposed upon the approval of the UCFM process. 

Which Regulations do I have to comply with?

The NSW Food industry is subject to requirements outlined in the Australia New Zealand Food Standards Code (the Code), Food Act 2003 (NSW) and Food Regulation 2015.

Food Standards Code

Production and Processing Standard for Meat (Standard 4.2.3)

All UCFM manufacturers must comply with Standard 4.2.3 – Production and Processing Standard for Meat. Divisions 1 to 3 are applicable to all meat businesses while Clause 5 of Division 3 sets out additional requirements for UCFM products.

Additional requirements for UCFM

  1. A UCFM must be produced in accordance with a food safety management system (Food Safety Program (FSP) in NSW) which has been verified and audited to ensure the number of E. coli organisms in the final UCFM product complies with the microbiological limits in Standard 1.6.1 of the Code and demonstrates that the production process handles the variations of E. coli contamination in the ingoing raw meat ingredients.
  2. As part of the validation or verification requirements of the FSP, the number of E. coli organisms must be recorded for the raw meat ingredients used to make a UCFM and in the product after fermentation and any other subsequent process.
  3. During UCFM production the following must be monitored and recorded at suitable frequencies
    • the pH of a fermenting UCFM; and
    • the temperature and time of fermentation of UCFM; and
    • the temperature and time of maturation/drying of UCFM; and
    • the temperature and time of smoking of UCFM; and
    • the weight loss or water activity
  4. The measurements recorded must be kept for 12 months after the use-by date or best-before date of a UCFM.
  5. The fermentation of a UCFM must be initiated through the use of a suitable starter culture.
  6. A previously fermented or fermenting meat must not be used as a starter culture or an ingredient in a UCFM.
  7. Meat and batter mix used in the preparation of a UCFM must, if stored by the manufacturer, be stored at 5°C or below prior to fermentation.
  8. The pH of a fermenting UCFM must be measured in accordance with the Method outlined in Standard 4.2.3
Labelling (Standard 1.2)

All packaged food for sale must have a label. Please refer to Standard 1.2 and Standard 2.2.1 of the Code for more detailed information.

At a minimum, the following information are required to be on a label of a UCFM:


Labelling requirement



Name of the food

A name or description sufficient to indicate the true nature of the food.


Lot identification



Name and address of the supplier

The business address in either Australia or New Zealand of a person who is a supplier.

Not a PO Box number.


Advisory statements, warning statements and declaration

If the product or ingredients contain any of the most common food allergens, it must be declared. 

It can be done either in the ingredient list (bold font) or a separate statement such as ‘contains peanut’.

  • gluten (if you use wheat flour), 
  • crustaceans, 
  • eggs, 
  • fish, 
  • milk, 
  • peanuts, 
  • soybeans,
  • sesame seeds,
  • tree nuts,
  • lupin.


A statement of ingredients

A statement of ingredients must list each ingredient (including food additives) in descending order of ingoing weight. 


Date marking information

Either a use-by date or best before date of the product.

Refer to the ‘Shelf-life testing’ document on the Food Authority’s website.


Storage conditions and directions for use

The conditions at which the product is required to be stored to ensure that the product will keep until the ‘use-by’ or ‘best before’ date.


Information relating to nutrition, health and related claims

Standard 1.2.7 sets out the claims that may be made on labels about the nutritional content of food (nutrition content claims) and the claims that may be made on labels about the relationship between a food or a property of a food and a health effect (health claims).


Nutrition information

The label must have a Nutritional Information Panel (NIP).

It must include: the number of serving in the package, serving size (in grams), average quantity per serving and average quantity per 100 grams for:

  • energy
  • protein
  • total fat
  • saturated fat
  • carbohydrate
  • sugars, and
  • sodium.

If a product has any nutrition content claims, the NIP must include the required additional declaration as per the Code. 


Information about characterising ingredients and characterising components

Characterising ingredients or component means an ingredient or component of the food that is mentioned in the name of the food, or is usually associated with the name of the food by a consumer, or is emphasised on the label of the food in words, pictures or graphics.

The proportion of a characterising ingredient or component must be declared as a percentage.


Meat and meat products – labelling of fermented comminuted processed/manufactured meat

The label must contain the following words ‘fermented processed /manufactured meat – not heat treated’. 

Food Additives (Standard 1.3.1)

The amount of additives in the final UCFM product must comply with the maximum permitted levels specified in Standard 1.3.1 and Schedule 15 (section 8.3) of the Code as outlined below.



Maximum Permitted Limit (MPL) – mg/kg


Additives permitted at GMP

See Schedule 16


Colourings permitted at GMP

See Schedule 16


Annatto extracts


220 221 222 223 224 225 228

Sulphur dioxide and sodium and potassium sulphites






Ethyl lauroyl arginate


249 250

Nitrites (potassium and sodium salts)


280 281 282 283

Propionic acid and sodium and potassium and calcium propionates



Polyoxyethylene (20) sorbitan monolaurate


200 201 202 203

Sorbic acid and sodium, potassium and calcium sorbates



Pimaricin (natamycin)

1.2 mg/dm2

251 252

Nitrates (potassium and sodium salts)


Food Regulation 2015

Part 9 of the Food Regulation 2015 outlines the specific requirements related to the meat industry.

Testing requirement

Division 8 Clause 116 states that the holder of a license that authorises the operation of a meat processing plant or meat retail premises must, at the holder’s own expense, ensure that samples of ready to eat meat products that are handled in the course of the operation of the processing plant or premises and are required by the NSW Food Safety Schemes Manual to be analysed in accordance with this clause.

Non-compliance to the testing requirement will result in an enforcement activity with a maximum penalty of 25 penalty units.

The NSW Food Safety Schemes Manual specifies the following testing for UCFM products.

Product to be tested

Test to be conducted, the limit and frequency

E. coli

Not exceeding 3.6 cfu/g

Uncooked comminuted fermented meat (UCFM)

Finished product

Every batch

You must notify the Food Authority if any sample analysed fails to meet the standard set out in the Food Safety Schemes Manual:

Australian Standards

The operation of a meat processing plant must comply with the following Standards:

(a) in relation to a meat processing plant at which the processing of meat (other than poultry meat, rabbit meat, ratite meat or crocodile meat) is authorised by the relevant license – the standard specified in Australian Standard AS 4696 – 2007, Hygienic production and transportation of meat and meat products for human consumption, as in force from time to time,

(b) in relation to a meat processing plant at which the processing of poultry meat is authorised by the relevant license – the standard specified in Australian Standard AS 4465 – 2006, Construction of premises and hygienic production of poultry meat for human consumption, as in force from time to time,

(c) in relation to a meat processing plant at which the processing of crocodile meat is authorised by the relevant license – the standard specified in Australian Standard AS 4467 – 1998, Hygienic production of crocodile meat for human consumption, as in force from time to time,

The operation of meat retail premises must comply with the standards specified in the publication titled New South Wales Standard for Construction and Hygienic Operation of Retail Meat Premises published by the Food Authority.

How can I determine the pH of my UCFM product?

Standard Method (FSC Standard 4.2.3)

  • Mince a representative portion of the sample of the UCFM and place that portion in a stoppered bottle with twice its weight of water. 
  • Shake at five-minute intervals for 30 minutes.
  • Determine the pH value of the liquid electrometrically at 20°C.

Alternative method

pH can also be determined through the use of clean, calibrated, direct-contact pH probes or meters.

When testing is done by using this method, it must be done aseptically so you do not contaminate the product. 

Indicator strips have generally proved to be unsuitable for measuring the pH of fermenting products due to the problem in establishing adequate contact between the indicator pad and the product. The fat in the product may coat the indicator pad and prevent liquid from the product reacting with the indicator.

How can I monitor product weight loss?

From Guidelines for the Safe Manufacture of Smallgoods (Meat & Livestock Australia, 2015)

Checking weight loss is important to make sure that the maturation process has proceeded correctly. To monitor weight loss, you should do at least the following:

  1. Make sure your scales are accurate and calibrated. 

    It is no use putting a 150 g sausage on a scale which weighs up to 50 kg – the accuracy will not be enough to support your validation.
  2. Weigh a representative sample – 10 sticks from a batch should be sufficient.
  3. Tie a label on each stick and write the starting weight and the date on it.
  4. Each time you weigh the stick, write the new weight and the date on the label.
  5. Do not just average the 10 weights because that only allows you to say “on average my product has the correct weight loss”.
  6. Keep the individual weighing – this will tell you how variable your process is. 
  7. If it is so variable that some sticks are too moist to be released, you need to find out why there is uneven drying.
  8. Record and retain the results as part of your verification.
  9. During validation of the process, you can check the weights against the water activity to confirm the recipe is producing the necessary reduction.

How do I undertake microbiological testing of my UCFM product?

Please refer to the document titled ‘Microbiological testing’ (Appendix 1 of the NSW Food Safety Schemes Manual) on the Food Authority’s website.


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