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Substitution of USDA Beef and Pork

Nutrition Services Division Management Bulletin
Purpose: Policy

To: U.S. Department of Agriculture Foods Processors and School Food Authorities

Number: USDA-FDP-05-2013

Attention: U.S. Department of Agriculture Foods Processors, U.S. Department of Agriculture Foods Distributors, Food Distribution Program Recipient Agencies

Date: October 2013

Subject: Substitution of U.S. Department of Agriculture Beef and Pork

Reference: U.S. Department of Agriculture Policy Memorandum FD-130

This Management Bulletin (MB) provides guidance to California and National Processors regarding the ability to substitute U.S. Department of Agriculture (USDA) beef and pork with commercial beef and pork.  

Under current regulations, the substitution of USDA beef and pork with commercial beef and pork is prohibited, as the condition of the commercial products can differ from USDA specifications. Policy Memorandum FD-130 clarifies the USDA’s plan to allow for the substitution of beef and pork under strict measures.   

The USDA, in coordination with the Agricultural Marketing Service (AMS), is giving approved USDA Foods processors the option of submitting a plan for substitution. If approved, it would provide for the substitution of USDA beef and pork with commercial beef and pork that meets the following requirements:

  1. Must be of U.S. origin
  1. Must be equal or better quality in all USDA purchase specifications for USDA beef and pork

In accordance with this policy, the USDA’s Food and Nutrition Service (FNS) will exercise its waiver authority under Title 7, Code of Federal Regulations (7 CFR) Section 250.30(t) to waive the regulatory provision in 7 CFR Section 250.30(f), which prohibits the substitution of USDA beef and pork, for a processor with an approved substitution plan. If a processor is found to be out of compliance with any of the provisions of the approved Processor Control Certification Program plan or approved substitution plan, FNS reserves the right to revoke or suspend such a waiver until corrective action is taken. FNS reserves the right also to implement a blanket revocation of such waiver for all processors.

Approval Requirements

In order for approved USDA Foods processors to begin substituting beef and pork, processors must have an approved substitution plan. The substitution plan must guarantee the following:

  1. Processing is performed in plants under continuous federal or state meat inspection programs, in accordance with 7 CFR Section 250.30(g).

  2. AMS graders will monitor the process of substituting to ensure compliance with substitution requirements.

  3. Commercial beef and pork are purchased from an AMS-approved vendor in good standing and must be tested to ensure that they are of equal or better quality in all USDA purchase specifications. This includes specifications relating to acceptable tolerance levels for specific microorganisms, chemical residues, and fat.

  4. Testing results are submitted to the AMS promptly, permitting AMS graders to ensure compliance with substitution requirements.

  5. Substituted product will be subject to audits for humane handling, food defense, and threat agent testing.

  6. The inclusion of a step-by-step description of how production will be monitored.

  7. Only certified (as above) commercial beef and pork can be commingled with USDA beef and pork.

  8. Only certified commercial beef and pork can be used to replace any USDA beef and pork subject to production and other losses.

  9. Backhauled product cannot be substituted. Only bulk USDA beef and pork delivered directly to the processor can be substituted.

  10. Accurate records are maintained for all USDA Foods received, substituted, and grading certificates received from the AMS.
Plan Submission

Processors operating in California and other states must submit a substitution plan to AMS directly by e-mail to for approval by the AMS and FNS. Questions regarding Policy Memorandum FD-130 should be directed to Sherry Thackeray, FNS, by phone at 703-305-2652 or Larry Meadows, AMS, by phone at 202-692-0342.

Processors operating only in California must submit a substitution plan to Jackie Henderson, Manager, Distribution and Processing Unit, by e-mail at After review and validation of required components, we will forward your plan to the AMS for final approval. 

If you have any questions regarding this MB, please contact Manpreet Kaur, Processing Consultant, Distribution and Processing Unit, by phone at 916-323-2591 or by e-mail at

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Monday, March 27, 2017
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