Charleston's charcuterie chefs can turn entrails into a delicacy, utilize mold for culinary magic, and transform a thick blob of pork fatback into a ridiculously rapturous 'nduja. But translate those meticulous curing processes into the detailed, scientific forms required to satisfy the South Carolina Department of Health and Environmental Control's new food code? That's proving a harder hog to rustle.
The intense, slow, and mysterious process by which one creates charcuterie out of typically unused animal parts has become many a chef's passion. Coppa, salamis, lamb bacon, bresaola, picante, mortadella, pancetta....delicious poetry, especially compared to this mouthful: Hazard Analysis Critical Control Point, or HACCP in DHEC-speak.
But the HACCP is one of local charcuterie maker's major headaches right now. And has been since DHEC adopted an updated food code for charcuterie on June 27, 2016.
The new regulations require that retail "special process" operations must develop and file a HACCP that outlines, in step-by-minute-step detail, the entire process for the product. So making prosciutto needs its own HACCP documentation and making salami needs another, and so on — pages and pages of tedious written documentation modeled on NASA standards, which must then be presented to DHEC for approval.
"The problem is, unless you've worked with a HACCP plan before, you're entering unknown territory," says Craig Deihl, chef at Cypress and Artisan Meat Share and a founding member of the Butcher's Guild, a national network of meat professionals that promotes responsible butchering.
He feels daunted by the documentation process after submitting forms that got returned for revision. "I understand how to make charcuterie, but not how to have a complete paper trail, or at least one that my DHEC rep can understand," says Deihl, who took a HACCP class as prep, and the man who reviews his paperwork was taking in the same class. DHEC attributes this to frequent class audits.
The issue is complex. Of course there's a need for food safety — Trichinella, Staphylococcus, Listeria, and mold are just some of pathogens that can turn a lovely picnic of cold cuts into a deadly, gut-wrenching nightmare. The main risks in the ultra slow, age-old process of curing meats involves monitoring pH levels, water activity level, and cross contamination.
When Deihl began delving into charcuterie in 2007, he developed his own meticulous processes based on the DHEC standards and guidelines then in place. His formulas are focused on one thing: taste.
"This is a really long, slow, artisan product where it's all about flavor. The thing that's unique about our process is I make it, stuff it, and put it in my storage room. I don't want to check it after 72 hours. Part of this whole dilemma is they want me to change what I'm doing. It hangs there for a god awful long time — it could be a year and a half for the large salamis," says Deihl. "Food scientists aren't thinking about flavor, they're thinking about safety."
"I want to do what's right and safe. I've been doing this for 10 years and never had a problem," adds Deihl, who is 100 percent behind the need for caution, care, and safety.
But he's also running a business and restaurant with a small staff and doesn't have endless hours to devote to tedious paperwork, or the budget to outsource the documentation process. Plus, DHEC only gave special process operators a year and a half lead-time to adapt to the new regulations. Currently Deihl is operating under a variance to the HACCP. And furthermore, the DHEC regulators, according to Deihl and other charcuteriers in the Charleston area, are not well versed in the complexities of the process.
"Our contact in Columbia who specifically heads up this division doesn't have a clue about charcuterie, about what makes them safe or doesn't make them safe," says Mercantile butcher David McBeth. "It's difficult when we say to him, 'these sausages are ready to go and we should be able to serve them,' and he comes back and says 'We need to see a pH drop' ... it's a constant back and forth thing. It would be helpful for them to get their act together," he adds. "It seems like regulation for the sake of regulation."
Travis Grimes, executive chef at Husk, agrees that the DHEC hoops are troublesome. "We have our HACCP plans in place. We mainly do smoked and cooked meats which are not as in-depth as the dry process ones," says Grimes. Husk's charcuterie is made by Jon Kurzen, who had to make adjustments to conform to the specifications. "With DHEC's guidance we went back many, many times and made corrections to the verbiage in our plans. It's pretty technical and pretty frustrating."
And for our local charcutiers, even if they jump through the initial hurdles and the HACCP paperwork passes DHEC approval, there's no guarantee that the field inspector who comes knocking will be on the same page.
According to DHEC, the process is more straightforward. "All HACCP plans are evaluated and approved through DHEC's food protection division located in Columbia. Thorough reviews of requests for a special process are completed by the division's staff, which includes a coordinator that has more than 10 years of experience in writing and evaluating HACCP plans for the food processing industry as well as experience in training others in how to write HACCP plans," the agency commented.
A DHEC coordinator offers technical assistance on these plans, which might include referrals to other resources such as Clemson's Food Science Program, the Food and Drug Administration (FDA), and the U.S. Department of Agriculture.
Sounds a lot like making sausage.
So what's the cure for those who've become devotees of artisan meat delicacies? Might you be left hanging like a salami on a drying rack?
"For now, I'm not doing any dry charcuterie, and it's depressing me," says Deihl, who personally oversees and hand-makes every ounce of charcuterie sold by Cypress and Artisan Meat Share, and has about six months of product left before he's out.
"I'm going to stop to figure this out so I can get back to doing what I do very well. Fortunately, it's our slow season right now, so I hope I'll have the time."
But one thing that Deihl won't relent on is changing his process — as difficult to document as it may be — simply to satisfy the HACCP.
"I'm not going to make a product that tastes like something from the grocery. My number one fear is the loss of quality," he says. "Yes, I want to be safe. And I want to make the most delicious product in the form of dry cured, fermented sausages, salumi, and salami that you've tasted. Unfortunately my skill set is I don't know how to put that into writing. I can, however, make it for you, and when it's done, you'll have a bite and say 'by damn, that's super tasty.'"