NSF International Registration Guidelines for Proprietary Substances and Nonfood Compounds

Historically, the Food Safety and Inspection Services (FSIS), a branch of the United States Department of Agriculture (USDA), required meat and poultry facilities to use pre-processing compounds (Proprietary Substances) and products used in and around food processing areas (Nonfood Compounds) that had been approved under the USDA authorization program. This requirement, based upon recognized public health benefits, carried over into many other product applications (including fishery and retail operations. Product evaluations were primarily based upon formulation and label review and generally did not include testing. Upon a determination of compliance, the USDA would issue a Letter of Authorization and the product would be listed in the next edition of the List of Proprietary Substances and Nonfood Compounds. The USDA authorization ensured that FSIS inspectors would approve a product's use within meat and poultry operations. Two Federal Register notices, published August 25, 1997 and the final on February 13, 1998, announced the end of the USDA authorization program. The FSIS significantly altered their approach to facility inspections, eliminating the need for USDA product evaluation. FSIS moved away from prescriptive regulation to performance-based reviews. This new approach was driven by the established system of Hazard Analysis and Critical Control Points (HACCP) facility operation. Under HACCP, all meat and poultry establishments must identify and manage critical control points (primarily relating to microbial contamination) for food processing. For Nonfood Compounds and Proprietary Substances, the facility operators must select the appropriate product to not only meet their operational needs, but also their HACCP requirements. In January of 2000, NSF launched a Registration Program for Proprietary Substances and Nonfood Compounds. This program mirrors the prior USDA program evaluation for all product categories and streamlines the registration process. Working with the USDA, NSF captured all prior review guidelines and packaged them into a single document, which will serve as the foundation upon which products are evaluated and registered by NSF. Upon adoption of the NSF Registration Program, all products authorized previously by the USDA are also listed. All products that are subsequently reviewed by NSF are highlighted in the NSF Listing and shall carry a NSF Registration Number on the product label.