Appendix A & B update: AAMP meets with industry groups in Washington, D.C.
Last month, I spent the day in Washington, D.C. with other industry associations and the scientific working groups that we have put together to work on Appendix A & B issues.
We spent the morning going over the preliminary results of the studies on Lethality (Appendix A) and stabilization (Appendix B) and prepared for our presentations to FSIS staff that afternoon. The meeting with FSIS lasted about four hours; I feel it went very well. The working group of scientists and industry experts did a tremendous job in presenting their research, as well as some of the holes they felt existed in the current science used by FSIS. The information was well received, and a second meeting is being planned with a larger group from FSIS.
A lot of great work has been accomplished, but there is still more to do, including some additional studies. FSIS is preparing to release an updated version of the 2017 Appendix A & B guidance documents in the next few months, but they could delay it in order to include some of the information that the working group is making available. Either way, the newer version will be much more workable for AAMP members and processors. It is not perfect, but a move in the right direction. We will update you as we see the final work and let you know how to proceed in using the new guidance as support for your processes.
FSIS issues compliance guideline on kit labeling
On July 9, 2019, USDA’s Food Safety and Inspection Service (FSIS) issued a notice of availability and a request for comment on a new guideline for kit products that contain meat or poultry products.
Specifically, the guideline addresses the circumstances in which the assembly of a “kit product” that contains meat or poultry needs to be done under FSIS inspection and the labeling required for these products. This is the first time the Agency has addressed this topic via formal guidance.
A “kit product” consists of individually-packaged food components sold together as a single unit, such as pizzas, salads, fajitas, wraps, meals, etc. that contain a meat or poultry component. FSIS guidelines state that the act of assembling a kit product that contains meat or poultry does not need to be done under FSIS inspection if the following conditions are met:
- The meat or poultry component is prepared and separately packaged under FSIS inspection and labeled with all required features;
- The outer kit label identifies all of the individual components in the kit; and
- The outer kit label clearly identifies the product as a single unit or “kit,” such as “Chicken BBQ Dinner Kit” and “Beef Lasagna Meal.”
Comments on the guideline are due by September 9, 2019. In its notice, FSIS states that once it assesses comments, the Agency will issue instructions to the Office of Field Operations to clarify what products constitute kits that should no longer be under inspection. View the Federal Register here: https://bit.ly/2XCFYSV
FSIS announces retail exemption adjusted dollar limitations
FSIS is announcing the dollar limitations on the amount of meat and meat food products and poultry and poultry products that a retail store can sell to hotels, restaurants, and similar institutions without disqualifying itself for exemption from federal inspection requirements. In accordance with FSIS’ regulations, for calendar year 2019, the value for the retail dollar limitation for meat and meat food products remains unchanged at $75,700. For calendar year 2019, the value for the retail dollar limitation for poultry and poultry products also remains unchanged at $56,600. Additional information on retail exemption dollar limitations can be found here: https://bit.ly/2Fui0OF.