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Meat Institute Submits Joint Comments Regarding Appendices A and B Compliance Guides

Monday, September 18, 2017

(North American Meat Institute)

The Meat Institute and National Turkey Federation (NTF) submitted joint comments to the Food Safety and Inspection Service (FSIS) regarding the documents titled, " Salmonella Compliance Guideline for Small and Very Small Meat and Poultry Establishments that Produce Ready-to-Eat (RTE) Products and Revised Appendix A " and " Compliance Guideline for Stabilization (Cooling and Hot-Holding) of Fully and Partially Heat-Treated RTE and non-RTE Meat and Poultry Products Produced by Small and Very Small Establishments and Revised Appendix B ."

The Meat Institute and NTF recommended FSIS revert back to previous versions and seek additional input from processing authorities and microbiologists before implementing the revised guidelines. The organizations asked FSIS to ensure field inspection personnel understand that the compliance guidelines are meant to serve as resources containing suggested best practices, and do not impose regulatory requirements. The comments also detailed areas in both compliance guidelines that are inconsistent, overly restrictive and lack scientific support.

In comments about Appendix A, the Meat Institute takes issue with FSIS's decision to narrow product casings to semi-permeable and impermeable in situations where relative humidity does not need to be assessed. In addition, the Meat Institute contends natural casings should be classified as semi-permeable because they hold water, but are permeable to gases. The compliance guideline, however, does not provide enough information to classify natural casings as semi-permeable.

In response to Appendix B, the Meat Institute and NTF ask FSIS to state there are additional means by which companies can demonstrate meeting the performance standard in relation to Option 2, even if the time between 120°F and 80°F is longer than one hour, by using tools such as supporting scientific articles, pathogen modeling and challenge studies.

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