AMI Files Comments in Support New FSIS Test and Hold ProceduresWednesday, July 13, 2011
(American Meat Institute)
AMI reiterated its support for controlling sampled product in comments submitted in response to Food Safety and Inspection Service (FSIS) Docket No. 2005-0044: Not Applying the Mark of Inspection Pending Certain Test Results, which announced FSIS’ intention to withhold a determination as to whether meat and poultry products are eligible to enter commerce until all test results that bear on the determination have been received.
“AMI has long advocated as a ‘best practice’ that establishments retain control of sampled product to avoid a recall in the event the test result is positive for an adulterant,” the comments stated.
In September 2005, AMI, along with several other organizations and with assistance of and encouragement from FSIS, mailed to every small and very small federally inspected establishment a best practices document encouraging them to adopt a policy to control tested product until the results are known. In addition, AMI requested, on two separate occasions, that the agency adopt a policy that is largely consistent with the concepts articulated in the published notice.
Given AMI’s past actions and long-standing policy, AMI stated that it supports the concepts articulated in the notice, with the following clarifications:
- The policy should not require the use of
company seals but should allow the use of other
effective mechanisms in addition to seals.
- The agency’s policy should not provide
for agency retention of any FSIS tested
product, but rather the policy should allow a
company to utilize its own, effective control
measures to ensure the product is not used or
distributed for sale to consumers before the
test results are known.
- AMI disagrees with the agency statement
that “if the establishment moves the product
to other locations, it would not be able to
transfer ownership of the product until
negative test results become available.”
Strict application of this approach would
force an unnecessary change in business
practices and could create chaos with a supply
chain that relies on fast distribution times
because of quality and shelf life issues.
The critical issue is not one of
ownership; rather it is one of product
- In addition, the above-discussed concepts advanced by AMI in these comments regarding this policy should apply not only to domestically produced products but also to products exported to the United States.
To view the comments and attached documents
in their entirety, go to
To view the FSIS notice, go to http://www.fsis.usda.gov/OPPDE/rdad/FRPubs/2005-0044.pdf.share on facebook share on twitter