According to NAMI, FSIS clearly states in the 2014 Compliance Guide that to label a product as “jerky” it must be shelf stable because consumers “consider and expect jerky to be shelf stable” . In order to achieve shelf stability, the 2014 Compliance Guide explains that facilities must achieve the water activity as identified in the facility’s scientific material, not by the RPM.
Specifically, according to FSIS, “(a) although MPR values indicate the degree of dryness of the product, they are not necessarily indicative of the microbial safety or stability of the product because they do not take into account the availability of the water”.
Because FSIS has determined that the existing MPR standard in the Food Standards and Labeling Policy book is not an appropriate means to determine shelf stability and support the safe movement and marketing of these products without refrigeration, this redundant standard is particularly difficult for small and very small establishments. , the petition continues. Resources are much better spent on verifying important parameters related to food safety, eg water activity, pathogen testing, environmental monitoring, etc., in accordance with the 2014 Compliance Guide .
Gallimore says NAMI is seeking a change in the food standards and labeling policy book because the reference to curing is outdated and may confuse manufacturers and consumers of cured meat. “Since FSIS tries to explain in its 2014 compliance guide that the “jerky” entry in the agency’s Food Standards and Labeling Policy book is not a standard of food safety, NAMI believes it is beneficial to government and industry to simply remove the MPR reference from the FSIS Policy Book,” she added.
The first petition filed with FSIS in 2022 came in April when the Northern Goose Processors Ltd. requested changes in the definition of ready-to-cook poultry must include partial dressing of a carcass as authorized by the secretary if the producer demonstrates that there is a market for the product and that the carcass can pass post-mortem inspection.
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