According to NAMI, FSIS makes clear 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 establishments must achieve the water activity as identified in the establishment’s scientific support, not by the MPR.
Specifically, FSIS says, “(a)lthough MPR values indicate the degree of product drying, they are not necessarily indicative of microbial safety or product shelf-stability because they do not take into account the availability of the water.”
Because FSIS has determined 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 such products absent refrigeration, this redundant standard is especially difficult for small and very small establishments, the petition continues. Resources are much better spent verifying important food safety-related parameters e.g., water activity, pathogen testing, environmental monitoring, etc., per the 2014 Compliance Guide.
Gallimore says NAMI seeks a change in the Food Standards and Labeling Policy Book because the drying reference is outdated and may confuse jerky manufacturers and consumers. “Given that FSIS goes to great lengths to explain in its 2014 Compliance Guide that the ‘jerky’ entry in the agency’s Food Standards and Labeling Policy book is not a food safety standard, NAMI believes it is beneficial to both the government and industry to simply remove the MPR reference from the FSIS Policy Book,” she added.
The first petition filed with FSIS during 2022 came in April when Canada’s Northern Goose Processors Ltd. asked for changes in the Ready to Cook Poultry definition to include partial dressing of a carcass as authorized by the Secretary if the producer shows that there is a market for the product and that the carcass can pass a post-mortem inspection.
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