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NAMI petitions over ‘jerky’ entry in FSIS Policy Book

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The North American Meat Institute (NAMI) has filed a petition with USDA’s Food Safety and Inspection Service (FSIS) requesting that FSIS delete the Moisture Protein Ration (MPR) reference from the “jerky” entry in the FSIS Food Standards and Labeling Policy Book.

The petition calls for changing the “jerky” entry in the FSIS Policy Book to remove the MPR reference.

The petition filed on May 9 is the second received by FSIS this year.  It was referred to the Office of Policy and Program Development for review and has been assigned petition number 22-02.

Casey Lynn Gallimore,  NAMI’s director, for regulatory policy, filed the paperwork claiming, the MPR reference is an inappropriate indicator of shelf-stability and potentially a source of confusion for industry and consumers.

“The Meat Institute has a rich, century-long history and provides essential member services including legislative, regulatory, scientific, international, and public affairs representatives for the meat and poultry packing and processing industries,” Gallimore wrote.

“Together, NAMI members produce the vast majority of U.S. beef, pork, lamb, and poultry products in the United States. Several NAMI members produce jerky products subject to the MPR ‘standard’ outlined in the FSIS Policy Book.”

In 2014, FSIS updated its “Compliance Guideline for Meat and Poultry Jerky Produced by Small and Very Small Establishments” (2014 Compliance Guide)2 in response to several comments the agency received after initially publishing the guidance document in 2012.

As the agency said in the 2014 Compliance Guide: “FSIS does not have a standard of identity for jerky in its regulations. However, jerky has historically been dried to an MPR of 0.75:1 or below as described in the FSIS Food Standards and Labeling Policy Book.”

FSIS further explains in the 2014 Compliance Guide that, although some manufacturers rely upon the MPR rather than water activity for determining whether their process adequately dries the jerky to produce a shelf-stable product, MPR is an inappropriate indicator of shelf-stability. NAMI says it is requesting the MPR reference be removed from the FSIS Policy Book, as it may be incorrectly interpreted to be a requirement for shelf stability, which it is not.

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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