"Safe and Suitable" Meat Processing Ingredients

Those interested in what's in their food and how their food has been produced might want to check out the USDA FSIS Notice issued last week.  It includes a chart that lists the "Safe and Suitable Ingredients" that may be "used in the production of meat, poultry, and egg products."

This Notice provides an interesting window to the world of modern meat production. Some will react positively, noting the advantages that chemical compositions have provided us in establishing a safe system of meat production. Many chemicals are intended to serve as antimicrobials. Others will be dismayed at the laundry list of chemical washes, baths, injections, and sprays used on a typical serving of meat.

Either way, note the last column in the chart, "labeling requirements."  The labeling requirement for the use of many of these chemicals is "[n]one under the conditions of use." 

For example, as is set forth in the chart, under our current system of labeling law, anhydrous ammonia can be used in ground beef, followed with a carbon dioxide treatment "in accordance with current industry standards of good manufacturing practice" without any labeling requirement.  This is because anhydrous ammonia is considered a "processing aid."

FDA regulations define a "processing aids" as

• Substances that are added to a food during the processing of such food but are removed in some manner from the food before it is packaged in its finished form;
• Substances that are added to a food during processing, are converted into constituents normally present in the food, and do not significantly increase the amount of the constituents naturally found in food; or 
• Substances that are added to a food for their technical or functional effect in the processing but are present in the finished food at insignificant levels and do not have any technical or functional effect in that food.

See 21 CFR 101.100(a)(3)(ii).

Note that a "blend of salt, lemon extract, and grapefruit extract" also serves as an antimicrobial in hamburger, but FSIS requires that the "[p]roduct must be descriptively labeled" when this it is used.

As a side note, University of Arkansas researchers are doing some very interesting work on feeding cows orange peels as an "antimicrobial boost."  See, Cleaning Cows From the Inside Out.


But, back to the Notice.  Another category of chemicals that are also immune from labeling requirements are "secondary direct food additives."  These are defined as "substances whose functionality is required during the manufacture or processing of a food and are ordinarily removed from the final food. Although residuals might carry over to the final food, residuals must not exhibit any technical effects.  Secondary direct food additives are consistent with FDA’s definition of a processing aid so labeling is not required."  See 21 C.F.R. pt. 173.

Carbon monoxide gas is used in many meat packaging systems to preserve the fresh color of the product as well as its stated purpose "to maintain wholesomeness, provide flexibility in distribution, and reduce shrinkage of the meat."  It's use will not show up on the label because it is considered a "secondary direct food additive."

I find all this strangely fascinating.  When we talk about our "food system," it is a lot more complex than most people realize.