ADVANCEMENT OF THE SCIENCE
further processing. Both prechill and post- chill reinspections are done daily. The prechill reinspection test is divided into two categories. One category is to moni- tor the dressing and evisceration (processing category) conducted by a company. The oth- er category is to monitor a company’s ability to remove unwholesome defects such as le- sions and disease conditions (trim category) from the carcasses to produce a wholesome product for the public. Each category is dealt with separately. Postchill testing is to ensure the finished products meet national standards in the regu- lations. Testing is completed by the CSI in a manner similar to the prechill testing. If the criteria are not met, the company retests for validity of the results; if the test results are deemed valid, all products representing the samples that did not meet criteria are re- worked and retested until results are accept- able. Then routine sampling resumes (Sub- part K—Post Mortem Inspection, 2023). Reinspection of Raw Red Meat Because all establishments have adopted HACCP plans, statistically based tasks for reinspection of raw red meat have been absorbed into the HACCP inspection pro- cessing codes and therefore are not presently required to be performed by FSIS inspectors. Companies may opt to use the former FSIS statistically based method for reinspection. The regulation indicates that new methods for statistically based red meat reinspection are anticipated in the future (Reinspection, Retention, and Disposal of Meat, 2023). Inspection for Deception and Product Wholesomeness FSIS protects consumers from unwhole- someness and deceptively labeled products that federally inspected meat and poultry companies might produce inadvertently or intentionally. CSIs are responsible for
checking labels for accuracy and regulatory requirement compliance, and by monitor- ing processing steps where products are weighed and ingredients and additives are formulated and added. Labeling and Product Standards FSIS regulates the labeling of meat and poultry products to safeguard consumers from public health concerns and deception. There are reg- ulations for both red meat (Labeling, Marking Devices, and Containers, 2023) and poultry (Subpart N—Labeling and Containers, 2023; Subpart P—Definitions and Standards, 2023). CSIs check the labels and Formulation Sheets for compliance with regulations and the accu- rate listing of ingredients. In an example of mislabeling, cartons of Korean-style beef were found to contain a chicken-based product that was not declared on the label, and milk, which was an undeclared allergen (Saunders, 2022). One of the required features of a label oc- casionally tested by CSIs is the net weight of the product in the packages. The net weight is the weight of the packaged meat and poul- try product minus the weight of the packag- ing (tare weight). The customer pays for only the net weight and not the gross weight (net weight + the tare weight). Big 9 Formulation Verification Due to an increase in the number of recalls of products containing allergens that were not declared on the labels, FSIS directs CSIs to schedule a task to verify that companies are complying with the requirement to list allergens. Even though this task involves labeling issues, it has public health signifi- cance because anyone consuming an aller- gen that they are allergic to will suer health consequences. This task is scheduled once per month for each company that produces allergen-containing products. The Big 9 Food Allergens refer to nine al- lergens that account for 90% of all food aller-
gy reactions. In 2023, the Food and Drug Ad- ministration (2023) added sesame to the list of major food allergens. The Big 9 are milk, tree nuts, crustaceans, fish, peanuts, wheat, soybeans, eggs, and sesame. CSIs are to ob- serve the formulation of products and review records to verify that there is consistency be- tween the products and the labels, including declaration of allergens. If a company does not comply with the regulatory requirements, the CSI documents a noncompliance record and takes appropriate action to protect public health, such as the initiation of a recall. Summary and Conclusion CSIs have a wide range of inspection duties. CSIs monitor the food safety systems via SSOPs, HACCP plans, and general sanitation. Companies are required to have an SSOP plan in place to show what they are going to do to prevent contamination of products and food-contact surfaces. SSOP plans include corrective actions whenever deviations occur. A HACCP plan is an analysis of each step in the process of food production to determine which steps are CCPs. These CCPs include the hazards to be controlled, monitoring pro- cedures and frequencies, verifications and frequencies, critical limits, and recordkeep- ing. FSIS ensures that product labels are not deceptive and do not contribute to a public health issue such as allergens. Disclaimer: The information and conclusions of this special report are those of the author and do not necessarily represent the ocial position of USDA or FSIS. Further, the inter- pretation of the regulations used to support this special report may not reflect the actual interpretation set forth by USDA and FSIS. Corresponding Author: Roger W. Amery, 1663 Delaware Court, Geneva, IL 60134. Email: ameryrogerw@yahoo.com.
References
Amery, R.W. (2023a). Federal meat and poultry inspection duties and requirements—Part 1: History and current responsibilities. Journal of Environmental Health , 85 (9), 22–25. Amery, R.W. (2023b). Federal meat and poultry inspection duties and requirements—Part 2: The Public Health Inspection System,
marks of inspection, and slaughter inspections. Journal of Environ- mental Health , 85 (10), 16–19. Food and Drug Administration. (2023). Food allergies . https://www. fda.gov/food/food-labeling-nutrition/food-allergies
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