National Advisory Committee on
Meat and Poultry Inspection
November 14 - 15, 2001
Standing Sub-Committee Number 2
Issue: Modernizing Standards of Identity for Meat and Poultry Products
Standards of identities are necessary, but should be flexible enough
for industry to meet new consumer expectations, but must continue to be
truthfully and inclusively labeled.
- What are the general comments of the Committee on the Strategy and
guiding principles outlined by the Agency?
Supportive of guiding principles consistent with FDA for development
of petitions that the Agency can use as a basis for proposed rule
making.
Do any Committee members have data that demonstrate the
relationship between food standards modernization and the impact on
public health?
Committee is unaware of data, but recommends calls for research
through various channels available through USDA as well as query
various consortia.
What is the process used by representatives of the meat and poultry
industry, consumer groups, and others to identify the need for a change
to an existing food standard or the creation of a new standard?
- Consumers trends
- New ingredients, public aspect focus group correspondence.
- Market process (domestic & International)
- Consumer market perceptions of products standards
- Ethnic demographics
- Does the Committee have any data on the costs to industry for
compliance with food standards, such as time, resources, trade,
competition, and compliance?
With regards to data to support the Agency for proposed rule making
of guiding principles, the committee recommends trade group survey of
industry members to determine what information is available and
collect, compile, and provide what is appropriate to the Agency.
With regards to proposal outlining principles to follow committee
recommends that detail be requested in proposed rule for petitioners
related to data needed by FSIS relating to the particular standard.
- Is the Committee aware of any research available regarding consumer
and industry perceptions of food standards to support the rule making
process?
Committee is not aware of specific data beyond the NPPC/NCBA survey
submitted for review.
- Is the Committee aware of any economic harm to industry because
enforcement of outdated food standards or the absence of a way for
industry to modify current food standards?
Perceived, real or potential economic harm due to enforcement of
outdated standards resulting from the inability to keep up with
consumer trends and explore new technologies that might enhance product
safety.
The Committee fully supports the guiding principles as outlined in
the issue paper, and wishes to reemphasize that the modernization of
food standards of identity would permit enhancing a product safety
without adversely affecting its labeling and consumer product
recognition.
Outdated standards also can result in loss of market shares to
different commodities meeting consumer dietary needs.
- Is the Committee aware of any implications of Federal food
standards modernization on State regulations or international food
standards of identity?
Insignificant effect on State because pre-emptive Federal
regulations would require State to change with Federal changes.
Recommend Agency include harmonization discussion with International
and US Standards as part of guiding principles.
- Does the Committee have any evidence that shows that modernization
of food standards will result in greater product diversity in the
marketplace?
Anecdotal observations of greater product diversity related to
reduce fat products as an example.
Recommend trade group marketing committees survey industry members
for additional data.
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