Since early March, the product notoriously known as “pink slime,” Beef Products Inc.’s lean finely textured beef, has come under an unprecedented amount of scrutiny from most everyone who eats. The ensuing debate has prompted many to question why ground beef packages containing the product are not labeled as such, or at the very least, why the ammonium hydroxide gas used to kill bacteria on the beef is not labeled as an additive or ingredient.

Which elements of food production get labeled and which go incognito, and why?

In the case of lean finely textured beef, the answer to that question involves taking a look at the rules surrounding particular substances in food production called “processing aids.”

Processing aids are substances used to aid food production, are not found at significant levels in the final product and have no “functional or technical effects” on the food. The wide-reaching category encompasses everything from organic acids in produce washes to dough strengtheners in frozen waffles.

In short, neither the U.S. Department of Agriculture (USDA) or the Food and Drug Administration (FDA) require food makers to list processing aids on labels, and a wide variety of processing aids are allowed in food production as long as each one falls within the guidelines of being “Generally Recognized as Safe,” a classification for ingredients often abbreviated as “GRAS.”

The FDA keeps lists of GRAS products, whether they are used as additives or processing aids. (Whereas processing aids are not identifiable in foods, additives are ingredients required on the label because they are found in the final product and technically alter it.) These GRAS lists include everything from salt to chlorine gas to ammonium hydroxide, the antimicrobial used to sanitize lean beef trimmings.

To better illustrate the role of processing aids in food production, the USDA cites the example of a compound called sodium silicoaluminate and its role in sausage. The seasonings found in some sausages may include sodium silicoaluminate for its technical use as an anti-caking agent. Look at that sausage as a whole, however, and the presence of sodium silicoaluminate does not significantly change the food’s identity as a sausage.

Given the complexity of the modern food system, accounting for every input that goes into the average supermarket product would be a challenging and largely impractical undertaking, said Dr. Richard Raymond, former undersecretary for food safety at USDA.

In theory, substances classified as processing aids should carry no distinguishable traits into the final product, and therefore identifying them all on a label should have little value, Raymond told Food Safety News. But the classification of processing aids is not an exact science, he added, and some processes get excluded from the club.

As an example, Raymond cited Congress’ classification of irradiation as an additive rather than a processing aid despite the technique fitting the criteria of a processing aid. Food irradiation is the process of eliminating microorganisms from food through exposure to ionizing radiation.

In the U.S., meats, spices and some fruits and vegetables can be irradiated to improve safety or shelf life. Because of irradiation’s classification as an additive, however, irradiated foods are designated with an international symbol, the Radura, to inform consumers their food was treated with irradiation.

“When consumers see the Radura symbol on meat, they don’t want to eat it,” Raymond said. “But (for) whole carcass, low-dose irradiation is no different from any other processing aid that’s generally recognized as safe.”

As it turns out, classifying additives and processing aids as GRAS is not an exact science, either. As the term “Generally Recognized” implies, the FDA looks for a substance to be considered safe according to the consensus of qualified experts, but the agency simply lacks the resources to test all ingredients itself.

Individuals in the food industry often supply scientific data to the FDA for the agency to declare an additive or processing aid as GRAS. Because of the sheer number of substances involved in food production, the FDA relies on industry to vet products and has not conducted a full review of GRAS substances since 1997.

As a result, industry perception plays a role in whether a substance gets declared as a processing aid or an additive, and therefore whether or not it ends up on the label. By the nature of the categorizing process, each substance gets classified on an individual basis, as the USDA’s federal food labeling guide explains:

“[The Food Safety Inspection Service] does not have a definition for incidental additives or processing aids. However, if a company believes that the use of a substance in the manufacture or formulation of a meat or poultry product is consistent with FDA’s labeling definition for an incidental additive processing aid, then data needs to be submitted to FSIS to substantiate conformance with the FDA regulation. FSIS will determine on a case-by-case basis whether a request for the specific use of an ingredient is consistent with FDA’s labeling definition of an incidental additive processing aid and thus, exempt from labeling.”

As the scrutiny around lean finely textured beef continues, the intricacies of food labeling rules are certain to only make the debate slimier.

  • Michael Bulger

    It seems to me that anyone who’s primary concern is food safety would not champion ground beef. It could easily be argued that ground beef persists primarily due to consumer choice and despite food safety concerns. The argument that the ill-informed consumer is ruining the business of food safety by objecting to “pink slime” thus reveals itself to be two steps back.
    Raw ground beef is a consumer-demand product, not a food safety product.
    If safety was the primary concern, the beef would be precooked and not raw. To go to the wall in the name of food safety for such a product as LFTB is to stretch the imagination of the observer.
    I simply mean that food safety advocates (who I admire greatly) should temper their expectations of public sympathy when it comes to processed hazardous foods.

  • Barb

    I want to know why (in addition to the other questions) the price of ground beef containing ‘pink slime’ isn’t lower. Doesn’t the addition of this stuff bring the cost down? I looked at extra lean ground beef at WalMart last week and it was marked at almost $10 a pound.

  • Donnie

    Processing aids derived from corn are frequently used, and never labeled. This also applies to sulfites used to bleach food starches, and other purposes. For those of us who are allergic to corn or sulfites, this is a risky situation. We never know if a food or food product that we eat contains hidden corn, sulfites or both, until after we eat it. We can have severe allergic reactions to foods we thought were safe for us. It is rarely helpful for us to contact food companies to ask if corn or sulfites are used as processing aids. The customer service people either say don’t know, or will tell us they are not used, when they actually have been used in processing. Misinformation can be deadly for us. I am allergic to both corn and sulfites and hidden cornstarch and corn derived citric acid, lactic acid and other unlabeled corn/sulfite processing aids are dangerous for me.

  • Radiation is, by definition, a form of energy whose mass is exceedingly negligible making it hard to understand how exposure of a food to an energy source could possibly be construed as introducing an “additive” to such irradiated food.
    Somewhere on its voluminous web site, FDA has published a position paper on the subject of food irradiation and where it has explained that the reason for this odd categorization is that FDA has found that radiation of certain energies and doses tends to convert certain normal components of food into new chemical entities, not originally present in the food before irradiation. The FDA views these new chemicals, arising as the direct result of radiation, as the additives in question. Since these new chemical entities arise in food in amounts proportional to the radiation intensity, FDA has therefore chosen to consider the process of irradiation itself as an additive (because it causes additives to arise).
    Maybe FDA’s reasoning in this matter is a bit too pointy-headed for most folks, but that in itself doesn’t make it wrong. Actually, I see their position as quite useful. Since the “additives” arising from irradiation have been identified and quantified, perhaps some clever folk can figure out a way to irradiate food in such a way as to disable the “Bad Bugs” without generating the additives that have been identified and defined as the problem with irradiation. As I see it, a process like this run through the existing rules would eliminate the need for any scary labeling (i.e., no additives). At that point, the meat industry would have the “kill step” HACCP depends upon. This would not, of course, solve all problems, but it would be a step forward and it certainly would be a competitive advantage to whoever took that step first.

  • “The ensuing debate has prompted many to question why ground beef packages containing the product are not labeled as such, or at the very least, why the ammonium hydroxide gas used to kill bacteria on the beef is not labeled as an additive or ingredient.” Additives in food, drugs, cosmetics, and medical devices require approval by U.S. FDA. The form and frequency of approval depends on the particular Additive. For most Additives, the appropriate approval process requires approval of each batch. For more information visit

  • This is more than about a little puff of ammonia hydroxide.
    The meat known as “pink slime” is the discarded waste meat from the butchering process at several meat plants brought together into one place–heated so the fat melts and then force into a centrifuge to separate the meat from the fat. This, all before it gets squeezed through a tube and puffed with ammonia hydroxide–the levels of which a specific plants controls without USDA supervision.
    This is all very different from what people expect: a chunk of meat goes into a grinder and then onto the shelves.
    You can talk about the importance of educating consumers related to other products and then decry education consumers because you happen to support a company.
    You all need a consistent message.

  • Wynann Brownell


  • Jen

    I don’t see people pitching a fit about hotdogs. What do you think hotdogs are made out of? And bologna? And deli meat.. do you think turkey, beef & ham all come off the animal like that? No, it is processed and pressed and held together with congealers, treated with nitrites. I think if people are going to gripe about ammoniated beef trimmings, they need to gripe about all processed meats. But, the meat is ammoniated because they want it to be SAFE. How many meat companies selling raw beef are treating it to kill pathogens? Can’t we be happy that they care enough to do this? Ammonia is a natural substance. Our bodies produce it naturally. It is not used in levels even remotely high enough to be considered dangerous to our health. If you don’t want to eat this kind of beef, buy from your local butcher. That is your right, and your choice. But stop condemning this company for this process when it is done for our safety.

  • John

    “Done for Our Safety?? Nice thought, but this is REALLY being Done for Their Profitability. And the bottom line is they are selling “trimmings” (connective tissue, etc) falsely as “Meat”…
    And yes, good point about hot dogs and processed meats (yummy with lots of addictive sugar and salt and Many preservatives) — Buyer Beware. Being full of baloney is not usually an accolade….
    And while the microbial toxins may have been put through a kill step — there’s nothing healthy or safe about these foods…

  • citizen 625

    Did you know that Japanese researchers are extracting edible products, and feeding them to research subjects, from human feces? Could you argue that the feces was a processing component of the final amino acids and doesn’t need to be labeled? The only people who don’t want to fully and completely label foods are those who benefit financially.

  • First, sorry for typos earlier.
    Jen, no this material is not the same as cold cuts or hot dogs. Most people know that unless they check further, they could be getting mystery meat of a form in a hot dog or cold cut.
    Hamburger is a different thing. It’s packaged as “fresh ground beef”. People have expectations about hamburger, especially at the store, they don’t necessarily have with packaged hot dogs.
    Right now, with this stuff mixed in, I genuinely feel that consumers are being deceived.
    I don’t think anyone has condemned the company. People have decided they don’t want anything to do with this material, which is our right. And we’re demanding to know when the food we eat has this material introduced into it. And this is also our right.
    We can’t make good food choices if the USDA and this expert and that decide unilaterally what we do and don’t need to know. No safety procedure in a company is going to make up for withholding important information.
    This entire publication is based on the premise of disseminating information and educating people. How can it, then, support suppression of information and keeping people ignorant?
    A very inconsistent message.

  • Hi Shelley,
    I’m confused by your last comment. Are you saying that Food Safety News is supporting the suppression of information about LFTB?

  • Javaguy

    Wynann, please be advised if you eat any processed foods produced in the United States that contain the following ingredients: Corn or any of it’s major derivatives, of which there are dozens…see HFCS, Soy; including items like soy lecithin, or Sugar/Sucrose derived from Beets,you are eating GMO altered foods. You’re only method of ensuring a GMO free diet is to exclusively choose organic products or change your residency to any of the countries in the EU, which require GMO labeling. Oh wait, GMO labeling would be considered socialist…now wouldn’t it? And we can’t have that in the good ole USA can we?

  • Hi Shelley,
    I’m confused by your last comment. Are you saying that Food Safety News is supporting the suppression of information about LFTB?

  • James, frankly that’s the impression these series of articles and opinion pieces are beginning to imply.
    Yes, many of the pieces are by authors outside this publication, but the articles and opinion pieces originating from Food Safety People do show a generalized support for BPI, and, frankly, a somewhat dismissive attitude towards those who are concerned about this material being mixed into hamburger meat. Excuse me, unlabeled hamburger meat.
    The impression if strengthened by Dan Flynn’s recent piece equating online petition sites with “mob rule”. Following all the discussions related to the “pink slime” petition, it’s not a stretch to make a connection between this activity and Flynn’s piece.
    (As a side note to Flynn: the anti-climate groups also make the demand for “reasonable decisions that flow from science”. This, after they basically ignore or disregard any inconvenient science.)
    The message Food Safety News is giving is inconsistent.

  • Shelly, the goal at Food Safety News is not to create an echo chamber of positions you might agree with. We will leave that to FOX News and MSNBC – whatever might be your preference. We try hard to keep the news factual and the opinions hot. The idea is to let the reader make decisions on their own on the truth of news stories and to challenge pre-set notions in opinion pieces.

  • – Check out how pink slime is made –
    this disgusts me..

  • Jen

    I am confused. How would anyone think hamburger is anything other than junk meat from hundreds of different cows all ground up together? Do you think it is simply nice hunks of whole muscle meat that is ground up? No.. that is why it is why they grind it. Who would take a perfectly good steak and grind it up? Ground meat is sort of the low end left overs of the meat world mixed with muscle meat. If you want non-ammoniated beef, go to your local butcher, and leave BPI out of it.

  • Fair enough, Bill.
    I’m actually not as bothered by FSN support of whatever this stuff should be called. You appreciate the safety factors and the effort the company makes to a higher degree than I (and others) do. Frankly, a much higher degree.
    I am bothered, though, by FSN’s seeming rejection of the ability of the public to express dismay over this material being included in what we assume to be “fresh ground beef”. The use of the term “mob rule” by your editor, Flynn, was, frankly, patronizing.
    Patronizing and naive. I’m astonished that anyone would think most people wouldn’t react negatively. You’re a lawyer, part of your job is to understand people’s perceptions. You must not be surprised by any of this.
    In my opinion? The biggest mistake BPI ever made was not demanding that any hamburger carrying their product be labeled. If the company is proud of what it produces, you’d think they’d want it showing up in gold letters on the package.
    By demanding the label, they’re the ones who could have controlled the initial exposure. Now? Trust has been broken.

  • Jen

    Perhaps Americans should look up what ground beef or hamburger may be made of, according to USDA. Perhaps we assume too much, or know too little about the food industry. I do not think this company is mislabeling anything, especially when USDA defines what can be included in ground beef and BPI did not step outside their boundaries. If you want different labeling laws, yell at USDA or go to your legislators to petition. Don’t blame BPI.
    “All types of lean finely textured beef are sustainable products because they recover lean meat that would otherwise be wasted. The beef industry is proud to produce beef products that maximizes as much lean meat as possible from the cattle we raise. If this beef is not used in fresh ground beef products, approximately 1.5 million additional head of cattle would need to be harvested annually to make up the difference, which is not a good use of natural resources, or modern technology, in a world where red meat consumption is rising and available supply is declining.
    Ammonium hydroxide is used in the processing of a wide array of other foods including soft drinks, baked goods, cheeses, and puddings. Ammonia is essential to life and naturally present in meat and almost everything else we eat.
    When any form of lean finely textured beef is blended into ground beef, will it be labeled?
    Because it is 100% beef, LFTB is not singled out as a separate ingredient on ground beef packages.”

  • Anthony Boutard

    Yes, people should read the definitions, or “standards of identity,” in the Code of Federal Regulations (CFR). It has separate standards of identity for ground beef/hamburger and beef patties.
    9CFR139.15 (a) & (b) define chopped beef, ground beef and hamburger as containing “chopped fresh and/or frozen beef with or without seasoning and without the addition of beef fat as such, shall not contain more than 30 percent fat, and shall not contain added water, phosphates, binders, or extenders.”
    At 9 CFR 139.15 (c), beef patties “consist of chopped fresh and/or frozen beef with or without the addition of beef fat as such and/or seasonings. Binders or extenders, Mechanically Separated (Species) used in accordance with Sec. 319.6, and/or partially defatted beef fatty tissue may be used without added water or with added water only in amounts such that the product characteristics are essentially that of a meat pattie.”
    As I read the standards identity, “lean finely textured beef” is only permitted in a product labeled as a beef patti (sic), not those labeled as chopped beef, ground beef and hamburger. In fact, under 9CFR319.6 (d) “Mechanically Separated (Species) and Mechanically Separated (Species) for processing described in Sec. 319.5 shall not be used in baby, junior, or toddler foods, ground beef, hamburger . . .”
    In other words, “lean finely textured beef” or LFTB is not allowed in a product labeled as ground beef or hamburger, or, for that matter, food for young children. Labeled as beef patties and all bets are off.

  • BB

    Heh, heh, Anthony. Even honey isn’t recommended for babies, juniors or toddlers (botulism, you know). It’s a bad idea to feed ’em raw organic veggies, too — grown in manure and thus inoculated with a variety of nasty disease bugs, you see. So, what’s your point about LFT beef? How exactly is it uniquely dangerous? You certainly are reduced to grasping at straws to argue your transparently agenda-driven position. So, so sad.

  • Inspector Minkpuppy

    Your interpretation of 9CFR319.6 (d)in regards to LFTB is incorrect because LFTB is not considered mechanically seperated beef due to the way it is made. The processes are totally different, different raw materials are used, and different regs apply.
    Yes, “Machines” are used in both but the machines do different things. One extracts the meat from bone through mechanical force. The other seperates it from fat through heating.
    That’s the part that’s confusing for anyone that hasn’t actually eyewitnessed the processes and believe me, 99% of the articles describing the process are incorrect.
    LFTB is created by heating the trimmings enough to liquify the fat and spins it off in centrifuge type drum. Then it’s treated with ammonium GAS, not washed in liquid ammonia. That’s the biggest lie of all. The gas disperses quickly and no residue is left on the product. That’s why it’s not required to be labeled.
    LFTB comes from the fatty trim left over from trimming steaks down to no fat at all because that’s what the consumer wants. It’s much more efficient than throwing 20 guys on a trim line to trim off those bits of lean left on that fat trim. It’s not floor scrapings (also banned) or dog food. No bones are involved in this whatsoever. Mechanically seperated meat regs don’t apply here.
    In contrast, mechanically seperated beef raw materials are bones with meat attached, not fat. It’s produced by feeding bones through a device that applies mechanical force to the
    bone to extract the meat rather than heating. It is banned because of the risk of spinal cord tissue and other specified risk materials making it into the meat when spinal columns are sent through the machine. Spinal cord tissue is banned because it could carry BSE prions and we don’t want Junior getting mad cow disease from his cheeseburger.
    Two completely different processes. Period.
    “Arguing with an inspector is like wrestling a pig in the mud.
    After awhile, you realize the pig likes it.” -seen on a poster in a USDA office 🙂