Food Safety and Inspection Service (FSIS) labels are not always informative. The warning label prescribed in 9 C.F.R. 317.2(l) and 381.125(b) has faded into the background of consumer’s awareness by overuse. Other terms such as “uncooked” or “ready to cook” for partially cooked or breaded products are not as clear as “raw” or “contains raw meat/poultry.” In a 2007 report, USDA’s National Advisory Committee on Microbiological Criteria for Foods stated, ”’Ready-to-cook’ may not clearly inform the consumer that the product must be cooked to a minimum internal product temperature to kill pathogens.” In an earlier draft, the committee had concluded, “It should not be left to the consumer to determine if the product is RTE, especially if the product is partially cooked or otherwise appears ready to eat. Ambiguous terms such as ‘Ready to Cook’ must be avoided to prevent consumer confusion on product handling and preparation.” Yet, a visit to a grocery store will reveal FSIS-inspected packages with “Ready to Cook” labels. Smith, et al, reported in 2008 that, in four outbreaks of salmonellosis involving breaded, prebrowned, stuffed chicken products, “most individuals affected thought that the product was precooked due to its breaded and prebrowned nature, most used a microwave oven, most did not follow package cooking instructions, and none took the internal temperature of the cooked product.” After another outbreak of salmonellosis involving Chicken Kiev, I suggested to a member of the FSIS Labeling Division that the product label should include “raw chicken.” The response was that the industry does not like “raw” and prefers “uncooked” or “ready to cook.” That is contrary to the definition for mislabeling where clear labeling is prescribed by the Meat Inspection and Poultry Inspection Acts, 21 USC (n)(6) and 21 USC 451 (h): “The term ‘misbranded’ shall apply to any carcass, part thereof, meat or meat food product under one or more of the following circumstances: if any word, statement, or other information required by or under authority of this chapter to appear on the label or other labeling is not prominently placed thereon with such conspicuousness (as compared with other words, statements, designs, or devices, in the labeling) and in such terms as to render it likely to be read and understood by the ordinary individual under customary conditions of purchase and use; …” An alternative to relying on clear labeling is in 9 CFR 318.10(b) that prescribes destruction of Trichinella spiralis in pork products: “Products named in this paragraph, and products of the character hereof, …  shall be effectively heated, refrigerated, or cured to destroy any possible live trichinae … and other product …, which the Administrator determines  … would be prepared in such a manner that the product might  be eaten rare or without thorough cooking because of the appearance of  the finished product or otherwise.” Given that T. spiralis is less prevalent and less heat-resistant than salmonellae, one must wonder if that provision is overly strict or is FSIS policy toward Salmonella and salmonellosis indifferent. References: National Advisory Committee on Microbiological Criteria For Foods. 2007. Response to the Questions Posed by the Food Safety and Inspection Service Regarding Consumer Guidelines for the Safe Cooking of Poultry Products Journal of Food Protection, Vol. 70, No. 1, 2007, Pages 251-260. Smith, Kirk E.; Medus, Carlota; Meyer, Stephanie D.; Boxrud, David J.; Leano, Fe; Hedberg, Craig W.; Elfering, Kevin; Braymen, C. 2008. Outbreaks of Salmonellosis in Minnesota (1998 through 2006) associated with frozen, microwaveable, breaded, stuffed chicken products. Journal of Food Protection. 71:2153-2160.

  • Kristin Woods

    Great article. Rtc is not as clear as raw.

  • crs

    Using the word “raw” makes a lot of sense. It’s strong and unambiguous, and probably the industry feels distaste for the word because everyone feels distaste for raw chicken. Industry concern that sales could be affected even minimally must not take precedence over consumer safety, right?