On May 24, 2016, the National Chicken Council ("NCC")
petitioned USDA's Food Safety and
Inspection Service ("FSIS") to adopt regulations
concerning the labeling of raw, stuffed chicken products. NCC is
requesting that FSIS require that not-ready-to-eat
("NRTE") stuffed chicken breast products that appear
ready-to-eat ("RTE") be labeled to "clearly inform
consumers that the products are raw and how to properly handle and
cook them." Specifically, NCC requests that FSIS amend 9
C.F.R. Part 381 to add a new section that: (i) defines a NRTE
stuffed chicken breast product that appears RTE; (ii)requires the
product name to contain the term "raw" and an accurate
description of the poultry component; (iii) requires the principal
display panel of the product to bear a "raw product"
safety statement, a raw chicken safety icon with the statement
"oven bake only," and a serving suggestion explaining
that the label illustrates the suggested serving of the product
after baking; and (iv) requires the labels to contain
validated cooking instructions containing the proper cooking
method, the endpoint temperature, instructions to measure the
internal temperature using a meat thermometer, the "do not
microwave" icon, the "oven bake only" icon, and the
statement "raw—do not microwave" followed by the
explanation "to help prevent foodborne illness caused by
eating raw poultry."
In addition, the petition calls for FSIS to publish a compliance
guidance explaining how to validate cooking instructions for such
NRTE stuffed chicken breast products that incorporates NCC's
"Best Practices for Cooking Instruction Validation for Frozen
NRTE Stuffed Chicken Breast Products." NCC's Best
Practices are consistent with and expand upon FSIS's
recommendations for validation. For example, NCC's Best
Practices advise that cooking instructions for each product should
include guidance for the appropriate metal cooking utensil to
support consistent cooking results, appropriate product spacing to
support even heating of the product, and the standard placement of
the product in the oven, all of which should be validated
accordingly.
In a similar but unrelated citizen petition on May 31, 2016, the Safe
Food Coalition also requested that FSIS revise its labeling
requirements for raw chicken, as well as for raw and partially
cooked meat and poultry products and siluriformes fish.
Specifically, the petition requests that the rules require labels
to provide more specific information about safe handling practices
for such products, including: (i) an endpoint temperature, as well
as any "rest time" requirement; (ii) instructions to use
a thermometer to verify the product has reached the recommended
internal temperature; (iii) information on safe handling practices
to minimize risks associated with improper sanitation, handling,
storage, and temperature control; (iv) the four core "check
your steps" safe food handling graphics featured on the food safety
website, instead of the graphics currently displayed; and (v) a
web address for additional information.
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