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Wednesday, January 25, 2012

USDA Proposal looking to eliminate Labeling Specialists, those who monitor ingredients, including allergens, in meats and poultry

The USDA is proposing to eliminate the review of all meat and poultry ingredient statements and formulas by their labeling specialists.  The current USDA regulations require that all ingredients, including allergens, be listed in the ingredient statement of every meat product sold in the U.S.  The subject proposal would end all review of ingredients statements by USDA labeling specialists.

Milk is frequently used as a binder in many products, often meats.  This legislation would make it near impossible for those managing milk allergies to safely buy meats and poultry over the counter, with the exception of those products which are certified organic.  This may not be such a bad thing, however, the financial cost can be an added burden for some.

In order to better understand the topic at hand, I have reprinted below the email forwarded to me from Michelle Fogg, President of the Utah Food Allergy Network (UFAN).  I am hoping that many of you will take action by forwarding this on to as many people as you think will help to stop this proposal from being approved.

Thanks for your support!
Daniella Knell

From: Robert G. Forbes <>
Date: Wed, Jan 25, 2012 at 8:45 AM
Subject: USDA proposal to cease review of all ingredient statements

Over the past few weeks I have corresponded with you concerning the USDA plan to expand generic label approvals and eliminate review of ingredient statements and corresponding formula information on all labels. Based on a few comments filed on the proposal it appears there may be some confusion regarding this issue.

USDA is proposing to eliminate review of all meat and poultry ingredient statements and formulas by their labeling specialists. USDA regulations require that all ingredients, including allergens, be listed in the ingredient statement of every meat product sold in the U.S. But ingredient labeling is very complex and mistakes are made. When a USDA labeling specialist compares and reviews formula information submitted by the manufacturer against ingredients declared on the product label, undeclared allergen errors are PREVENTED! Products will not be approved and cannot enter commerce until the label is corrected and allergens are properly declared on the product label. USDA’s December 5, 2011 proposal will stamp out this consumer safeguard.

Generic approval means meat processors approve their own labels instead of USDA labeling specialists. USDA permitted limited generic approval beginning in 1996. Prior to 1996, all labels were submitted to USDA’s labeling specialists who approved them after confirming that, among other things, all the ingredients in the food were properly declared on the label. At first the industry was reluctant to approve their own labels because they weren’t sure they were correct. Many relied on the guidance provided by USDA labeling specialists and many still do today. Since 1996, more and more processors began to take advantage of the opportunity to approve their own labels. Over the past few years, USDA has more actively encouraged them to do so. In 1995 there were zero recalls due to undeclared allergens. Recalls for undeclared allergens have increased steadily ever since. By 2009, there were 14, in 2010, 16 ,and last year there were 41 involving at least 500,000 pounds of product, and this is just the tip of the iceberg. Many more undeclared allergen errors go unnoticed entirely because a generic label application form, formula, and processing procedures are not required to be submitted to USDA for review. Accordingly, the mislabeling is never discovered either prior to or after entering the marketplace. Since the product formula was never disclosed to labeling headquarters, no one but the manufacturer knows what’s in the product! This results in many unsuspecting consumers experiencing adverse reactions caused by ingredients they did not know they were ingesting.

The subject proposal would end all review of ingredients statements by USDA labeling specialists. Even if the processor wanted USDA guidance on whether everything was properly declared, USDA would not provide it. So far, many processors and their associations have voiced concern that without USDA labeling specialist review they may inadvertently put a product on the market that is mislabeled. That’s a big problem for the processor and a bigger problem for the allergy sufferer.

As I’ve said before, when USDA is bent on advancing their agenda they have a history of ignoring consumer and industry comments. If you feel this proposal will have an adverse effect, you should comment to USDA, but also we urge you to contact your Congressional representatives. The comment period ends February 3, 2012, so time is of the essence.

To obtain contact information for your Congressional representative you may access: and enter your zip code in the upper right corner under the heading "Find Your Representative". To contact your senators go to: and select your state from the pull down menu in the upper right corner of the page.

Here is a suggested comment to forward to your representatives:

We are opposed to the USDA proposal published in the Federal Register December 5, 2011 which would discontinue review and approval of all meat and poultry formulas and ingredients statements by USDA labeling specialists. This proposal would increase the incidences of undeclared allergens and put the health and safety of millions of Americans with food allergies at greater risk. We ask that you help stop this USDA action.
You may review a copy of the lengthy proposal at (

From there you may also file a comment with USDA.

If you have any questions or would like to discuss the proposal please feel free to contact me.
Bob Forbes
Government Liaison Services, Inc.
200 N. Glebe Rd. Suite 321
Arlington, VA 22203

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