Four years ago, Thomas Gremillion of the Consumer Federation of America petitioned USDA’s Food Safety and Inspection Service (FSIS) on behalf of the Safe Food Coalition. The petition sought an FSIS rulemaking to revise the regulations that prescribe mandatory safe handling instruction (SHI) labeling for raw and partially cooked meat and poultry products.

In a May 31 decision letter, FSIS told Gremillion it was denying his petition and is not planning on doing any rulemaking “at this time.”

“FSIS will continue to explore new strategies for communicating safe food handling practices to consumers. The current SHI labeling regulations will remain in place while we consider research options and other strategies,” the agency ruling says.

The Safe Food Coalition is “not precluded from submitting a revised petition that contains additional information to support the requested actions.”

The Safe Food Coalition petition specifically asked that FSIS update the regulations to require that the SHI label:

  • display information about thermometer use and end-point cooking temperatures;
  •  include the “Check Your Steps” logo that identifies the four safe handling practices on the website — clean, cook, separate, and chill –instead of the current required graphic
  •  be positioned in a manner to ensure the label’s readability; and
  •  include a web address for additional information on safe cooking recommendations.

FSIS  claims the results of recently published consumer research found that three experimental SHI labels that contained many of the features requested in the petition did not perform better than the current SHI label regarding visual attention and label adherence for all four safe handling instructions.

FSIS said research also found that consumers tend to focus more on the manufacturer’s cooking instructions (MCI) than the SHI.

“Based on these results, FSIS has concluded that initiating rulemaking to revise the SHI labeling regulations as requested in your petition would not be an effective use of agency resources because the requested revisions would likely have a limited impact on influencing consumer food handling behavior,” according to the decision. “Therefore, as discussed below, we have decided to deny your petition without prejudice.”

The National Advisory Committee on Meat and Poultry Inspection (NACMPI) Subcommittee on Food Handling Labels recommended in 2014 that FSIS pursue changes in the existing SHI label and conduct consumer research to determine the effectiveness of any revisions to the SHI label.

Six consumer focus groups that FSIS conducted in 2015 revealed that consumers would find certain revisions to the SHI label, such as recommendations to use a food thermometer and providing endpoint temperatures, useful.

“Based on these results, FSIS determined that additional research using more rigorous, quantitative approaches with a larger sample of consumers was needed to help inform potential revisions to the current SHI label and assess whether a label revision would improve consumer food safety behaviors,” the agency said.

FSIS contracted in 2018 with RTI International and its subcontractor North Carolina State University (NCSU) to conduct consumer behavior research to assess whether revisions are needed to the SHI label required on all raw and partially cooked products and to evaluate the ability of consumers to properly discern between not ready-to-eat (NRTE) and (ready-to-eat) RTE products

RTI submitted its final report on the consumer research results on September 23, 2020. A brief summary of the results related to the SHI label is discussed in the decision letter and the full research report is published on the FSIS website at:  The summary points include:

  • The first phase of the research consisted of a web-based experiment that was conducted with a sample of U.S. consumers to select three variants of a revised SHI label that best attract participants’ attention.
  • The three revised SHI labels that were selected contained many of the features requested in the Safe Food Coalition petition, such as information about thermometer use and end-point cooking temperatures, updated safe handling messages and graphics, and a web address for additional information on safe cooking recommendations.
  • The second phase of the research consisted of a behavior change study to evaluate the effectiveness of the three revised SHI labels compared with the current SHI label on the study participants’ adherence to recommended safe handling instructions
  • The behavior change study included an observational meal preparation experiment, an eye-tracking study, and post-survey interviews with study participants.

The decision letter says; “The results of the behavior change study showed that the three revised labels, which, as noted above, contained many of the features requested in your petition, did not perform better than the current SHI label regarding visual attention and label adherence for all four safe handling instructions.”

“While one revised label was more effective at encouraging proper handwashing, it did not influence other behaviors. The study also found that participants tended to spend more time looking at the manufacturer’s cooking instructions (MCI) than the SHI label, and they tended to look at the MCI before they looked at the SHI,” it added.

Also on the petition front last week, FSIS posted additional comments on the Northern Goose Processors petition. It seeks an amended standard for the  definition of “Ready to Cook Poultry,” to allow the production and import acceptance for the Chinese Young Goose with Head without requiring a religious exemption.

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