It’s the law: Descriptive designation for needle-or blade-tenderized raw beef products as required by 9 CFR 317.2(e)(3)


This notice cancels and reissues the content of FSIS Notice 29-16 to provide clarification on the requirements of the final rule in Section III, the products that are not subject to new requirements in Section IV, and to fix the web-link to the final rule in Section II. This notice provides instructions to inspection program personnel (IPP) on how to verify that establishments meet the new labeling requirements for raw or partially cooked needle or blade tenderized supertroopbeef as specified in 9 CFR 317.2(e)(3).


On May 18, 2015, FSIS published a final rule to establish labeling requirements for raw or partially cooked mechanically tenderized beef products (Descriptive Designation of Needle- or Blade-Tenderized (Mechanically Tenderized) Beef Product (80 FR 28153)). The rule amends the regulations by adding 9 CFR 317.2(e)(3). See Section V. of this notice for the effective date for this rule.


  1. Under 9CFR317.2(e)(3) the product name for a mechanically tenderized beef must contain a descriptive designation:
  2. “Mechanically Tenderized” or, if needle tenderized the product can be described as “Needle Tenderized,” or if blade tenderized, the product can be described as ”Blade Tenderized.”
  3. The product name and the descriptive designation must be printed in a single easy-to- read type style and color and must appear on a single-color contrasting background. The print may appear in upper and lower case letters, with the lower case letters not smaller than one-third (1/3) the size of the largest letter, and with no intervening text between the identity of the meat and the descriptive designation. The descriptive designation may be above, below, or next to the product name without intervening text or graphic on the principal display panel.

NOTE: See Attachment 1 for label examples.


  1. Products that are going to another official establishment to be fully cooked or to receive another full lethality treatment are not required to have the descriptive designation.
  2. Thelabelsofraworpartiallycookedneedle-orblade-tenderizedrawbeefproductsdestined for household consumers, hotels, restaurants, or similar institutions must bear validated cooking instructions (see Section VI, C.).
  4. Non-intact beef products that are clearly non-intact, e.g., ground beef patties, hamburger patties, beef patties.
  5. Beef products that are tenderized by other than needle and blade, such as pounding or cubing, which visibly changes the appearance of the product, e.g., cubed beef steak.
  6. Any beef product that has been fully cooked and those destined to another Federal establishment to receive a full lethality treatment.
  7. Raw or partially cooked products labeled as “Corned Beef” that have been mechanically tenderized (including through injection of a solution).
  8. Raw mechanically tenderized beef products that are less than 1/8” thick, such as, beef bacon or carne asada, or raw mechanically tenderized beef products that are diced, such as stew meat.

The final rule was effective for needle- and blade (mechanically) tenderized beef products on May 17, 2016. Product already labeled and in storage prior to the effective dates will not need to be relabeled prior to distribution.

  2. After the implementation date of this notice, IPP are to verify whether establishments meet the requirements in 9 CFR 317.2(e)(3) while conducting the General Labeling task in accordance with FSIS Directive 7221.1, Prior Labeling Approval. IPP are to determine whether the establishment produces this type of product by reviewing a copy of the final label that is in use, the product formulation, the processing procedure for the product.
  3. When performing the General Labeling task, IPP are to verify the required validated cooking instructions contain at a minimum the following information in order to comply with 9 CFR 317.2(e)(3)(iii):
  4. The cooking method (e.g., grill, bake);
  5. That these products need to be cooked to a specified minimum internal temperature;
  6. Whether these products need to be held for a specified time at that temperature or higher before consumption to ensure that potential pathogens are destroyed throughout the product; and
  7. A statement that the internal temperature should be measured by a thermometer.

needle.tenderize.crNOTE: These validated cooking instructions may appear anywhere on the label.


  1. IPParetobeawarethatestablishmentsmaywishtoincludeadditionalinformationwithin the descriptive instructions that will make the labels more useful to consumers; however, FSIS will not require additional information on the product labels. For example, establishments may wish to include the temperature setting of the cooking device, time to complete cooking, whether the product needs to be flipped during cooking, the amount of time to cook on each side exposed to the heat source, recommendations to thaw the product, if applicable, or recommendations to measure the temperature in thickest part of the product, etc.
  2. WhenconductingtheHazardAnalysisVerificationTaskasdescribedinFSISDirective 5000.6, Performance of the Hazard Analysis Verification (HAV) Task for HACCP plans that include mechanically tenderized beef products subject to the Rule, IPP are to verify that the establishment has the appropriate supporting documentation to validate the cooking instructions provided on the label.

NOTE: If IPP have questions regarding the adequacy of the support, they are to seek guidance from their immediate supervisor or an Enforcement, Investigation, and Analysis Officer (EIAO).

  1. IPP are to document the results of their verification, including any noncompliance, in PHIS in a manner that accords with Chapter VI of FSIS PHIS FSIS Directive 7000.1, Verification of Non- Food Safety Consumer Protection Regulatory Requirements.


Needle and damage done: beef roasts

Inactivation of Escherichia coli O157:H7 in beef roasts cooked under selected cooking conditions was evaluated.

needle.tenderize.crEye of round roasts were each inoculated at five sites in the central plane with a five-strain cocktail of E. coli O157:H7 at ca. 6.3 log CFU per site and cooked to center temperatures of 56 to 71°C in a convection oven set at 120, 140, 180, or 200°C, in a conventional oven set at 120 or 210°C, and in a slow cooker set on high or low.

Prime rib roasts were each inoculated at 10 sites throughout the roast with the same E. coli O157:H7 cocktail at ca. 6.6 log CFU per site and cooked in the conventional oven set at 140 or 180°C to center temperatures of 58 to 71°C.

The number of sites yielding E. coli O157:H7 after cooking decreased with increasing roast center temperature for the eye of round roasts cooked in the convection oven or in the slow cooker at a given setting, but this trend was not apparent for roasts of either type cooked in the conventional oven. Reductions of E. coli O157 in both types of roasts were generally less at the center than at other locations, particularly locations closer to the surface of the meat. When eye of round roasts were cooked to the same center temperature in the convection oven, the reduction of E. coli O157:H7 increased with increasing oven temperature up to 180°C and decreased after that. The reduction of E. coli O157:H7 in replicate roasts cooked under conditions in which the organism was not eliminated during cooking mostly differed by >1 log CFU per site. However, E. coli O157:H7 was not recovered from any of the inoculation sites when eye of round roasts were cooked to 65, 60, 60, or 63°C in the convection oven set at 120, 140, 180, and 200°C, respectively; cooked to 63 or 71°C in the conventional oven set at 120 and 210°C, respectively; or cooked to 63°C in the slow cooker set at high or low.

For prime rib roasts, E. coli O157:H7 was not recovered from any of the inoculation sites in roasts cooked to 71 or 58°C in the conventional oven set at 140 and 180°C, respectively.

Inactivation of Escherichia coli O157:H7 in beef roasts cooked in conventional or convection ovens or in a slow cooker under selected conditions.

J Food Prot. 2016 Feb;79(2):205-12. doi: 10.4315/0362-028X.JFP-15-116

Gill CO, Devos J, Badoni M, Yang X

Are you sure about that? Is that roast needle tenderized? Does it matter?

After a few days at the beach and being disappointed with restaurant food, it was good to be home, with my BBQ and a rib roast.

It was fairly delicious.

prime.ribBut the question arises, was it needle tenderized, potentially passing pathogens from the exterior to the interior and requiring a higher cooking temperature for safety.

I know the butcher where I purchased the meat, he knows what I do, and they cut the carcass up at the shop, so I believe him when he says it wasn’t needle tenderized.

All food purchases are faith-based.

Boneless beef rib eye roasts were surface inoculated on the fat side with ca. 5.7 log CFU/g of a five-strain cocktail of Salmonella for subsequent searing, cooking, and warm holding using preparation methods practiced by restaurants surveyed in a medium-size Midwestern city.

A portion of the inoculated roasts was then passed once through a mechanical blade tenderizer. For both intact and nonintact roasts, searing for 15 min at 260°C resulted in reductions in Salmonella populations of ca. 0.3 to 1.3 log CFU/g.

For intact (nontenderized) rib eye roasts, cooking to internal temperatures of 37.8 or 48.9°C resulted in additional reductions of ca. 3.4 log CFU/g. For tenderized (nonintact) rib eye roasts, cooking to internal temperatures of 37.8 or 48.9°C resulted in additional reductions of ca. 3.1 or 3.4 log CFU/g, respectively.

Pathogen populations remained relatively unchanged for intact roasts cooked to 37.8 or 48.9°C and for nonintact roasts cooked to 48.9°C when held at 60.0°C for up to 8 h. In contrast, pathogen populations increased ca. 2.0 log CFU/g in nonintact rib eye cooked to 37.8°C when held at 60.0°C for 8 h. Thus, cooking at low temperatures and extended holding at relatively low temperatures as evaluated herein may pose a food safety risk to consumers in terms of inadequate lethality and/or subsequent outgrowth of Salmonella, especially if nonintact rib eye is used in the preparation of prime rib, if on occasion appreciable populations of Salmonella are present in or on the meat, and/or if the meat is not cooked adequately throughout.

Microbiological safety of commercial prime rib preparation methods: Thermal inactivation of Salmonella in mechanically tenderized rib eye

Journal of Food Protection, Number 12, December 2015

Alexandra Calle, Anna C.S. Porto-Fett, Bradley A. Shoyer, John B. Luchansky, and Harshavardhan Thippareddi

Can labels of tenderized beef prevent E. coli illness?

Labels are a lousy information vehicle; but they’re a start.

According the this report from CBS, needle or mechanical tenderizing is where cuts of meat is pierced with needles or sliced with blades to break down collagen and make it taste better. But the meat could make you sick if not cooked properly.

needle.tenderize.crBrian Buckley, who works for the Institute of Culinary Education, said the process drives surface contaminants, including potentially lethal E. coli, deeper into the meat so cooking is less likely to kill them.

“If you don’t cook the meat thoroughly to 160 degrees all the way through, you could expose people who east more medium to medium rare to E. coli,” he explained.

The problem is there’s no way to know if the meat you’re buying is tenderized. There are no labels to alert consumers.

Between 2000 and 2009 there were five documented outbreaks of E. coli linked to mechanically tenderized beef, leaving 174 people sick, and one dead.

Starting in 2016, tenderized beef in the U.S. will have to be labeled as such, along with cooking instructions. Labels are already required in Canada.

About 25 percent of beef sold in stores is tenderized.

Eating mechanically tenderized beef could make you sick

Before you bite into your next steak, consider this unappetizing fact: It may have been punctured all over before it made its way to your plate, contaminating the inside of the meat with bacteria that can make you sick.

needle.tenderize.crAs the name suggests, mechanically tenderized beef has been put through a machine that breaks up the muscle fiber and tough connective tissue with blades or needles. This promotional video for the Jaccard Model H Commercial Meat Tenderizer shows just what that looks like (below).

About a quarter of beef sold in the U.S. has been treated this way. The restaurant industry is one of the largest purchasers of mechanically tenderized beef because the process makes cheaper cuts of beef more palatable and therefore more marketable. Moderately priced cuts – such as sirloin tip, eye of round, inside round and outside round – are more likely to have been mechanically tenderized, according to the beef industry.

After an E. coli outbreak in 2012 prompted the largest meat recall in Canada’s history, the country instituted mandatory labeling of all mechanically tenderized beef that includes safe cooking instructions. In the U.S., Costco started voluntarily labeling such cuts as “blade tenderized” after meat sold in its Canadian stores was implicated in that outbreak.

After years of pressure by consumer groups, the U.S. now is poised to require labeling of mechanically tenderized beef, too. That’s over the objections of the meat industry. But the new rules still might take years to take effect.

Why wait for government? Mechanically tenderized meat labels delayed in US until at least 2018

The best food providers don’t wait for – or hide behind — government.

That’s why Costco already labels meat that is mechanically or needle tenderized.

needle.tenderize.crOther retailers should do the same.

For those waiting for government, a labeling rule which would require packages to provide cooking instructions for the mechanically tenderized meat, had to be finalized by Dec. 31 in order for it to take effect before 2018 under separate requirements of the U.S. Department of Agriculture’s Food Safety and Inspection Service.

Philip Brasher writes in Agri-Pulse that FSIS first proposed the labeling for mechanically tenderized meat in June 2013 out of concern that consumers aren’t cooking the meat properly to eliminate pathogens. The meat is tenderized with knives and needles that can drive bacteria inside the product.

However, the meat industry strongly opposes the labeling requirement and USDA officials did not send the final rule to the White House Office of Management and Budget for review until Nov. 21. The regulation remains pending at OMB. Under FSIS labeling regulations, the labeling rule could have taken effect as soon as 2016 only if it had been cleared by OMB and approved by USDA by Dec. 31.

The meat industry has argued that the meat doesn’t pose a significant risk and that the special cooking instructions aren’t warranted. In comments filed with FSIS in October 2013, the American Meat Institute said that antimicrobial measures instituted by processors assure that the meat is safe.

The Costco label says the meat should be cooked to an internal temperature of 160 degrees Fahrenheit. Corbo said the final FSIS rule is likely to offer consumers an option to the 160-degree minimum: Cook the meat to 145 degrees and let it stand for least three minutes. The meat will continue to cook internally for the three minutes even though it is no longer on the heat source. 

US health groups want mechanically tenderized meat label rule finalized

Food safety types are pressuring the Obama administration to finalize a rule before the year ends that will require meat packers to label beef that is mechanically tenderized.

needle.tenderize.crThe Center for Foodborne Illness (CFI) Research & Prevention said if the U.S. Department of Agriculture labeling rule is not published by Dec. 31, it won’t be implemented until January 2018 due to Food Safety and Inspection Service uniform compliance date requirements for labeling meat and poultry products.

The nonprofit health organization said mechanically tenderizing meat creates a higher risk of bacteria contamination that causes food poisoning. 

Mechanically tenderized products like steaks and roasts are repeatedly pierced by small needles or blades, which the group says increases the risk of pathogens located on the surface of the product being transferred to the interior.

needle.tenderize.beef.HC.feb.14From 2003 to 2013, the Centers for Disease Control and Prevention received reports of five foodborne illnesses attributable to needle- or blade-tenderized beef products prepared in restaurants and consumers’ homes. 

The rules would require the labels to display cooking instructions so consumers have the information they need to properly destroy pathogens.

Canada passed a labeling law in Aug. 2014.

Labels the law for all mechanically tenderized beef in Canada

In a move to cut risk from foodborne E. coli, all mechanically tenderized beef (MTB) sold in Canada from today on must be labelled as such and list instructions on safe cooking.

needle.tenderize.crHealth Minister Rona Ambrose on Thursday announced the new labelling requirements for all uncooked MTB — expanding a rule that’s been in place since July last year for federally licensed beef plants producing steaks and roasts.

The new label must clearly state the beef being sold is “mechanically tenderized,” and must include instructions for safe cooking, stressing the importance of cooking MTB to a minimum internal temperature of 145 F (63 C) and turning over steaks at least twice during cooking.

The Canadian Food Inspection Agency (CFIA) is tasked with verifying retailers’ and packers’ labels meet the new requirements, Health Canada said.

Mechanical tenderization is a common practice for improving beef tenderness and flavour, using needles or blades to break down, penetrate or pierce the meat’s surface and disrupt the muscle fibers, or to inject the meat with a marinade or tenderizer.

mech-tenderized-beef-boeuf-attendris-meca-01-413x280Normally, the risk of E. coli contamination from a rare or undercooked steak, roast or other solid cut of beef is “not a significant concern” since such bacteria would normally be on the surface of the meat and “inactivated” during cooking.

Much like grinding beef, mechanical tenderization can increase the potential for bacteria to transfer from the surface to the centre of the meat.

Unlike ground beef, however, as a Health Canada health risk assessment pointed out last year, it’s “not necessarily apparent by just looking at a mechanically tenderized meat product that it has undergone this process.”

The May 2013 assessment showed “a five-fold increase in risk from MTB products when compared to intact cuts of beef.”

Health Canada noted that in 2012, out of 18 cases of foodborne E. coli O157-related illness from a Canadian outbreak linked to contaminated beef, five cases were considered to be “likely associated with the consumption of beef that had been mechanically tenderized at the retail level.”

The rule covers all solid cuts of MTB, regardless of thickness, which means it will also apply to cubed steaks, “fast fry” or “minute” steaks. It will apply to both pre-packaged and non-pre-packaged products.

MTB that’s packaged on the premises at selection or purchase — such as in a butcher shop or at a clerk-served meat counter — will need to be identified as such before the customer selects a desired cut of beef. An in-store sign would identify a product in a display case as “mechanically tenderized,” for example.

In those cases, once meat has been packaged to give to the customer, the product must carry both the mandatory “mechanically tenderized” label and safe cooking instructions on the “principal display panel.”

Metal tip found in Calgary boy’s burger may be meat tenderizing needle: expert

Needle or mechanically tenderized beef can introduce shiga-toxin producing E. coli like O157 into the center of a steak, rendering it not safe if undercooked, but what about the actual needle?

needle.tenderize.crJames Deane, who is six, was eating a hamburger made from meat purchased from Costco on Wednesday night in Calgary when he bit into a piece of metal which looks like the tip of a needle.

Domenic Pedulla, president of Canadian Food Safety Group, says meat is injected with brine or flavouring a lot of times because they’re using a lower quality or tough cut.

James’ father, Mike Deane, contacted Costco and the Canadian Food Inspection Agency after finding the needle.

Costco confirms the meat was purchased at its south Calgary store, and has started an investigation with the supplier, JBS Food Canada, Inc., which has a plant in Brooks, Alta.

JBS says it is aware of the allegations and is co-operating with the investigation.

Pedulla says processors run their products through metal detectors to avoid such situations.

He says foreign objects in food are becoming less common “because processors are tightening up their procedures and the technology is getting better.”

Needle tenderized? No problemo; AMI asks for withdrawal of beef rule

The American Meat Institute has submitted comments recommending that USDA’s Food Safety and Inspection Service (FSIS) withdraw its proposed rule requiring labeling on needle- or blade-tenderized beef products.

“The existing labeling scheme for products that have been needle injected or blade tenderized, with appropriate qualifying statements or tenderizingPageother label information, provides open and transparent information based on recognizable common and usual product names and should be kept,” the comments say.

The comments highlight, among other things, the safety record of mechanically tenderized (MT) products, as well the proposed rule’s potential to confuse consumers by changing the product name to include the mechanically tenderized distinction. 

AMI’s full comments are available at