Tag Archives: Tenderized

USDA: Everything you ever wanted to know about labeling needle- or blade–tenderized beef

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Compliance Documents

Q1. Where can I find information on the new “mechanically tenderized beef products regulation per 9 CFR 317.2(e)(3)?

Information on “mechanically tenderized beef products” is available from the following locations:

Labeling Issues

Q2. Under this final rule, will the product need to be labeled with the specific method of mechanical tenderization used to prepare the product?

tenderizedmeat2_custom-949f4ddbfc4f2cb411923f9296e69966fe69d995-s1100-c85No, the label need not include the specific type of mechanical tenderization used. To provide flexibility, FSIS is allowing the phrase ‘‘mechanically tenderized’’ to be used as the descriptive designation on any type of mechanically tenderized product. In addition, in lieu of “mechanically tenderized,” such product may be labeled as ‘‘needle tenderized’’ or ‘‘blade tenderized,’’ as applicable.

Q3. Can “needle injected” be used as the descriptive designation on the labels of raw or partially cooked beef products that have been mechanically tenderized?

No, needle injected may not be used as the descriptive designation. The terms “needle tenderized” or “mechanically tenderized” must be used as the descriptive designation for needle tenderized raw or partially cooked beef products and the terms “mechanically tenderized” or “blade tenderized” must be used as the descriptive designation for raw or partially cooked blade tenderized beef products.

Q4. Are the descriptive designations “mechanically tenderized,” “blade tenderized,” or “needle tenderized” only required on raw or partially cooked beef products?

Yes, unless the product is destined to be fully cooked or to receive another full lethality

treatment at an official establishment, such product must be labeled accordingly.

Q5. Do the new labeling requirements apply to mechanically tenderized pork, lamb, or goat products?

No. The rule applies only to raw or partially cooked beef products that have been mechanically tenderized.

Q6. Can establishments put both mechanically tenderized beef products and non- mechanically tenderized beef products in the same immediate container and label it with the descriptive designation “mechanically tenderized?”

No. To label product as “mechanically tenderized” when it was not would be false and misleading.

needle-tenderize-crQ7. If we sell mechanically tenderized raw or partially cooked beef or veal products in protective coverings, must the protective coverings meet the mechanical tenderization labeling requirements when the immediate container of this product is labeled “For Institutional Use Only?”

No. Under 9 CFR 317.1(a)(1), protective coverings should not bear any mandatory labeling information.” In this case, the immediate container, which also serves as the shipping container, is required to be labeled with the descriptive designation and bear validated cooking instructions and all other applicable labeling features.

Q8. Is beef cubed steak is subject to the new labeling requirements?

No, this regulation will not apply to raw or partially cooked beef products that have been cubed. The regulation is specific to needle and blade tenderized beef products. FSIS stated in the final rule:

The descriptive designation will only apply to raw or partially cooked beef products that have been needle tenderized or blade-tenderized, including beef products injected with marinade or solution. Other tenderization methods, such as pounding and cubing, change the appearance of the product, putting consumers on notice that the product is not intact. Moreover, most establishments already label cubed products as such. (80 FR 28157)

Q9. Must the labels for raw or partially cooked mechanically tenderized beef products be submitted to the FSIS Labeling and Program Delivery Staff (LPDS) for approval?

No. The descriptive designations, “mechanically tenderized,” “blade tenderized,” and “needle tenderized” are not considered special statements or claims under 9 CFR 412.1(c). Therefore, as stated in the final rule, simply adding the descriptive designation and validated cooking instructions to a label would not require LPDS approval, given the label is otherwise in accordance with FSIS’s regulations.

Q10. Do the new labeling requirements apply to raw or partially cooked mechanically tenderized beef products that are produced at establishments that use a validated intervention during the production of such products?

Yes, the new labeling requirements would apply to products treated with a validated antimicrobial intervention, unless the establishment applies a lethality treatment that achieves a 5-log reduction in pathogens. Mechanically tenderized beef product treated at an official establishment with an intervention or process, including HPP, that has been validated to achieve at least a 5-log reduction for Salmonella and Shiga Toxin-producing E. coli (STEC) organisms (including E. coli 0157:H7) would not be subject to the requirements in this final rule because it has received a full lethality treatment. (See 80 FR 28153)

Q11. Do the new labeling requirements apply to mechanically tenderized beef products labeled or prepared at retail stores?

Yes, the new labeling requirements would apply to raw or partially cooked mechanically tenderized beef products produced, packaged, and labeled at a retail store.

Cooking Instructions

Q12. Is there compliance guidance available on validating cooking instructions for mechanically tenderized beef products?

Yes, at:

FSIS Compliance Guideline for Validating Cooking Instructions for Mechanically Tenderized Beef Products

Q13. Where can I find scientific studies on validated cooking instructions?

Attachment 1 of the above FSIS Compliance Guideline for Validating Cooking Instructions for Mechanically Tenderized Beef Products contains a summary of published scientific support for cooking instructions.

Q14. Do the new labeling requirements apply to raw or partially cooked mechanically tenderized beef products that are too thin to practically measure their internal temperature using a food thermometer?

No, the new labeling requirements do not apply to raw or partially cooked mechanically tenderized (including through injection with a solution) beef products that are too thin to measure their internal temperature using a food thermometer, such as beef bacon or carne asada. FSIS does not intend to enforce the requirements for these products because they are customarily prepared in a manner that is sufficient to destroy pathogenic bacteria.

Note that the thickness of many food thermometers used by consumers is approximately 1/8,” making it difficult to measure the end product temperature of products 1/8” thick or less through use of a thermometer.

Q15. Where on the label of raw or partially cooked mechanically tenderized beef products can the validated cooking instructions appear?

Validated cooking instructions must appear on the immediate containers of all raw or partially cooked mechanically tenderized beef products destined for household consumers, hotels, restaurants, or similar institutions. These instructions can appear anywhere on the product label.

Mechanically Tenderized Beef With Solutions

Q16. Must the label of a raw or partially cooked mechanically tenderized beef product that contains added solution also declare the percentage of added solution?

Yes. However, there are different options for declaring the total amount of solution added. See 9 CFR 317.2(e)(2).

Q17. Do the new labeling requirements apply to raw or partially cooked beef products that have been marinated in a tumbler or vacuum tumbled?

The rule only applies to raw or partially cooked beef products that have been mechanically tenderized by needle or blade. This rule does not apply to other processes, such as tumbling or vacuum tumbling, unless the product is also mechanically tenderized by needle or blade.

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Needle or blade tenderized steak continues to raise safety concerns

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It’s an important day for food safety types because new research shows E. coli O157:H7 can enter beef cuts like steak during mechanical or blade or needle tenderization, as it’s called.

The idea is that small needles are inserted into steak to inject tenderizers. All hamburger should be cooked to a thermometer-verified 160F because it’s all ground up – the outside, which can be laden with poop, is on the inside. With steaks and roasts, the thought has been that searing on the outside will take care of any poop bugs like E. coli and the inside is clean. But what if needles pushed the E. coli on the outside of the steak to the inside?

Previous work has shown similar results, and the new research in the Journal of Food Safety confirms that E. coli O157:H7 can enter the interior of beef cuts like steaks during the tenderization process. The new work does not assess whether cooking on a grill can kill off the internalized bacteria but does refocus attention on a lingering food safety issue, almost one year after an E. coli O157:H7 outbreak in needle tenderized beef sickened at least 21 people in 16 states.

Luchansky et al. wrote in the July 2009 JFP that based on inoculation studies, cooking on a commercial gas grill is effective at eliminating relatively low levels of the pathogen that may be distributed throughout a blade-tenderized steak.

Quantitative analysis of vertical translocation and lateral cross-contamination of Escherichia coli O157:H7 during mechanical tenderization of beef
30.nov.10
Journal of Food Safety
Lihan Huang, Shiowshuh Sheen
http://onlinelibrary.wiley.com/doi/10.1111/j.1745-4565.2010.00273.x/abstract
ABSTRACT
Quantitative vertical translocation and lateral cross-contamination of Escherichia coli O157:H7 during mechanical tenderization of beef meat were investigated using a restaurant-style meat tenderizer, which was first used to tenderize a surface-inoculated sample, and then an additional four uninoculated samples. It was observed that the vertically translocated bacteria (in log10 cfu/g) was directly proportional to the logarithm of the tenderization depth, with an average translocation coefficient of 3.14 ± 0.66 log10 cfu/g per log10 mm of depth. For lateral cross-contamination, the bacterial counts recovered from the top layers of the first four pieces of meat decreased by approximately 0.5 log10 cfu/g after each tenderization. There was no decrease in the bacterial counts recovered from the top layers after the 4th tenderization. More tenderization studies were needed to quantitatively analyze the trend of lateral cross-contamination. However, it is evident that both vertical translocation and lateral cross-contamination can occur during mechanical tenderization of meat.
PRACTICAL APPLICATIONS
Foodborne illnesses caused by consumption of undercooked non-intact beef meats contaminated with Escherichia coli O157:H7 are an emerging public food safety concern as evidenced by a major outbreak recently. This study investigated both vertical translocation and lateral cross-contamination of E. coli O157:H7 during mechanical tenderization of beef. The results from this work can aid quantitative assessment of risks caused by non-intact beef meats.

Has that Christmas steak been needle tenderized? Does that mean a higher internal temperature is required to kill E. coli O157:H7? People sick in 6 states

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There’s nothing like three inches of freshly fallen Christmas morning snow to make me think … barbeque.

Before firing up the grill in a couple of hours, I now have to consider whether the T-bones I bought at Dillons were needle or blade tenderized, or not. The idea is that small needles are inserted into steak to inject tenderizers. All hamburger should be cooked to a thermometer-verified 160F because it’s all ground up – the outside, which can be laden with poop, is on the inside. With steaks, the thought has been that searing on the outside will take care of any poop bugs like E. coli and the inside is clean. But what if needles pushed the E. coli on the outside of the steak to the inside?

There have been 6-7 such outbreaks in the past, but only a couple appear to be linked to the consumer issue of – how do I cook this Christmas steak?

The U.S. Department of Agriculture issued a press release last night warning that people in Colorado, Iowa, Kansas, Michigan, South Dakota and Washington were sick with E. coli O157:H7 and the common vehicle appeared to be “non-intact steaks (blade tenderized prior to further processing).” Why the U.S. Centers for Disease Control has not commented on the outbreak remains a mystery.

Minnesota lawyer Fred Pritzker was the first to publicly identify the potential outbreak linked to blade-tenderized steaks a week ago, on Dec. 18/09.

He also explained that in November of 1997, the Meat and Poultry Subcommittee of the National Advisory Committee on Microbiological Criteria for Foods concluded that standard beef steaks have a low probability of  E. coli O157:H7 migrating from the surface to the interior of the beef muscle.

Because of this, the cooking advice was to cook the steak at least enough to effect a cooked color change on all surfaces. Hence, it was officially safe to eat a steak rare.

Except color is a lousy indicator. How about some temperature recommendation, oh holy micro committee?

But the committee limited this advice to “intact beef steak” and then defined the term as follows: “A cut of whole muscle that has not been injected, mechanically tenderized or reconstructed.” Under the Food and Drug Administration’s 1977 food code, “injected” meant “manipulating a meat so that infectious or toxigenic microorganisms may be introduced from its surface to its interior through tenderizing with deep penetration or injecting the meat such as with juices.”

Based on these definitions, USDA’s Food Safety and Information Service FSIS proclaimed in early 1999 that the agency believes there should be a distinction between intact cuts of muscle and non-intact products, including those that have been tenderized and injected.

That was 1999. I don’t see any such intact or non-intact label when I go to the grocery store. Restaurants remain a faith-based food safety institution. And the issue has rarely risen to the level of public discussion.

The issue is not new, but may be new in terms of public discussion. Echeverry et al. wrote in the Aug. 2009 issue of the Journal of Food Protection that,

After three different outbreaks were linked to the consumption of nonintact meat products contaminated with Escherichia coli O157:H7, the U.S. Department of Agriculture, Food Safety and Inspection Service published notice requiring establishments producing mechanically tenderized and moisture-enhanced beef products to reassess their respective hazard analysis and critical control point system, due to potential risk to the consumers.

The researchers found that application of antimicrobials to the steaks prior to packaging and shipment on day 0 was effective in reducing internalization of both pathogens in nonintact beef products stored for both 14 and 21 days.

Luchansky et al. wrote in the July 2009 JFP that based on inoculation studies, cooking on a commercial gas grill is effective at eliminating relatively low levels of the pathogen that may be distributed throughout a blade-tenderized steak.

I hope they’re right. But there’s obviously something going on in the current outbreak.

Oh, and I know it was Christmas Eve and everything, but the USDA press release contained the tired and sometimes true advice for handling ground beef – hamburger – which has nothing to do with intact or non-intact steaks. I won’t be asking Karen anything (ask Karen is the supposed on-line help thingy that USDA keeps flogging).

There are many more details that will emerge as the story evolves, and people more knowledgeable than I — and others — pop up to speak. I’m sorry if you’re spending Christmas barfing because the food safety community did a lousy job providing information about risks that are out there. I’m still enjoying Christmas morning with the family. That’s Sorenne looking out our living room window this morning.