A product can weigh no more at the point of packaging than it did prior to water-misting.
By Raymond L. Frechette
A seemingly minor but economically significant change was coaxed and wheedled from FSIS last summer.
Surprisingly, it has gone unnoticed, particularly by the segment of the industry that stands to benefit from the change.
Policy Memo 108 B, issued last June, takes a small step toward equalizing the inspection rules between red meat and poultry.
This revised policy allows hamburgers and ground beef patties for the first time to use water-misting as a processing aid prior to freezing.
Policy Memo 108 A, which has been on the books for a number of years, allowed the use of water-misting prior to freezing for "all meat and poultry."
If the misting resulted in an ice glaze, or added to net weight, then it had to be declared on a label.
If, however, a processor could demonstrate that all of the water used to protect the meat or poultry items from dehydration had evaporated prior to packaging, no label statement was needed.
This was a help for most of the meat and poultry industry, producing product with little or no surface dehydration. There are also quality and monetary advantages.
The problem with memo A was that USDA did not interpret "all meat" to include hamburger or ground beef.
New memo issued
After an 18-month battle, Policy Memo 108 B was issued. But the wording of the policy still leaves many doubts about what is allowed, and how the policy works.
One of the terms contributing to this confusion is "ice glaze."
Water-misting results in ice glaze only when there is a visible film of frozen water on product surface after it is packed.
If that happens, a label declaration is required.
And since added water is not allowed by the Regulatory Standard (9 CRF 319.5) in ground beef or hamburger, the name of the product must also change.
Whereas, a chicken patty would become a "chicken patty, ice glazed," a hamburger would become a "beef patty, ice glazed."
The other confusing point concerns weight gain. A product can weigh no more at the point of packaging than it does prior to water-misting.
A label statement
In the case of all other meat, the consequence of weight increase is a label statement such as "protected with water-misting," and discounting the amount of gain from the net weight. That, and a name change to "beef patty," would apply to hamburger and ground beef.
The fact that patties weigh more when water-misted has no bearing on the label.
The point of this exercise is to prevent dehydration and therefore eliminate weight loss in the freezer.
In practice, a processor would not eliminate weight loss, but could reduce it because no process is in perfect control.
USDA is not simply going to take a processor's word that the water-misting is not producing net weight gain, a partial quality control program will be required.
It is not difficult to write a quality control program. But it can be difficult to write one that does not have any unforeseen problems.