by Gary Jay Kushner
If the Office of Management and Budget ever gives the go-ahead, FSIS will begin a process that should enable the development and marketing of a wider variety of traditional meat products that respond to consumers' demands for lower fat and other forms of more nutritious foods.
The focus of FSIS' efforts will be on the amendment or perhaps elimination of Standards of Identity for numerous products-in some cases removing restrictions on the substitution of alternative protein sources for portions of a product's meat block, and in other cases removing meat and fat minimum content requirements.
At first glance, it might seem anathema to the meat industry to suggest that traditional meat products might include less meat in favor of other ingredients. An understandable perception by meat processors-and even consumers-might logically be that the integrity of these products would be jeopardized by watering them down with non-meat ingredients, reducing the amount of meat they contain.
Of course, some meat processors might believe that they will sell less meat if alternative ingredients are used.
On the other hand, there is little debate that consumers have become increasingly aware of the relationship between diet and health, and they are looking for ways to eat more nutritiously. Consumers' near-universal dilemma, however, is how to do this without fundamentally changing their basic diets.
To the meat industry's benefit, Americans are still basically meat eaters who do not want to abandon the wide and delectable array of products that are available.
An innovative marketer should be looking for ways to satisfy both objectives. The approach that FSIS is considering could well be an important part of the answer.
In particular, FSIS has submitted for OMB approval two rule-making initiatives that would foster a review of the role that food standards play in product development.
The first is a proposed rule that would permit deviations from standards for the production of lower fat alternatives to traditional foods. The second is an advance notice of proposed rule-making that would solicit comments on FSIS' historical reliance on food standards to dictate the labeling and composition of foods generally.
Both should be published soon with OMB's backing given its philosophical objection to food standards as barriers to product innovation.
The proposed rule is expected to follow FSIS' approval of the production of "reduced-fat pepperoni," and issuance of a policy memo that specifically permits deviations from a food standard in order "to reduce the fat content [of the standardized product] to qualify for use of nutrient content claim."
That policy specifically allows for the use of ingredients not otherwise permitted by a standard such that the modified food qualifies for a defined nutrient claim which is included in the product name.
Although the policy memo is limited to modified breakfast sausage, cooked sausage and fermented sausage, the expected proposal will cover virtually all standardized foods.
Safe, suitable ingredients
The FSIS proposal is expected to mirror an existing FDA regulation that permits deviations from its standards, including the addition of safe and suitable ingredients, when a modified food bears a nutrition claim as part of the product name.
These ingredients can only be added to accomplish certain specified technical effects in the modified food, including as a means of ensuring traditional equivalence with the standardized food, to maintain performance characteristics, and as a fat analog.
The advance notice of proposed rule-making will be much broader than the proposed rule; it will broadly solicit comments on the continuing role of food standards and the extent to which they should guide FSIS labeling policy.
It is possible that FSIS would eventually propose specific changes to many of its existing food standards as a result of the advance notice of proposed rule-making, although it may take some time.
Production innovation driven by changing consumer preference has been a mainstay of the meat industry's success. Meat will always be a valued choice for consumers, and their demands for healthier versions of traditional foods will present important new business opportunities.
Companies that plan for the changes in standards that lie ahead and participate constructively in the process will be first in line to take advantage of this growing segment of the market.