FSIS Directive 7235.1 Mandatory Safe Handling Statements on Labeling of Raw and Partially Cooked Meat and Poultry Products

ATTACHMENT 2

QUESTIONS AND ANSWERS ON SAFE HANDLING STATEMENTS (cont.)

C. EXPORT/IMPORT PRODUCTS

1. Question: Will products for "export only" require safe
          handling information?

          Answer: No. "Export only" products must conform to our
          regulations, except as provided for in Sections 317.7 and
          381.128 of the MPI Regulations. Those regulations allow
          deviations that are not in conflict with the laws of the
          country to which the product is intended for export. Since
          we are not aware of any country that required safe handling
          instructions prior to the final regulation, we do
          not believe safe handling instructions are required on
          products for export only. In addition, procedures outlined
          in FSIS Directive 9020.1, including obtaining a letter from
          the foreign purchaser and the foreign government, will not
          be necessary, unless some other deviation from labeling
          requirements is desired.

2. Question: If labels are printed in dual language, can the
          safe handling instructions be in the foreign language only?

          Answer: If the products are not for export only, the safe
          handling instructions must appear in English. Instructions
          in a foreign language may be given in addition to the ones
          in English.

D. LABEL SETUP

1. Question: Do the messages need to appear in a tabular
          fashion as shown in the exhibit in the preamble to the
          regulation?

          Answer: No. The order of the information needs to remain
          the same but the statements could be presented in a more
          linear fashion, a more vertical fashion, or a more
          horizontal fashion than shown in the exhibit in the
          preamble.

2. Question: Can the symbols be placed on the right of the
          safe handling messages instead of the left?

          Answer: Yes. The regulation does not specify that symbols
          must go on the left.

3. Question: Can the safe handling instructions be printed on
          an angle to other accompanying information?

          Answer: Yes.

4. Question: Can safe handling instructions be applied by a
          rubber stamp instead of a pressure sensitive label?

          Answer: Yes, as long as all stipulations of the regulation
          are met; e.g., type size, one color print on a contrasting
          background, etc.

E. SYMBOLS

1. Question: Do symbols have to be included with the safe
          handling instructions?

          Answer: Yes. The regulation requires symbols.

2. Question: Do symbols have to be an exact representation of
          those shown in the exhibit in the preamble to the
          regulation?

          Answer: No. For example, the regulation requires a graphic
          illustration of a refrigerator to accompany the "Keep
          refrigerated..." message. The graphic illustration does not
          have to be an exact duplication of what is shown in the
          exhibit in the preamble; however, it must be easily
          recognizable as a refrigerator. Similar requirements would
          apply to the other symbols.

F. SIZE REQUIREMENTS

1. Question: Is the 1/16-inch minimum type size for the
          capital letters or small letters?

          Answer: When upper and lower case or all lower case letters
          are used, it is the lower case letter "o" or its equivalent
          that shall meet the 1/16-inch minimum type size.

2. Question: Can the heading "Safe Handling Instructions" be
          bolder but only 1/16th inch?

          Answer: No. The heading must be larger than 1/16th inch.

G. LOCATION ON LABEL

1. Question: Can safe handling instructions be placed on hang
          tags on the outer labeling of products?

          Answer: Yes, hang tags will be considered an extension of
          the label and may be used for safe handling instructions.

2. Question: Can a pressure-sensitive sticker be placed over
          nonmandatory information on a temporary basis?

          Answer: Yes, stickers placed on nonmandatory information
          may be used for 6 months beyond the effective date of the
          final regulation. Such labels would continue to be
          approved under generic label approval.

3. Question: Can a pressure-sensitive label cover nutrition
          information until July 6, 1994, when nutrition information
          is mandatory?

          Answer: Yes, as long as it fully covers the nutrition
          information and no nutrition claims appear on the labeling
          that would require the nutrition information.

H. INTERIM DEVIATIONS

1. Question: Since this is the second final rule on safe
          handling information, are companies permitted to use the
          labels that were based on the August 16, 1993, interim rule
          and the first final rule published on October 12, 1993?

          Answer: Yes, labels complying with the interim rule may be
          used 1 year beyond May 27, 1994, the effective date of the
          second final rule. The label required under the second
          final rule remains unchanged from the label required under
          the first final rule. Such labels will continue to be
          approved under generic label approval.

2. Question: Do all raw products need safe handling
          instructions on the label by May 27, 1994?

          Answer: No. All comminuted or ground products must have
          the information on the label by May 27, 1994. For all
          other products, the information must be on the label by
          July 6, 1994.
Prior segment of
FSIS Directive 7235.1 (part 3)