Comment from Leland Jacobs

This Rule is not clear enough on the term of a Processed commodity product. Anyone can understand that cooking or smoking a commodity product item would clearly be changing the characteristics of the product and therefore making it a processed item, exempt from the rule. We can also understand that just adding water and some salt, sugar and or sodium phosphate does not really change the character of the commodity product. Where it gets confusing is if we will be able to generically approve the COOL information when the commodity product is marinated, enhanced or injected with tenderizers such as papain, bromelin, and/or ficin, and ingredients such as lemon juice concentrates, chicken broth, dried beef stock, natural flavor, spices.... It seems to many that the reason we would add a tenderizer to a covered commodity product is to change the character of this product (make a tougher muscle tender). As for the other ingredients, they are included in the solutions for the purpose of adding flavor, which also seems to be changing the covered commodity's original flavor. Although these more mild flavors are not as strong as the example of teriyaki flavored pork loins, the line between what is enough flavor or modifications to that covered commodity is very unclear. As every plants starts to do their generic approvals there will be, with no doubt, many different interpretations of what is considered a processed commodity product.