Comment from Linda Healey

The proposal rationale in this docket focuses on providing consumers with information to enable them to distinguish between single ingredient cuts of meat and poultry that do not meet a standard and do not contain an added solution and those that do contain a solution. But the language that states it will apply to all meat and poultry products that contain an added solution is un-necessarily broad. IF the focus is indeed to provide consumers clarity on simple cuts of meat and poultry with solutions added, the rule should state that clearly. However, as written, it could be broadly applied to any product at all that contains meat or poultry that has been altered by injection of a functional fluid such as chicken broth. For example, raw breaded stuffed chicken breasts, which are combination products containing several other ingredients in addition to poultry (to which a solution may have been added). Properly labeled, the ingredient declaration of a breaded and pre-browned or seasoned combination poultry or meat product already clearly states the amount of added solution by percentage and lists the solution ingredients in predominance order. The nature of this type of multi-ingredient product would be likely to prompt consumers to look at the ingredient declaration, where they would be fully informed as to the nature and amount of added solution, and no labeling change is necessary. We strongly suggest that the summary wording in the CFR include a qualifier similar to that from Docket FSIS- 2010-0012 from page 17 – clarifying that this new ruling does not apply to either breaded pre-browned chicken parts or combination products such as breaded or seasoned stuffed chicken or meat entrees—because it is unlikely the consumer would be misled.