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Issue Number: Council III 023


Amend Food Code - Consistency with FSIS Cooking Temperatures

Issue you would like the Conference to consider

The Food Safety Inspection Service (FSIS) is proposing that the FDA 2013 Food Code § 3-401.11 Cooking be reorganized to identify which instructions apply to intact and non-intact meat and poultry products, revise the minimum time and temperatures for cooking meat and poultry products to reflect FSIS cooking guidance, and refer to FSIS cooking guidelines for additional appropriate time and temperature combinations. These changes would harmonize the Food Code with FSIS cooking guidelines and provide more flexibility for retail and food service institutions to use other time and temperature combinations to cook meat and poultry products.

Making the Food Code instructions consistent with FSIS regulatory framework and cooking guidance will decrease confusion and help ensure that the products are cooked properly to destroy pathogens that could cause foodborne illness.

FSIS also notes that it has proposed new requirements for labeling beef products that have been mechanically tenderized so that consumers and retailers are aware of which products are mechanically tenderized and so that validated cooking instructions will be included on the label. The proposed Food Code changes would be consistent with the proposed rule.

Public Health Significance

FDA 2013 Food Code section 3-401.11(A)(1) applies to fish and meat, including game animals, and specifies that the products can be cooked to 63°C (145°F) for 15 seconds. This time and temperature combination is only appropriate for intact portion cuts of meat. Although there are exceptions in 3-401.11(A)(2) for non intact products, it is not clear that the instruction applies only to intact products. As most meat products are considered non-intact as a result of mechanical tenderization or chemical injection, clarification is needed indicating that the cooking temperature specified in this section is for intact portion cuts only.

Section 3-401.11(A)(2) applies to mechanically tenderized meats and specifies that they should be cooked at 68°C (155°F) for 15 seconds. However, according to the FSIS Guidance on Safe Cooking of Non-Intact Meat Chops, Roasts, and Steaks, non-intact products should be held at 68°C (155°F) for 17 seconds. Other time and temperature combinations in the table would also provide a 5-log reduction of Salmonella in these products. Therefore, FSIS and FDA recommend that time the product is held is increased to 17 seconds to be consistent with the table, and the other time and temperature combinations from the table in the FSIS guidance are provided.

Section 3-401.11(A)(3) applies to poultry products and recommends that they are cooked at 74°C (165°F) or above for 15 seconds. According to the FSIS guidance in the Time-Temperature Tables for Cooking RTE Poultry Products, poultry products can be cooked to 74°C (165°F) instantaneous to achieve a 7-log reduction of Salmonella. Therefore, FSIS is recommending deleting the 15 second dwell time from the minimum criteria specified in that subparagraph. This change is also consistent with CFP Issue #2002-I-33, which recommended that USDA and FDA work together to establish instantaneous cooking temperatures for animal products that have minimum dwell time of 15 seconds. In addition, FSIS and FDA are recommending that retailers have the option of cooking poultry products using the other time and temperature combinations in the FSIS poultry tables.

Section 3-401.11(B) applies to roast beef, corned beef and other products and indicates that they should be cooked using the time and temperature combinations in the table. These time and temperature combinations are from FSIS Appendix A and achieve a 6.5-log reduction of Salmonella, however only some of the time and temperature options have been provided. FSIS and FDA recommend that all of the time temperature options from Appendix A are provided.


FSIS Appendix A Compliance Guidelines for Meeting Lethality Performance Standards for Certain Meat and Poultry Products, 1999. Found at:

FSIS Time-Temperature Tables for Cooking Ready-to-Eat Poultry Products, 2005. Found at:

FSIS Guidance on Safe Cooking of Non-Intact Meat Chops, Roasts, and Steaks, 2009. Found at:

Recommended Solution: The Conference recommends...

that a letter be sent to FDA recommending that the 2013 Food Code, Section 3-401.11 Cooking, be amended as follows:

1) Reorganize the section to identify which instructions apply to intact meat and poultry products and non-intact meat and poultry products;

2) Revise the minimum time and temperature requirements for mechanically tenderized meat, poultry, and roast beef to reflect USDA Food Safety Inspection Services (FSIS) regulations and cooking guidance for these products; and

3) Refer to appropriate FSIS Guidance Documents for additional appropriate time and temperature combinations not currently specified in the Food Code.

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