Silly / funny regulatory inconsistency or odd audit finding
Just for fun, the recent discussion about mushrooms and their RTE status had me thinking of silly / odd / funny regulatory tangles or strange audit requirements.
For my plant, the oddest is pepperoni rolls. Because of a 1987 legal argument, pepperoni rolls are NOT subject to USDA inspection despite the fact that they're sliced meat and NOT between 2 pieces of bread. Take pepperoni and roll it in a tortilla, USDA. Take pepperoni and roll it in dough, NOT USDA.
But if USDA is concerned with meats and NOT pepperoni rolls, why then does adding CHEESE to a pepperoni roll make it subject once again to USDA?
Ah, politics.
The FDA told me that for allergen purposed egg is only egg if it comes from a chicken!!!
Oh, and if it's turkey or chicken USDA, non amenable species (in this case quail) FDA :roflmao: even though there all "poultry"
Good post, this should be fun!
I enjoy following the journey of eggs. Take a ride with me.
A feedcorn seed crop is monitored by Aphis (USDA) for disease health and their harvest and market is monitored by USDA.
Those seeds are used to plant corn under USDA and state laws, pesticides applied are regulated by EPA, though their residues in the final feed.
The corn is harvested and feed production is inspected and regulated by FDA's center for veterinary medicine.
They're fed to layer chickens, who are watched and monitored by FDA, though USDA APHIS hangs out to monitor disease and requires inspection as well for interstate bound eggs and egg products. The shell eggs are laid.
BTW, if the eggs are imported, USDA will meet them at the border, but FDA will handle any recalls or other issues as long as they stay in the shell.
These shell eggs are graded, so they're inspected by USDA AMS for grading and carry their seal, though of course shell eggs at the supermarket are solely an FDA inspected product.
The shell eggs will end their time with FDA-oh crap! Some of them are broken or misshapen, or otherwise not grade A! Let's process them into egg products then, you know, just crack them and make white/yolk mixtures for foodservice, manfacturers, etc.
FSIS (USDA): Stop right there!
You cracked those eggs, so now they're DEFINITELY a USDA/FSIS product. They regulate all processed egg products, so you have an inspector in your plant, a legend on the product, and you definitely are done swapping agencies.
So I took the eggs and spray-dried them, no confusion, still an egg product and USDA is on it!
So I took more eggs and freeze-dried them. Oh, wait, now it's an FDA product again, even though it's an identical product in composition to the spray dried eggs.......
In fact, if I use processed egg products and make a: dietary food, no bake custard mix, egg nog, acidified salad dressing, noodles, milk egg dips, cake mix, french toast, sandwiches, or cooked omelets, USDA checks out and hands eggs back to FDA.
If I've made any mistakes above.....whatever. To heck with egg laws and the lobbying groups that created that mess.
Could be worse, you could add quota to those eggs!!!