Food Protection Trends - May/June 2018 - 176

controlling temperature before and after processing, and
using proper sanitation. There was room for improvement
or clarification with a few of the retailers. Overall, it can be
concluded that intervention in necessary to ensure adequate
knowledge and safe practices to verify adequate risk management. Since mechanically tenderized and enhanced beef
products have been classified as higher risk compared with
those that remain intact, meat retailers must take additional
steps to reduce risk before the product reaches the consumer.
Beef that is mechanically tenderized or enhanced by
processes such as cubing or vacuum tumbling, or by way
of mallet (pounding), do not fall under the labeling rule,
despite also being considered higher-risk than intact beef
(18). Docket No. FSIS-2008-0017, Descriptive Designation
for Needle- or Blade-Tenderized (Mechanically Tenderized)
Beef Products states that even though vacuum tumbled beef
products are processed in a manner that may introduce
pathogens (if present) below the product's surface, the final
rule will not apply to them (18). Additionally, the rule states
that tenderization methods that change the appearance of
the product, such as pounding (using a mallet) or cubing,
indicate to the consumer that the product is non-intact
(18). It is inferred that if the process changes the appearance
of the meat, then the consumer should assume it should
be handled differently and therefore it does not require
additional labeling (18). These statements assume that the
consumer can always visually tell that raw or partially cooked
beef products have been manipulated in a way that increases
the risks associated with the product and therefore must be
handled in a different way (i.e., cooking non-intact beef to a
higher temperature than intact beef). FSIS concluded that
there was not sufficient data to establish whether the risk
that pathogens may be introduced into product as a result
of vacuum tumbling is similar to that associated with needle
and blade tenderized beef (18). Foster-Bey et al., comparing
blade-tenderized beef and vacuum-tumbled beef, concluded
that regardless of how steaks were manipulated, inoculated
pathogens (STEC-8 cocktail) were translocated into the
deeper tissues of the subprimal, and cooking was effective in
reducing appreciable levels of STEC (6, 19).
Various interpretations exist as to what constitutes a
beef product as mechanically tenderized or enhanced/
marinated, leading to confusion. Cubing or pounding beef,
the most frequent means of mechanically tenderizing beef
at the sample site, is considered "mechanically tenderized"
per the 2013 Model Food Code but does not fall under the
requirements for Docket No. FSIS-2008-0017: Descriptive
Designation for Needle- or Blade-Tenderized (Mechanically
Tenderized) Beef (4, 18). The term "mechanically tenderized"
is defined by the 2013 Model Food Code as manipulating
meat with deep penetration by processes (4). The 2013
Model Food Code specifies that the term "mechanically
tenderized" does not include processes by which solutions
are injected into meat, but Docket No. FSIS-2008-0017

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Food Protection Trends May/June

requires the use of the descriptive designation "mechanically
tenderized," "blade tenderized," or "needle tenderized"
on the labels of raw or partially cooked needle- or bladetenderized beef products, including beef products injected
with a marinade or solution (4, 18). Vacuum-tumbled beef
can incorporate marinade or enhancement solutions as found
at the sample site but is not considered to be mechanically
tenderized by either the 2013 Model Food Code definition
or Docket No. FSIS-2008-0017. The diversified descriptions
of mechanically tenderized and enhanced/marinated at times
conflict with one another and therefore make these types of
products difficult to regulate.
Proper refrigeration temperatures are necessary to reduce
the risk of growth of pathogens, if present. One retailer
reported holding beef intended for mechanical tenderization
at between 44 and 45°F rather than at the refrigeration
temperatures (40°F or below) recommended by the USDA
(17). Although holding beef between 44 and 45°F is not an
infraction of the 2009 Food Code, which North Carolina
employed at the time of the study, this suggests that meat
retailer personnel may not treat mechanically tenderized
meat and enhanced beef differently from intact beef (5).
Proper cleaning and sanitation of equipment used to
tenderize meat is needed to prevent cross-contamination
between batches. Some retailers reported cleaning and
sanitizing after every use, while others did so only 1 or 2
times per day. Improper or infrequent cleaning and sanitation
of equipment used to mechanically tenderize and enhance
beef indicates that extra precaution is not being taken
concerning these high-risk products. Multiple retailers
did not know or did not disclose information about the
refrigeration temperatures at which they kept beef intended
for mechanical tenderization, cleaning and sanitizing
procedures, or the frequency of cleaning and sanitizing
equipment. This suggests that meat retailer personnel may
not be aware of or may not be implementing good practices
regarding refrigeration temperatures and/or cleaning and
sanitation of equipment.
Meat retail establishments examined in this study were
often found within close proximity of each other and were
observed to be niche ethnic markets. Many of the retailers
mechanically tenderizing or enhancing beef products were
identified as markets serving minority races/ethnicities.
This frequently resulted in language barriers between the
interviewers and meat retailer personnel.
Prior to this study, no information was available as to
whether mechanical tenderizing or enhancement of beef
was being performed onsite. Now that the prevalence and
parameters of these processes are better understood, meat
retailer managers and employees can be educated about
food safety practices that could potentially reduce the
risks associated with these types of products. Educational
materials must be developed to serve a larger population
of the public. As culturally unique food handling behaviors

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