This editorial was originally published Sept. 25 on The Lunch Tray.

Will chicken processed in China be included in school lunches? No. The USDA’s Agricultural Marketing Service ensures that products included in [sic] school lunch program are produced, raised, and processed only in the United States, its territories or possessions, the Commonwealth of Puerto Rico, or the Trust Territories of the Pacific Islands.

To parents with little knowledge of how school food programs operate (i.e., the vast majority), this statement from FSIS would seem to settle the question — and provide solid reassurance for those concerned about Chinese-processed chicken being fed to their kids at school. But the FSIS statement is in fact quite misleading. It is true that school districts participating in the National School Lunch Program (the “NSLP,” which also includes school breakfast and after-school snack programs) receive agricultural commodities from the USDA’s Agricultural Marketing Service, and it is true that these products are domestic.  But the USDA is well aware that school districts also procure significant portions of their school food from private vendors, and this method of school food sourcing is entirely omitted from the answer above — despite the blanket “no” response. So the pertinent question is: Can private vendors sell Chinese-processed chicken to schools? I emailed the FSIS and a USDA spokesperson agreed that “schools also make their own purchases” of school food, but she went on to note that such purchases are governed by a “Buy American” regulation which

requires participating schools to purchase domestically grown and processed foods, to the maximum extent practicable. A domestic . . . product is defined to be “. . .  a food product that is processed in the United States substantially using agricultural commodities that are produced in the United States.”

This regulation sounds like a de facto ban on Chinese-processed chicken.  But at the end of her email, the spokesperson also disclosed that under the “Buy American” rule:

[p]roducts that are processed in the United States and comprised of at least 51 percent domestic ingredients are considered domestic.

I have since expressly confirmed with the USDA that this definition of “domestic” would indeed allow Chinese-processed chicken into the school lunch program.  Here’s how:  if, for example, a manufacturer of frozen chicken egg rolls fully assembles the egg rolls in this country, but sources the cooked chicken in the egg rolls from a Chinese processor, the egg rolls are considered “domestic” so long as the Chinese-processed chicken doesn’t comprise more than 49% of the total product. School districts could buy these egg rolls without violating the “Buy American” rule and the egg rolls would not have to bear any country-of-origin labeling to disclose the location of the poultry processing.  And this scenario could easily apply to any chicken-based entree supplied to schools, such as chicken soup, frozen chicken burritos, chicken chili, chicken-stuffed ravioli, and more. I also learned that there’s a second exception to the “Buy American” rule.  In the unlikely event that the economics of chicken processing shift, such that it becomes reliably cheaper for schools to source items like patties and nuggets using Chinese-processed chicken over domestically processed chicken, then schools can freely buy such products, regardless of ingredient percentages. So the bottom line is this: despite the blanket reassurance to the contrary on FSIS’s website, it is entirely possible that Chinese-processed chicken will be used in school meals. It’s also worth noting that, according to the USDA spokesperson, there is no analogous “Buy American” restriction on schools providing evening meals to students, nor does it apply to meals served in day care centers, as both of these programs are part of the Child and Adult Care Food Program rather than the NSLP.  (“School supper” programs are increasingly common; by 2015, an estimated 21 million students will be eating dinner at school.)  Accordingly, it appears that any Chinese-processed chicken product, regardless of ingredient percentages, can be used in these meals as well. Whether Chinese-processed chicken presents a serious concern for parents is open for debate.  According to sources interviewed by Politico, few U.S. poultry producers have expressed interest in processing chicken in China at the present time due to logistical constraints.  If that situation changes, however, parents are unlikely to know about it.  Moreover, because no country-of-origin labeling is required on products containing Chinese-processed chicken, only school districts which expressly obligate vendors to use 100% domestically processed chicken will know exactly what they’re serving to kids. In my opinion, though, parents ought to be far more worried about the possible lifting of the export ban on Chinese-raised and -slaughtered raw poultry.  If raw Chinese poultry enters this country and becomes reliably cheaper than domestic poultry, its use in school food could become widespread under the second exception to the “Buy American” rule noted above.  (And, at any rate, raw Chinese poultry could always be used, up to 49%, in manufactured food items regardless of cost.)  Given that some Chinese poultry farmers allegedly used large quantities of illegal drugs in raising chickens sold to KFC, and given the potential vulnerability of young school children eating such chicken, a lifting of the export ban on raw Chinese poultry is a cause for serious concern. In the meantime, is FSIS intentionally misleading the public on this issue?  I can’t know, of course, but I suspect that in the rush to quell concerns about the August 30th announcement, the FSIS simply failed to vet its school food Q & A with the USDA’s Food and Nutrition Service, the branch of the agency overseeing child nutrition programs.  Regardless of motive, however, my own questioning of the agency (which began a full two weeks ago) has clearly brought the inaccuracy to its attention — yet, as of this writing, the original statement remains on its website.  

Well, in point of fact, the undisclosed presence of ammonia-hydroxide-treated bovine connective tissues in 70% of the nation’s ground beef  is hardly a “myth.”  But rather than responding under Twitter’s 140 character constraint, I’d like to address here a few of the main arguments currently being advanced by industry in defense of BLBT.

BLBT Is Nothing But Lean, Nutritious Beef

Meat industry lobbyists maintain that BLBT is nothing more than “lean, nutritious” beef, but it’s well worth noting that two former microbiologists at USDA’s Food Safety Inspection Service – now federal whistleblowers – have vociferously protested the agency’s controversial decision to classify BLBT as “meat.”  In a 2002 email to colleagues, one of these scientists wrote: “I do not consider the stuff to be ground beef, and I consider allowing it in ground beef to be a form of fraudulent labeling.”  That revelation ought to be at least some cause for consumer concern.

BLBT Is Perfectly Safe to Eat

Even BPI acknowledges that the types of slaughterhouse waste used to make BLBT- fatty scraps and bits of connective tissue left over from beef processing – is more susceptible to foodborne pathogens than regular cuts of meat.  These bits and pieces tend to come from the outermost part of the animal and thus are more likely to be contaminated with excrement smeared on the animal’s hide.  According to a Pulitzer Prize-winning 2009 New York Times exposé, federal testing between 2005-2009 found that ground beef containing BLBT was four times more likely to contain salmonella than regular ground meat.

In fairness, BPI has improved its safety protocols and now leads the industry in testing for not just one but the so-called “Big Six” strains of E. coli, and it also vows to hold back any batch testing positive for these pathogens.  But it’s important to remember that there are other deadly foodborne pathogens besides the Big Six.  Last year’s E. coli outbreak in Germany, which left 45 dead and 3,785 sickened, was caused by a previously unknown strain of the bacteria, demonstrating that microbiologists often identify new pathogens only after a deadly outbreak.  And should an outbreak occur, children are more vulnerable than adults to suffering serious harm, or even death.

Using Every Bit of the Cow is “Sustainable”

The meat industry argues that we ought to love pink slime because it “absolutely is the right thing” to use every available scrap on a cow carcass. But we were already honoring the noble ideal of “nose-to-tail” butchering by putting these scraps to use in the past for pet food or rendering into cooking oil.  Was there any reason to shift their use to human consumption, beyond profit motive?  (According to ABC News, BPI has made “hundreds of millions of dollars” on the sale of pink slime; a source quoted in the Times article says BPI’s founder and owner has “amassed a tidy fortune” from it.)

BLBT Helps Feed a Hungry World

BPI and the meat industry answer that last question by arguing that BLBT helps “feed America and the world” by stretching the available supply of beef products.  But if our country is undertaking a wholesale “stretching” of the food supply with ammonia-treated bovine connective tissue, shouldn’t individual consumers have the right to opt out?  Just as some people relish the idea of a beef tongue sandwich and others are repelled at the notion, many consumers want to avoid pink slime for reasons both rational and irrational.  Yet the federal government’s decisions — at BPI’s behest – to classify BLBT as “beef” so that it need not be labeled, and to treat ammonia hydroxide as an undisclosed processing agent, has utterly stripped consumers of the right to know exactly what they are eating and feeding their families.

BLBT Actually Helps America’s School Children

In a new post published on The Daily this morning, BPI spokesman Rich Jochum asserts that the presence of BLBT in school beef actually helps our children because it “1) improves the nutritional profile, 2) increases the safety of the products and 3) meets the budget parameters that allow the school lunch program to feed kids nationwide every day.”

Let me address these notions in a slightly different order.  When BPI argues that use of BLBT “increases the safety of products” it seems to be coming dangerously close to making the claim that by mixing the ammonia-hydroxide-treated substance into regular ground beef, its mere presence reduces pathogens in the rest of the product.  This is precisely how BPI first marketed BLBT when it was introduced in 2001, but, as well detailed in the aforementioned Times exposé, this food safety claim has been thoroughly discredited.

Second, when BPI says use of BLBT increases the nutritional profile of school food, I can only assume that the company is referring to the lower fat content of ground beef mixed with BLBT.  But of course another way of achieving the same result would be to add higher quality lean beef to the mixture, rather than pink slime.  This would of course be more costly, however, which leads to the third defense of pink slime, which is that it reduces school districts’ food costs.

On this
point, BPI and I are in complete agreement.  Use of BLBT shaves three cents a pound off the ground beef that contains it.  But as writer Tom Philpott wryly noted back in 2010:

Three cents off the cost of making a pound of ground beef. Under the severe fiscal austerity that school cafeteria administrators operate under, pinching those three pennies is a rational decision, even if it means subjecting children to ammonia-ridden slime that may contain pathogens.

The bottom line for me is this:  three leading fast food giants – McDonald’s, Burger King and Taco Bell – all recently discontinued their use of BLBT.  Though they haven’t said so explicitly, it’s likely that growing consumer concern over pink slime led to their change in practice.  But while fast food customers can vote with their dollars, our nation’s school children, particularly those whose lower economic status forces them to rely on federal school meals, lack any voice in the matter.  They must passively consume whatever the federal government sees fit to feed them.

I simply do not  believe that use of BLBT is doing our best by our nation’s children.

And, so far, apparently, over 175,000 people agree with me.

————————–

“My Response to Beef Industry Defenses of ‘Pink Slime’ “ was originally posted March 12, 2012 on Bettina Elias Siegel’s “The Lunch Tray: kids and food, in school and out” website. Reposted with permission.