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Association of Food & Drug Officials
 

Resolution Year 2005
Resolution Number 2:
Date Marking of Packaged Sandwiches for Retail Sales

Whereas, informal surveys by a number of states have found little public health rationale for the “use by/sell by” dates placed on packaged sandwiches observed for sale at retail; and

Whereas, there have been a number of recent recalls of packaged sandwiches due to the presence of Listeria monocytogenes; and

Whereas, the same informal surveys have found sandwiches transported without refrigeration and/or being sold out of temperature as those requirements are listed in the FDA Food Code; and

Whereas, questions have been raised as to the relationship between the date marking requirements found in the FDA Food Code and the date marking of manufactured packaged sandwiches; and

Whereas, many sandwich manufacturers have admitted that they have no scientific information to document that the shelf life of their sandwiches extends as far out as 27 days, as noted by the informal survey; and

Whereas, information on the safety of vacuum and MAP packaged sandwiches relative to the shelf life noted in the product labeling many times cannot be verified; therefore

Be It Resolved, that AFDO requests FDA to (a) develop regulatory guidance for specifically evaluating the safety of packaged sandwiches within the shelf life dates used by the manufacturer; (b) develop general guidance for shelf life labeling of other refrigerated foods; (c) provide guidance as to whether or not the shelf life of packaged sandwiches should be based on quality or safety; (d) provide guidance on the safety of vacuum/MAP packaging of sandwiches as it relates to the growth of Listeria monocytogenes; and

Be It Further Resolved, that FDA provide guidance on the scientific rationale between the use by/sell by dates placed on packaged sandwiches by the manufacturer (sometimes extending up to four weeks), and the seven (7) days or less shelf life required for foods produced at retail as mandated under the Food Code.

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