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How a calzone swayed me to favor a single food safety agency 

  • foodsafetystrategy
  • 6 minutes ago
  • 1 min read

I understand the need to draw what’s ostensibly an arbitrary line between foods covered by USDA FSIS and those under FDA authority. That the agencies have settled on the 2% cooked meat/ 3% raw meat as the line of demarcation is what it is. 


But here’s what threw me: closed versus open faced sandwiches. It’s always seemed a little silly that FDA regulates closed face and FSIS has authority over open faced. Again, it is what it is. But the question I posed related to how to define a closed face “sandwich” when the item is a wrap, calzone, quesadilla, etc. I realize regulations cannot account for every single situation, but should be constructed to provide reasonable flexibility and obvious interpretation to account for new food formats. Maybe wraps weren’t a thing when the dividing line was established and the open and closed faced terms were used.  


So intuitively, is a wrap or calzone closer to a closed faced or open faced sandwich? It’s not just closed, it’s enclosed. But alas, FDA has saif (via my TAN response) that it does NOT meet the definition of a closed face sandwich. This would make it regulated by FSIS. 

If you are thinking this is one of the stupidest and most ridiculous things you’ve heard, I’m right there with you. Single food safety agency, anyone? 

 
 
 

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