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Petition would allow transportation of hides; remove ‘inedible’ from definition




USDA’s   Food Safety and Inspection Service (FSIS) has received a petition from  the Robert M. Kerr Food and Agricultural Products Center (FAPC) on the campus of Oklahoma State University. The petition requests that FSIS amend 9 CFR 325.19(e) to remove “hides” from the articles considered naturally inedible by humans that are not subject to the federal meat inspection transportation requirements.
As stated in the OSU  petition, FAPC has been working with an entrepreneur to develop a process for an edible beef hide product using the hides from on-site beef harvest as the raw material. The petition states that the current regulation that prohibit the transportation of inedible products for further processing prevents full use of the hide. According to the petition, removing hides from 9 CFR 325.19(e) is needed to remove a barrier to product development.



According to FSIS,  the  request is being considered as a petition for rulemaking under the Administrative Procedure Act (5 U.S.C. 553(e)), USDA’s administrative regulations (7 CFR 1.28), and FSIS’ regulations on petitions (9 CFR part 392).
The OSU  petition has been referred to the Office of Policy and Program Development for review and has been assigned petition number 21-03. As provided in 9 CFR 392.6, the  petition ix  available to the public in the FSIS docket room and will be posted on the FSIS Website.



The Robert M. Kerr Food and Agricultural Products Center (FAPC) on the campus of Oklahoma State University  is specifically requesting the amendment of current policy prohibiting beef hide transportation because of inedible status.
Current Agency policy states under 9 CFR 325.19 “Provisions inapplicable to specimens for laboratory examination, etc., or to naturally inedible articles. The provisions of this part do not apply: (a)…(e) To articles that are naturally inedible by humans, such as hoofs, horns, and hides in their natural state.”
FAPC operates UDSA establishment #526 for the purposes of educating students about animal harvest and fabrication, as well as assisting entrepreneurs in the food industry with establishing value added products.
Since 2019, FAPC has been working with an entrepreneur to develop a process for an edible beef hide product using the hides from on- site beef harvest as the raw material. The next step for this entrepreneur is to obtain a USDA inspected establishment of their own to process the hides, and therefore we are submitting a protocol for future approval to transport the hides between establishments.



Working within the establishment, an approved process and HACCP plan were developed to remove hair, foreign material, and filth from the hides. Processing techniques derived from the client’s cultural experience have been successfully implemented, and the finished product has been marked inspected and passed. The inspection mark has catapulted the reputation and marketability of the hide product. The existence of the product filled a market in the ethnic foods category that is being met by similar, but inferior uninspected products.
Furthermore, OSU research into the current hide market has proven the hide is considered a waste. Processors do not receive monetary compensation for the hide, which amounts to 4.8 percent  of the live animal. In 2015, the AMS estimated a hide to be worth $6.96 for a typical steer. The success of this OSU petition will reduce the number of hides being sent to a landfill and give the slaughter establishment the option to reduce material lost as waste.
The OSU petition says that when the basis of the policy in 9 CFR325.19(e) was originally formed, there did not exist an edible beef hide product market in the United States. The development of this process to utilize a wasted portion of the live animal and fill a strong market demand has created the need for the policy to be amended per this petition’s request.
The definition of inedible product currently includes hides, and recent development of an edible hide product has proven the hide is edible. The current process is approved to take place in the slaughter establishment, however regulations prohibiting the transporting the inedible product for further processing prevents full utilization of the hide.
The OSU request was submitted on Nov. 12 by Andrea Graves, business planning and marketing specialist at the Robert M. Kerr Food and Agricultural Products Center. The FSIS response was filed on Nov. 18.
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