The bologna-maker wanted to call his product "country-brand Lebanon bologna made in Clinton, N.J." and, as a law-abiding American meat manufacturer, he applied to the Department of Agriculture for approval of a new label.
But the label reviewer Ray O. Gordon, a 28-year department veteran, stopped it in its tracks. "Country" bologna can only be made in the USDA's definition of the "country" -- that is, unincorporated aeas. "Country-brand" bologna can be concocted in a town, but the label must say what town. It was on this ground that Gordon reached for his collection of rubber stamps yesterday and came down hard with one saying the equivalent of "rejected."
It seems that only the bologna distributor was located in Clinton, and the manufacturer was 90 miles away in Palmyra, Pa.
One label down, 69 to go for Gordon during a typical workday in the U.S. Department of Agriculture labeling review section.
A former poultry inspector and lab technician for USDA, Gordon is one of seven people who work full time under a supervisor processing the estimated 100,000 applications submitted to USDA each year by companies seeking approval of new labels for meat and poultry products.
But are these labels really necessary?
The federal role in meat labeling dates to 1914 when it was authorized in broad form under the Federal Meat Inspection Act. It was one of the earliest consumer protection laws, designed to protect consumers from dishonest meat packers.
As the industry has gotten more complicated, so has the labeling. Some reformers, like Assistant Secretary Carol Tucker Foreman, would like to make the regulatory process sensible without abandoning it. But a new group of reformers might have a totally different view of what is sensible.
Gordon and his coworkers are proud of the work they do in trying to make it easier for American meatbuyers to figure out what they are paying for. But the level of detail and the centralization of the process illustrates what has happened to one consumer protection idea over 66 years.
The label approval process has changed little in recent years, and Foreman, in charge of food and consumer services, calls the system "archaic."
She is among those supporting a program to decentralize label approval. In a test beginning Dec. 1, the department will allow USDA inspectors in three areas of the country to process labels for products they normally inspect. The experiment which will affect parts of Missouri, Kentucky and the Washington metropolitan area, will be optional for companies. The idea is to allow meat and poultry plants in those areas to decide if they want to submit their label application to the local inspector or send it to the Washington office.
Bud Gordon, supervisor of the label staff in Washington (no relation to staff member Ray Gordon), thinks decentralization is the "greatest thing ever." Having inspectors at the plant handle some of the labels would reduce the workload for the D.C. office, Gordon said.
At present, all label review activity takes place in a comparatively small brick building at 300 12th St. SW, a short walk from the Smithsonian subway stop.
Applications for new labels arrive each morning in the mail and throughout the day by messenger. Sometimes, the company representative will deliver the application and try to get approval on the spot. The representative may make an appointment with a reviewer, or he or she may just walk in and try to see any reviewer available.
"We call them the expediters," said Marjorie W. Pinchback, a program assistant who oversees the handling and filing of applications.
Reviewers check to determine, according to Artanse Hussey, a reviewer, whether the applications meet these requirements:
The name on the label must correctly and adequately describe the product. "It can't say just turkey; it has to say what kind of turkey -- young turkey, for instance."
The handling statement must be proper, so the consumer knows whether to refrigerate after opening or take some other necessary step.
The statement of the product weight must be included.
The name of distributor and/or packer must be listed.
Provision must be made on the label or package for the mark of the USDA inspector.
Some print sizes must meet department regulations. Net weight, for example, must be in letters no less than 1/8 inch tall on small packages.
Other parts of the label contents are approved or disapproved on the basis of the reviewer's judgment, Hussey said.
"Light yellow printing on white background isn't prohibited by the rules but I might not approve it because it is so difficult to read," she said. The same is true of black on red, she said.
Hussey has been in the label section for 12 of her 20 years with USDA. Before joining the department she worked in the poultry industry.
At her desk, with hanging plants in the window and five regulation and policy books atop her file cabinet, Hussey described her job as a "constant challenge . . . because each time I reach for a new application, I get something new -- an Italian product, a won ton or some other new product, from the most basic to a gourmet."
Most of the applications that come to the reviewers are approved. Of the 104,826 submitted during fiscal 1980, 14762 were returned to the company without approval.
The applications that come to Hussey, Gordon and the other reviewers may be a sketch of a proposed label or they may be the printed label. Manufacturers with any doubts about their label usually have the sketch approved before going to the expense of having labels printed.
Firms making special dietary claims on labels, such as "no salt added" or "lower fat," must pass still another review by the three food technologists who work down the hall from the seven label reviewers.