Label Submission and Approval System

LSAS

Webinar Presentation

February 20, 2013

Labeling and Program Delivery Division

USDA, FSIS, OPPD
• Introduction and Background

• Submitter Benefits

• Review of Navigating Your Dashboard

• Review of Managing Establishments

• Brief Review of Creation and Submission of a Label 

Application

• How to check for Status

• How to respond to a Return

• Helpful Tips (Formula Examples, Claims & Supporting 

Documents, Appeals, and Miscellaneous Tips)

• Resources

• Questions

Agenda

2
Introduction and Background

The Labeling and Program Delivery Division (LPDD) within the United 

States Department of Agriculture (USDA), Food Safety and Inspection 

Service (FSIS) develops and provides labeling guidance, policies and 

inspection methods and administers programs to protect consumers 

from misbranded and economically adulterated meat, poultry, and egg 

products which ensure that all labels are truthful and not misleading. 

Labeling includes all forms of product identification, health-related 

claims, net weight, species identification and nutrition.

LSAS is a web-based software application that integrates and 

implements a secure electronic label application process for 

establishments to submit label applications and appeals. 

LPDD launched the Label Submission Approval System (LSAS) on May 

22, 2012.

3
LSAS Submitter Benefits

• Wizard available to assist submitters with determining which labels 

can be submitted through the Generic Label submission process 

will reduce submission errors and questions to LPDD staff around 

generic approval

• Application processing will be faster vs. paper submission

• Realize cost and time savings vs. shipping via surface mail

• Quick and ready online access to application status 

• Access via Level 2 eAuthentication

4
• Storage and record keeping in an electronic environment allowing 

establishments to save & re-submit standard documentation (e.g., 

documents that support claims; written protocols) vs. having to 

print and re-submit with each label application

• Edit checks in the system will check for formatting and submission 

errors, allowing for corrections in “real time” vs. correcting upon 

return from LPDD, reducing turnaround time for label review

• Enhanced communication mechanisms (e.g., messaging within 

LSAS), reducing initial time spent on first time application 

submission and re-submissions

LSAS: Submitter Benefits (Continued)

5
Account Requirements

Register for USDA Level 2 eAuthentication Account 

Respond to email confirmation within 7 days

Make an appointment with a Local Registration Authority 

(LRA) at a USDA Service Center nearest you. Appear in 

person so they may validate your identification 

Complete FSIS Enrollment Wizard to request activation of 

your account for LSAS

Create organizational or establishment profile name for LSAS

6
Account Requirements (Continued)

• Register for an Level 2 USDA eAuthentication:

http://www.eauth.usda.gov/

• Local Registration Authority (LRA) locations:

http://offices.sc.egov.usda.gov/locator/app?type=lra

• FSIS Website for LSAS:

http://www.fsis.usda.gov/Regulations_&_Policies/Label_Submission_Approva

l_System/index.asp

• LSAS Login Access/Enrollment:

https://lsas.fsis.usda.gov/

7
Navigating Your Dashboard

8
Navigating Your Dashboard (Continued)

Item Name Notes

1 Banner

With the exception of the LSAS logo, this banner appears on all USDA web 

pages.

2 Role

Displays the user’s current role. Certain users may be assigned multiple roles 

and can select role by using the dropdown list.

3 Profile Menu Allow user to change their role, share applications, manage establishments. 

4 Navigation Menu Appears on many LSAS pages; menu options depend upon user role. 

5 Quick links

Appears at the bottom of every page; links to additional resources. It displays 

the current application version.

6 LSAS logo Appears on all pages within the LSAS system.

7 Navigation Bar Includes Home, Contact Us and Logout

8 Header

Appears on every LSAS page; indicates the functionality being displayed in the 

context area. 

9 Content Area

Central to all LSAS screens, this area of the screen provides the functionality 

needed to enable the user to perform a task within LSAS.

9
Manage Establishment

Select Manage Establishments from 

drop down

10
Add New Establishment

Select the type of establishment 

you are adding to your profile

11
Add New Establishment (Continued)

Choice to use “Add Est. 

from PHIS” or manually 

enter.

12
Add New Establishment – (Continued)

Selection of PHIS Link

Enter Search Criteria

13
Results from PHIS search

Results of Search. Use 

“Select” to populate fields

14
Selection made and fields populated

15
Confirmation Message – (Submit/Confirm)

16
Create Label Submission

Select “Create” 

to begin

17
Establishment Selection - Step 1

Two establishments have 

been added to my profile

Be sure to “Save and Continue” for 

each screen

18
Establishment Selection – Step 1 (Continued)

Select Establishment(s) 

applicable to the submission you 

are creating

1

2

If you have not set up your establishments as 

previously demonstrated, you have the option to 

add it here.

If you have applied for your grant of inspection, but 

have not received your number, LSAS will generate a 

Temporary Establishment number. 

19
Establishment Selection – Step 1 (Continued)

Establishment selection is now 

populated in the “Included 

Establishments”

20
Product Information – Step 2

If selecting “extraordinary 

circumstances,” review policy at link 

provided and include supporting 

documentation

21
Special Claims Information – Step 3

Selection of some specials claims 

may require the need to include 

supporting documentation

22
Using the “Go To” Selection

Use the “Go To” button to navigate 

to a particular screen or step. 

Select “Go.”

23
Label Documentation – Step 4

1 Select type of documentation

24
Label Documentation – Step 4 (Continued)

2 Browse to locate file 

3 Select “Upload” 

25
Label Documentation – Step 4 (Continued)

Population of Uploaded Files. 

Note: documentation type displayed

4

26
Formula Information (Product Formula ) – Step 6

1 Enter one ingredient per line

2 Select “Search”

27
Product Information – Step 6 (Continued)

Reconcile any error 

messages

3

28
Product Formula – Step 6 (Continued)

Select Unit Type

Default: Percent

4

5 Enter appropriate totals for each line

OR

6 Certification required

Note: “Save” will provide calculated total

29
Approval Information (Temporary) – Step 8

If selecting “Temporary,” provide all 

information, including “Previously 

Approved Label Information”

Temporary

Review instructions at link provided and 

provide sufficient documentation

30
Summary – Step 10

The summary provides the 

opportunity to review your 

submission, and to include 

additional comments before 

selecting “Submit Application”

31
Submit Application, Confirmation – Final Step

Select Download Options

Application ID Number

32
Dashboard: Submitted Application Pool

Application Submitted, Status: 

Received by LPDD

33
Status Check

Status has changed from 

“Received” to “Pending”

34
Status Check (Continued)

Type in Application # and 

select Check

View Announcements for Web 

Submission Status to see what date LPDD 

is processing

35
Returned Application

After being reviewed, your submission may 

appear in either the Adjudicated (Approval) 

Pool or the Return/Rescinded Pool

Choose Select to find out 

why it was Returned 

36
Returned Application (Continued)

Select Summary from 

Available Actions

37
Returned Application (Continued)

Select

Scroll to the bottom of Summary to 

see Label Application Comments 

indicating why it was returned

38
Returned Application (Continued)

Select Edit from Available 

Actions

39
Returned Application (Continued)

Using “Go To” allows you to navigate to 

the screen or step you need to make the 

edits taking place

40
Returned Application – (Continued)

Existing documentation 

41
Returned Application – Adding New 

Documentation

Select type of documentation

Browse to locate file

1

3 Select “Upload” 2

Revised label image is attached

42
Returned Application – Removing Incorrect 

Documentation

Select which document you want to 

remove by clicking the box. 

To remove selection “Delete 

Selected”

43
7234 Summary in preparation of Submitting

If you have no other changes, proceed to 

7234 Summary

44
7234 Summary

The Summary provides the opportunity to review 

your submission and include comments before 

selecting “Submit Application”

45
Submit Application - Confirmation

Application ID Number

Option to download

46
Dashboard Shows Submitted Application Pool 

Your application has moved from the 

Return/Rescinded Pool to the 

Submitted Pool. It will appear in the 

LPDD Pool as a “Resubmittal”

47
48
Formula Examples

Component Formula

49
Formula Examples (Continued)

Composite Formula

50
• When listing your ingredients, DO NOT include bullets, 

special characters, or numbered listing, (e.g., #

cheddar cheese, 109. Ham, **Parsley,

- -Tomato paste, etc.).

• List all ingredients first. Perform search and reconcile 

error message. Then indicate the percentage or weight 

amounts. 

Formula Tips

51
• Which claims need supporting documents?

• What specific documentation is required?

The following chart provides some general guidance. 

Note: This chart is not all inclusive and should not be 

relied upon solely. 

Claims & Supporting Documentation

52
Claims & Supporting Documentation

Claims, Guarantees, Foreign 

Language

Documentation 

Required

What to Provide

Allergen Statements Depends on the claim See the Compliance Policy Guide on Voluntary Allergen at: 

www.fsis.usda.gov/Regulations_&_Policies/Labeling_Allergens/index.asp

Animal Production/Breed/Raising Yes Detailed written protocol explaining controls for assuring the production claim 

from birth to harvest. If purchased, include protocol information from the 

supplier;

A signed affidavit declaring the specifics of the animal production claim(s) and 

that the claims are not false or misleading;

Product tracing and segregation mechanism from time of slaughter through 

further processing for wholesale or retail distribution;

A protocol for the identification, control, and segregation of non-conforming 

animals/product;

A complete, current feed formulation using common and usual language or 

copies of the feed tags;

Certified/Verified Yes Third party certifies/verifies a claim, a current copy of certification/verification 

needs to be provided

53
Claims & Supporting Documentation 

(Continued)

Claims, Guarantees, Foreign 

Language

Documentation 

Required

What to Provide

Environmental/Green Yes Green Claims: have been approved on product regarding the packaging 

material used to hold the product.

Environmental Claims: All environmental claims need to be substantiated. They 

should be specific as to what part of the packaging they apply to, if not the 

entire package, and they should be sufficiently clear and understandable to 

prevent deception. Below is what we mean by “substantiation.” 

Substantiation: Any party making an express or implied claim that presents an 

objective assertion about the environmental attribute of a product, package or 

service must, at the time the claim is made, possess and rely upon a reasonable 

basis substantiating the claim. A reasonable basis consists of competent and 

reliable evidence, e.g. scientific evidence, such as tests, analyses, research, 

studies or other evidence based on the expertise of professionals in the relevant 

area. Evidence to substantiate claims will be evaluated on a case by case basis 

and should be submitted with each application for sketch approval.

Export Only Labels w/deviations from 

Domestic Requirements

Yes Documentation from the importing country that verifies the labeling deviation is 

in compliance with the laws of the importing country. A government document 

or letter from the importer (on company letterhead) usually is sufficient. Refer 

to 9 CFR 317.7 and 381.128.

Foreign Language No Translation information needs to be included on the label application; e.g., 

foreign language equals English

54
Claims & Supporting Documentation 

(Continued)

Claims, Guarantees, Foreign 

Language

Documentation 

Required

What to Provide

Geographical/Undefined Style Yes When terms for new geographic styles (not in the Policy Book) are used on 

labeling, for example, “Laos Style,” the geographic style would need 

documentation by a third-party authority. The third-party authority 

documentation should:

• Indicate the type of product as identified with and peculiar to the area 

represented by the geographical term;

• Indicate the particular characteristics of the X style in a manner that is quick 

and easy to understand. It may be a method of preparation and/or certain 

ingredients that are used;

• Have characteristics that are unique to the geographical style for which the 

documentation is being provided; and

• Should provide the credentials of the person who is claiming to be the third 

party authority. 

Further, unless, the new style is documented in the Policy Book, the company 

needs to submit the documentation for each new label submittal. 

Grading Terms No No documentation needed - the label application needs to validate the grade 

term in the product formula; e.g., USDA choice beef

Guarantees No No documentation needed.

Natural/Organic Yes Natural: No documentation needed. However, the definition, “minimally 

processed, no artificial ingredients” has to be connected to the claim by a 

symbol, such as an asterisk, or it has to be adjacent to the claim. See the specific 

criteria in the Policy Book.

Organic: A “current” or “up-to-date” organic certificate. These are required to 

be current as of a year. For additional information, see Agricultural Marketing 

Service, National Organic Program at: www.ams.usda.gov/AMSv1.0/nop

55
Claims & Supporting Documentation (Continued)

Claims, Guarantees, Foreign 

Language

Documentation 

Required

What to Provide

Nutrition/Health Depends on the claim. If the claim is defined in the regulations, no documentation is need.

If the claim is not defined in the regulation, submit the following:

Nutrition – comparative nutrition claims (less, fewer, reduced, light): For a 

comparative claim when compared to your own regular product, we need to see a 

label of your regular product. When compared to USDA data, we need a copy of the 

page from the USDA website to ensure it is appropriate. For the market leader, top 

3 or market basket, we need a current market basket survey (less than 1 year old) 

based on the volume of product and the labels of the products for comparison.

Religious Exemptions No Refer to Religious Exemption For The Slaughter And Processing Of Poultry, FSIS 

Directive 6030.1

Other Claims Depends on the claim.

May need to contact the 

office for more information.

Whole Grain: Whole grain documentation is needed when whole grain references 

appear in the product name, the labeling includes a factual statement of the grams 

of whole grains, or when the labeling makes any type of statement about whole 

grain in the product outside of the ingredients statement. (Note, if the only 

reference to whole grain on the labeling is in the ingredients statement, no special 

documentation is required.) Always provide a calculation showing how the grams 

of whole grain per serving of product is obtained. The calculation should correspond 

to the formula provided and with any supplier documentation. It is not sufficient to 

just provide the grams of whole grain per serving. One serving is defined as the 

serving size in the nutrition facts panel. If there is no nutrition facts panel on the 

label, then the appropriate RACC as defined in 9 CFR 317.312 or 381.412 should be 

used as the serving size basis. In cases where a specific component is identified in 

the product name as whole grain, for example, whole grain tortilla, then a second 

calculation is required to show that the whole grain is at least 51 percent of the total 

grain component (excluding non-grain components). 

Omega 3 Fatty Acids: For a factual statement , we need to see at least one piece of 

analytical data to support the information.

56
• Selection of an appeal is not a means to “resubmit” a returned application, 

Example: reviewer request a legible copy of label. Use “Edit” under available 

actions to address reviewer’s comments.

• The “appeal” function should only be used if an establishment disagrees with 

a specific modification or reason for rejection. 

• Written arguments supporting the basis for the appeal must be enclosed with 

the appeal. In addition, all uncontested modifications to labeling must be 

made prior to the submission of an appeal. 

• When prior approvals are mentioned in your argument, provide complete 

legible copies of the prior approval. If multiple prior approvals are involved, 

provide a listing.

Difference in Appeal vs. Return

57
• Never share your e-Authentication credentials with anyone. This account is 

specific to you as an individual. 

• If you are using a temporary establishment number, (example: 

LSAS_Temp123) be sure that you update your establishment profile with the 

correct establishment number and address. This is particularly important, 

once you receive your final grant of approval, as it ensure that LPDD can 

provide effective reporting. 

• If you have requested an Extraordinary Circumstance (EC), and your 

submission remains in Draft, be sure you have uploaded your supporting 

documentation . 

• If you permanently leave your company or establishment, contact the LSAS 

Administrator immediately to ensure that your account is properly closed. If 

other employees in your company will need access to your labels, instructions 

will be provided. 

Miscellaneous Tips

58
• Label System and Approval System (LSAS):

http://www.fsis.usda.gov/Regulations_&_Policies/Label_Submission_Approval_System/index.asp

• LSAS Industry Webinar: January 23, 2013: 

http://www.fsis.usda.gov/PDF/LSAS_Industry_Webinar_012313.pdf

• Industry User Guide:

http://www.fsis.usda.gov/PDF/LSAS_Industry_User_Guide_052112.pdf

• LPDD Labeling Guidance: 

http://www.fsis.usda.gov/About_FSIS/labeling_&_consumer_protection/index.asp

• Child Nutrition (CN) Labeling Program:

http://www.fns.usda.gov/cnd/cnlabeling/default.htm

• Generic Labeling:

http://www.fsis.usda.gov/Regulations_&_Policies/Generic_Labeling/index.asp

Additional Resources

59
• LSAS Administrator:

LSAS@fsis.usda.gov or lynn.yoder@fsis.usda.gov

or call: (301) 504-0837

• askFSIS:

http://askfsis.custhelp.com/

• Labeling and Program Delivery Division:

Office: (301) 504-0878

Additional Resources (Continued)

60
61