Hi! Thanks to Creative Cookier, I researched the law... which I'll post a pertinent section of below. Has ANYONE ANYWHERE had Royal Icing with Meringue Powder tested for pH and aw (water activity) in a lab?
If not, I suggest we look into labs which can do the testing and their cost (one is posted above), and maybe we can get donations to help CFO's pay for this from around the country? There is one in LA and these others in CA.
From FDA:
(c) "Potentially hazardous food" does not include:
- (i) An air-cooled hard-boiled egg with shell intact;
- (ii) A food with an aw value of 0.85 or less;
- (iii) A food with a pH level of 4.6 or below when measured at 24 °C (75 °F);
- (iv) A food, in an unopened hermetically sealed container, that is commercially processed to achieve and maintain commercial sterility under conditions of nonrefrigerated storage and distribution; and
- (v) A food for which laboratory evidence demonstrates that the rapid and progressive growth of infectious or toxigenic microorganisms or the growth of S. Enteritidis in eggs or C. botulinum can not occur, such as a food that has an aw and a pH that are above the levels specified under Subparagraphs (c)(ii) and (iii) of this definition and that may contain a preservative, other barrier to the growth of microorganisms, or a combination of barriers that inhibit the growth of microorganisms.
- (vi) A food that does not support the growth of microorganisms as specified under Subparagraph (a) of this definition even though the food may contain an infectious or toxigenic microorganism or chemical or physical contaminant at a level sufficient to cause illness.
I'm unfortunately operating at a significant loss at the moment due to business start-up costs, so can't afford to fund a significant portion of this on my own 
(Please send San Jose area business my way .... 
)