The USDA is beginning to consider whether or not to consider if Salmonella in poultry should be considered a problem.
The department’s Food Safety and Inspection Service (FSIS) today announced that it is “considering a regulatory framework” for a new strategy that would allow the agency to consider controlling Salmonella in poultry products. The goal, if things move forward, is to reduce human illnesses.
Every year at least 135,000 people are sickened by Salmonella, according to the Centers for Disease Control and Prevention. Of those illnesses, one-fourth are caused by the pathogen in chicken.
The potential framework described in the FSIS announcement has three prongs and an open ended time schedule.
Some who have been fighting for Salmonella to be declared an adulterant in poultry — making it illegal to sell chicken contaminated with it knowingly or unknowingly — are feeling lukewarm about the potential framework.
Bill Marler, a Seattle food safety attorney who three years ago filed a petition on behalf of several individuals and three consumer groups seeking to have Salmonella declared an adulterant, said the FSIS announcement reminded him of a 19970s TV commercial: “Where’s the beef?”
He said the proposal for a framework to consider studying the situation “dances around” the problem. He is concerned that the proposed framework is not bold enough. He is, however, glad to see some movement, any movement.
“This is the first public-facing document I’ve seen in more than 30 years that FSIS has put out there showing that they understand there is a problem,” Marler said.
Consumer Reports, one of the groups named in the petition filed by Marler, is also pleased at this first step by FSIS. The group said the announcement “is an encouraging sign that the agency is stepping up its efforts to protect the public.
“Salmonella contamination is all too common in poultry and poses a potentially deadly risk to consumers,” said Brian Ronholm, director of food policy at Consumer Reports. “It’s critical for the USDA to work expeditiously to adopt aggressive goals to sharply reduce Salmonella contamination and focus its efforts on reducing the strains that pose the biggest threat to human health.”
The citizen’s petition asked FSIS to declare 32 strains of Salmonella to be considered an adulterant. The FSIS is considering whether to review three of those strains.
Salmonella contamination is widespread in chicken in part because of the often crowded and filthy conditions in which they are raised, according to Consumer Reports. A recent CR investigation, for example, found almost one-third of ground chicken samples tested contained Salmonella.
Consumer reports said the numbers are alarming and that the framework needs to go further.
“While the USDA currently requires producers to test poultry for Salmonella, a processing facility is allowed to have the bacteria in up to 9.8 percent of all whole birds it tests, 15.4 percent of all parts, and 25 percent of ground chicken. Producers that exceed these amounts are given what amounts to a warning, but not prevented from selling the meat,” according to the Consumer Reports statement.
By the FSIS’s own admission the number of illnesses caused by Salmonella in poultry has remained stagnant for decades. This is in the context that industry has reduced the amount of Salmonella found in poultry by 50 percent. Marler explained that anomaly in terms of a swimming pool.
“If you have a pool and you drain out half of the water you still have half a pool of water,” he said.
The water in the pool represents the amount of Salmonella in the chicken. There’s just too much of it left, even with the 50 percent of it gone, that makes people sick. That shows how much Salmonella is in chicken — too big of a bacterial load, as scientists say.
With the proposed FSIS framework the number of human illnesses caused by Salmonella in poultry would be decreased by 25 percent, meaning three out of four people who are sickened would still get sick. That is not acceptable in Marler’s opinion.
The Center for Science in the Public Interest (CSPI) is pleased to see the attention to Salmonella in poultry but is cautiously optimistic.
“While the proposed framework represents a welcome shift in thinking by the agency, many important details are yet to be worked out, and the need for these changes is urgent,” CSPI said in a statement this morning.
“USDA’s announcement of this framework represents a landmark acknowledgment from an agency that has long refused to recognize that Salmonella in raw poultry poses unacceptable risks. Center for Science in the Public Interest first petitioned the USDA to ban certain strains of antibiotic-resistant Salmonella in 2011, and again in 2014, but was denied twice by the agency.”
STOP Foodborne Illness is also happy to see some action out of FSIS on the decade-old problem of Salmonella in chicken.
“Stop Foodborne Illness (STOP) applauds FSIS for taking the first step of developing meaningful, comprehensive controls for Salmonella in poultry that includes an enforceable final product standard. The proposed framework reflects many issues raised by STOP and its coalition partners in our joint petition filed in January 2021,” said Mitzi D. Baum, M.Sc. and CEO of STOP.
One key point in the proposed framework for the possible FSIS strategy for dealing with Salmonella in poultry is to have the industry work out the problem. The framework calls for birds to come into “the establishments” cleaner. That means that people who raise chickens would have to send healthy birds to slaughterhouses and processing plants.
By putting pressure on “the establishments” to accept cleaner birds the government believes the slaughterhouses and processors would put pressure on their suppliers, thus resolving the problem.
Marler says the most significant point in the proposed framework is that it recognizes that dealing with Salmonella pre-harvest is necessary. Right now there is no industry incentive to fix the problem.
Consumer Reports agrees that testing so-called incoming birds is a crucial step.
“Under the proposal announced by the USDA, poultry producers would be required to test flocks for Salmonella before slaughter and provide documentation on Salmonella levels or serotypes to processing plants,” according to Consumer Reports’ statement. “The requirement is meant to incentivize plants to implement measures to reduce the Salmonella load in the final poultry product. USDA is also considering the adoption of a final product standard to ensure that poultry contaminated with Salmonella likely to make people sick is not allowed on the market.”
The framework itself
A key point from the FSIS announcement is that the agency will be seeking comment from stakeholders on all of the elements of the framework — both at a public meeting and in written comments submitted to the meeting docket in the Federal Register — before moving forward with any proposed changes to regulations or other actions.
After analyzing recent data on human illness from the Centers for Disease Control and Prevention and FSIS sampling results from chicken and turkey products, the agency has decided to focus at this time on three serotypes: Enteritidis, Typhimurium, and Infantis, which together cause 33 percent of all Salmonella illnesses. The public petition requested that 32 types be considered adulterants.
Excerpts from the three components of the framework
Component 1: Requiring incoming flocks be tested for Salmonella before entering an establishment
FSIS is considering requiring establishments to characterize Salmonella as a hazard reasonably likely to occur at receiving and that incoming flocks be tested for Salmonella before entering an establishment.
Under this approach, the flock would have to meet a predetermined target for Salmonella at receiving, which may be industry-wide or establishment-specific, and the establishment must demonstrate that its subsequent process will be effective in reducing Salmonella so that the product will meet the final product standard.
Salmonella enters an establishment in and on the birds. The goal of this component is to incentivize the use of pre-harvest interventions that reduce the level of incoming Salmonella contamination or mitigate the risk of a particular serotype entering the establishment.
Under this approach, FSIS does not intend to require the industry to adopt any specific pre-harvest interventions but would allow flexibility for the industry to adopt the practices that are most effective at controlling Salmonella in each particular operation. Establishments would be encouraged to work with their suppliers and contractors to ensure they are implementing best practices in reducing the Salmonella hazard in breeding facilities, hatcheries, grow-out and throughout transport.
Component 2: Enhanced Establishment Process Control Monitoring and FSIS Verification
To ensure that poultry slaughter establishments are effectively controlling Salmonella throughout their operations, FSIS may propose to modify its current regulations to prescribe enhanced establishment monitoring procedures, including revised locations for multipoint sampling and the use of a statistical approach to process control.
The second component of this proposed framework builds on Hazard Analysis and Critical Control Point (HACCP), FSIS’ prevention-based approach to food safety. To ensure pathogen control throughout slaughter and processing operations, FSIS may modify the existing requirements for indicator organism testing for process control and establish additional parameters to better define the required analysis of the data. As part of the proposal, establishments may be required to test for indicator organisms (e.g., aerobic plate count [APC], Enterobacteriaceae).
Component 3: Enforceable Final Product Standard
FSIS is assessing whether certain levels or types of Salmonella in raw poultry products present an elevated risk of causing human illness such that they should be considered adulterants. As a result, the agency is considering implementing a final product standard or standards to ensure that product contaminated with Salmonella that is likely to make people sick is not sold to consumers.
To protect public health, FSIS regulations should prevent products with high levels of contamination and/or specific serotypes from entering commerce. This goal would be accomplished by declaring Salmonella an adulterant. In doing so, FSIS would rely on criteria that were applied to STECs. These criteria are: consideration of serotypes associated with human illness; low infectious dose; severity of human illnesses; and typical consumer cooking practices.
(Editor’s note) The reference to STECs, or Sign toxin-producing E. coli, relates to how the beef industry was forced to clean up its meat when E. Coli was declared an adulterant.
Consistent with its approach to determining the status of certain STECs as adulterants in specific raw beef products, FSIS is considering whether there are specific Salmonella and raw poultry product pairs that have characteristics that distinguish them from other raw poultry products contaminated with Salmonella, such that Salmonella at certain levels and/or types of Salmonella should be considered as an adulterant when present in that specific raw poultry product.
For example, FSIS will soon be releasing a proposal that Salmonella meets the criteria to be considered an adulterant in not-ready-to-eat (NRTE) breaded and stuffed raw chicken products, an action that will allow the Agency to better protect public health.
At the same time, FSIS is exploring if a single product standard for Salmonella in all raw poultry products may be appropriate. From a consumer’s perspective, exposure to a quantity and/or serotype of Salmonella likely to make them sick is a key risk factor for the illness that may be consistent across product types.
Seeking public comment
FSIS is soliciting input on all aspects of the draft framework, related to the three components as well as the cross-cutting issues. An online copy of the proposed framework is available at: www.fsis.usda.gov/inspection/inspection-programs/inspection-poultry-products/reducing-salmonella-poultry/proposed.