On April 25, 2023, the Food Safety and Inspection Service (FSIS) of the US Department of Agriculture (USDA) proposed its first ever limit on the level of Salmonella in raw chicken.
Under the new proposal, the chicken ingredient used in the manufacture of breaded, stuffed raw chicken products must not contain more than one live Salmonella per gram of chicken.
The FSIS will consider any breaded, stuffed raw chicken product to be adulterated if it is manufactured using a chicken ingredient that exceeds the one-per-gram limit.
The proposed limit does not apply to other forms of breaded raw chicken products, such as nuggets, patties, or chicken fingers.
The details will be published in the Federal Register, and the public will have a 60-day period in which to provide comments on the new proposal.
Why now?
In 1998-2020, the FSIS carried out 178 Salmonella outbreak investigations associated with raw and cooked chicken products. Fourteen of them involved breaded, stuffed raw chicken products.
According to statistics cited in the draft proposal, breaded stuffed chicken products accounted for less than 0.15% of the total US chicken supply, yet were associated with approximately 5% of all chicken-associated outbreaks in the United States.
In 2006, following a series of outbreaks, the FSIS urged the poultry industry to modify the labeling on packages of breaded, stuffed chicken products to emphasize to consumers that these products are, in fact, raw and that they must be cooked to an internal temperature of 165º.
That same year, the FSIS issued guidance to consumers regarding safe cooking practices for these products.
Nevertheless, additional outbreaks occurred in 2008-2009, 2013, 2014, 2015-2016, and 2021, leading the FSIS to propose this new policy approach.
In a Letter to the Editor of Food Safety News, Consumer Reports expressed its support for the initiative.
Conversely, the National Chicken Council has voiced its opposition to the proposed policy change.
According to reporting by Food Safety News, the Council raised concerns regarding economic impacts, job losses, and an “abrupt shift” in longstanding policy—a shift that the industry group claimed was not science-based.
Impact on food safety
The USDA argues, based on anticipated portion size and the expectation that at least some of the Salmonella will be killed when the raw chicken products are cooked, that their proposed limit “…should significantly mitigate the risk of illness…” associated with the raw, breaded stuffed chicken products.
But other countries have chosen a different path.
In the past, Canada also struggled with repeated outbreaks of Salmonella associated with raw, breaded chicken products.
On April 1, 2019, the Canadian Food Inspection Agency (CFIA) implemented a new policy designed to reduce the risk of Salmonella illnesses associated with these products.
That policy included a “zero tolerance” for Salmonella in a 125g sample of the raw chicken mix used to manufacture the targeted products.
This specification is 125 times as stringent as the proposed USDA limit.
There have been no reported outbreaks of Salmonella in Canada linked to consumption of raw, breaded chicken products manufactured since the new policy took effect.
In the United Kingdom and member countries of the European Union, the detection of Salmonella in any raw poultry product—intact, ground, and/or breaded—is grounds for initiating a product recall.
When viewed against the backdrop of European and Canadian policies, the proposed USDA approach is barely a first baby step in the direction of mitigating the risk of Salmonella outbreaks linked to raw, breaded stuffed chicken products.
And this new policy will have no effect at all on the risk of Salmonella infections from other raw poultry, whether due to undercooking or cross-contamination.
By the numbers
In its draft proposal, the USDA acknowledges that infective doses as low as from 1 to 420 Salmonella organisms per person have caused illnesses in previous outbreaks, with a median dose of 36 Salmonella per person.
At a permitted level of one Salmonella per gram, a 3-ounce (85g) portion of breaded stuffed chicken would contain, in theory, 85 Salmonella cells before cooking.
If the product is allowed to thaw and remain at or above room temperature before cooking, either in the car or in the home, these numbers will increase.
The best way to ensure that temperature abuse does not lead to a dangerous level of Salmonella is to start with as clean a slate as possible.
In this context, a limit of one Salmonella per gram is a recipe for disaster.
Faulty focus
The USDA has limited its proposal to breaded, stuffed raw chicken products, arbitrarily exempting all other breaded raw chicken products—indeed, all other raw poultry—from any limitation on the presence of Salmonella in the product.
This is a mistake. There is absolutely no scientific or epidemiological basis for this decision.
Canada, too, has made a similar error. While the Canadian “zero-tolerance” policy is far more stringent than the proposed USDA approach, the CFIA has limited that policy to breaded raw chicken products that are NOT stuffed, exempting all other raw poultry from this Salmonella control measure.
Neither country has adopted Salmonella-control measures that would reduce the risk of cross-contamination due to raw poultry in the kitchen.
It is time for both countries to face the reality that the presence of Salmonella in any raw poultry meat represents a significant health hazard to the general public and must be addressed at the source.
The time for baby steps is over.
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