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Breaded Stuffed Raw Chicken Products: Who’s Responsible for their Food Safety?

Reports of mishandling and illness from breaded stuffed raw chicken products go back nearly as far as the availability of the product itself. Since 1998, the products have been associated with up to 14 outbreaks and about 200 illnesses. In 2005, health officials warned consumers to make sure they fully cook frozen meat and poultry products, due to salmonellosis cases linked with the frozen, prebrowned stuffed chicken entrees. In 2008, USDA issued an alert reminding consumers that the products are raw even though they may appear to be cooked and to follow all cooking instructions. “Individuals who became ill did not follow the cooking instructions and reportedly used a microwave to prepare the product,” the alert stated.

Two decades later, the USDA’s August 1, 2022, announcement of action to declare Salmonella an adulterant in breaded stuffed raw chicken products is still getting pushback from chicken producers.

By declaring Salmonella an adulterant in these products, the announcement stated, FSIS will be able to ensure that highly contaminated products that could make people sick are not sold to consumers. Because the products appear cooked, they are frequently undercooked by consumers. Because “continual efforts to improve the product labeling have not been effective at reducing consumer illnesses,” USDA has proposed the action. FSIS will be proposing to set the limit at 1 colony forming unit (CFU) of Salmonella per gram, with products exceeding that considered adulterated and subject to regulatory action. However, the agency will seek comment on whether a different standard for adulteration – such as zero tolerance or one based on specific serotypes – would be more appropriate.

Currently, the announcement is just that, with USDA expecting to publish the notice in the Federal Register in the fall, seeking public comments on the standard, and informing a final implementation plan, including a verification testing program.

In the U.S. Regulatory Update Session at IAFP 2022 in early August, USDA Deputy Under Secretary for Food Safety, Sandra Eskin, discussed the announcement along with background on the decision and some of USDA’s future, related plans. The action was the outcome of a comprehensive look the agency was taking to control Salmonella in poultry to reduce illness. Although the industry has seen a decrease in detection, she said, there has not been a reduction in illnesses. Because the breaded stuffed chicken products appear to be RTE, but are actually raw, the agency began its focus there.

Turning to a discussion of “what’s next,” Eskin stated that there will continue to be a focus on Salmonella in poultry because of the failure to meet the public health goals. This will include focus on where the birds enter facilities, through the slaughtering and processing, and before they are distributed from the facility. Eskin also noted the challenges of detecting low levels of pathogens, but said that, as the agency learned with E. coli, “If we require it, the testing industry will create it.”

Other areas the agency is looking at include:

  1. Assessing the use of HACCP in slaughter and processing. Although it does provide a good basis, the agency will be “tweaking” requirements as it develops strategies.
  2. Incentivizing interventions and practices conducted before final product testing.
  3. Requiring Salmonella test results on incoming flocks before acceptance, with the processor proving the ability to bring the product into line if it is over the standard. The agency does not plan to require any specific pre-harvest intervention, however. Each facility would need to determine its own.

The concern from the National Chicken Council was primarily due to the precedent set by this abrupt shift in longstanding policy, made without supporting data, for a product category that has only been associated with one outbreak since 2015. Additionally, NCC said, “The only way to ensure our food is safe 100 percent of the time is by following science-based procedures when raising and processing chicken, and by handling and cooking it properly at home.”

It is that final statement that likely plays right back into USDA’s hands, as it is the fact that consumers are not properly handling and cooking the products that is causing the issues. While NCC also said it has twice petitioned FSIS asking for mandatory and stricter labels for these products, to help consumers better understand the proper cooking procedures, USDA also could retort that the chicken industry could have done that on its own, which may have supplanted the need for USDA to set the new requirements for these specific products.

Time will tell exactly how this new strategy toward poultry regulation lands, but FSIS is under pressure to do something to address the number of Salmonella cases attributed to poultry. Thus we should anticipate that this will likely lead to some new regulatory requirements. The fact that FSIS is talking about a quantitative standard rather than presence absence is a significant shift for the agency.  Similarly, paying more attention to risk and control of Salmonella on the live side is also a positive move – something that leading poultry companies have been seeking to manage for years.


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