USDA Continues to Set its Sights on Salmonella

After announcing its intent to declare Salmonella an adulterant in breaded stuffed raw chicken products in August, USDA FSIS has now furthered its action against Salmonella in all poultry, proposing a “regulatory framework” that would provide for an enforceable, quantifiable final product standard.

As we discussed in an August Insights article, FSIS stated its intent to propose limiting Salmonella presence in breaded stuffed raw chicken products to 1 colony forming unit (CFU) per gram, with products exceeding that considered adulterated and subject to regulatory action. To further its drive against Salmonella in poultry, FSIS is now considering a new regulatory framework that, as currently proposed, would include three components:

1. Requiring that incoming flocks be tested for Salmonella before entering an establishment. With Salmonella required to be characterized as a hazard reasonably likely to occur at receiving, incoming flocks would have to be tested for Salmonella at receiving with flocks meeting a predetermined target (which may be industry-wide or establishment-specific). Establishments must also demonstrate that their subsequent process will reduce Salmonella to meet the final product standard (in component 3).
2. Enhancing establishment process control monitoring and FSIS verification. To ensure that poultry slaughter establishments are effectively controlling Salmonella throughout their operations, FSIS may modify current regulations to prescribe enhanced monitoring procedures, including revised locations for multipoint sampling and use of a statistical approach to process control.
3. Implementing an enforceable final product standard. The Agency is considering a final product standard(s) to ensure that no product is sold to consumers that is contaminated with Salmonella likely to make people sick.

The new regulatory framework is being proposed because, while previous FSIS policies led to a 50% reduction in Salmonella on poultry from 2017 to 2021, there has been no demonstrable reduction in foodborne Salmonella infections linked to these products. To help determine the specifications of the framework FSIS is currently gathering scientific evidence from a variety of activities, including:

1. NACMCF guidance on the microbiological criteria FSIS could use to better prevent Salmonella infections associated with poultry products.
2. An FSIS risk profile for pathogenic Salmonella subtypes in poultry and quantitative risk assessments to address key risk management questions.
3. An FSIS expanded exploratory sampling program for young chicken carcasses to generate microbial data.

Although this proposed regulatory framework is still in the research and specifications stage, FSIS’ transitioning from presence-based to quantifiable Salmonella tests for breaded stuffed raw chicken products show that the agency is intent on continuing to move forward on Salmonella being declared an adulteration and enforcing new standards.

We do, however, see questions remaining, such as whether all Salmonella serotypes will be considered adulterants, or if only those most responsible for human illness would be held to new standards and regulatory action. There also seems to be some indecision on the part of FSIS as to whether there will be a quantitative approach, particularly as the agency’s comment-seeking on the action to declare Salmonella an adulterant in breaded, stuffed raw chicken products included that of whether a different standard for adulteration would be more appropriate “such as zero tolerance.” Perhaps it may even come down to a combination of regulations and standards based on the type of product and evaluation of risk.

Whichever side of the coin USDA FSIS comes down on, you can be sure there will be new regulations of some sort for Salmonella in poultry. With the recent recalls across the food industry, the ongoing consumer advocacy and media coverage, and the repercussions facing the food agencies, the industry is in a harsh regulatory environment. Prevention is at a greater premium than ever before, and food establishments – whether subject to FDA, USDA, or a state health agency – are wise to get ahead of the curve and ensure your food safety policies and programs are as effective as possible.