The National Pork Producers Council (NPPC) recently raised concerns about the scientific validity and practicality of reaching the goal of protecting public health through the USDA’s Food Safety and Inspection Service’s (FSIS) proposed “Salmonella Framework for Raw Poultry Products.”
Under the regulation, FSIS would classify certain Salmonella levels and serotypes in raw poultry products as adulterants and, therefore, prohibit them from entering the food supply, NPPC explained in Capital Update.
Additionally, poultry slaughter operations would need to include in their procedures for addressing enteric diseases, such as Salmonella, microbial monitoring programs with statistical process control methods and specific sampling methods. NPPC said that the agency is proposing changes to its existing prevalence-based performance standards approach to Salmonella despite acknowledging that it “has been effective in reducing the proportion of poultry products contaminated with Salmonella.”
NPPC pointed out in its comments that to reduce illnesses, risk-based performance standards will incentivize establishments to evaluate their status by conducting Salmonella quantification testing.
“An adulterated determination can result in unintended consequences, such as food waste of safe products, and will not help protect public health,” the organization said. “NPPC also noted that because Salmonella isn’t an ‘added’ substance – it occurs naturally – it doesn’t meet the statutory definition of an adulterant, and that case law does not support Salmonella being classified as such.”
The microbiological testing FSIS is proposing involves a small portion of product, NPPC said, so it is not representative of all products. NPPC believes such testing should be used only for verification. The organization also cautioned FSIS about requiring the use of risk assessments that rely on serotypes to determine the bacterium’s virulence. Other factors, including handling, preparation, and infectious dose, also play a role in causing Salmonella illnesses.
“Consumer health and safety is at the forefront of the pork industry’s practices,” NPPC wrote. “Although the proposed rule is focused on raw poultry products, NPPC acknowledges the importance of food safety and taking a scientific approach to protect our nation’s food. Salmonella continues to be a high priority for the pork industry, as producers and processors implement strategies and look for improved ways to address the bacterium. The pork industry will continue its collaborative efforts with FSIS to deal with Salmonella through informed policy.”
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