Kudos to FSIS and ARS for their work and proposing that poultry products “. . . contaminated with certain Salmonella levels and serotypes are adulterated. . . .” Implementing this rule should benefit public health. Producers and processors will likely protest because of the cost, however, a reduction in salmonellosis and the associated health care costs should offset the cost to the economy.
Kim, S., Kang, H., Excler, J.L., Kim, J.H. and Lee, J.S., 2024. The Economic Burden of Non-Typhoidal Salmonella and Invasive Non-Typhoidal Salmonella Infection: A Systematic Literature Review. Vaccines, 12:758
Sampling, testing and ending results will take time and holding lots will not improve quality or safety of raw product. The beef trim industry has adopted by shipping lots under seal. That may not work for raw poultry. The scientific literature has reliable rapid assays for Salmonella.
A historical note: FSIS visual inspection imposes draconian measures to keep certain conditions out of commerce based on 19th century concerns. In 1889, David Salmon reasoned, “There are, then, three very important reasons why we should have a careful inspection of our meat-producing animals at the time of slaughter: 1. To protect the health of our citizens, 2. To maintain the reputation of our meats in home and foreign markets, and 3. To discover communicable diseases of animals before they have spread beyond easy control.” He then predicted, “There may be diseases of man that are derived from animals, and the origin of which has not yet been recognized, and which will be brought out by the investigations of the future; . . .”
A half century later Salmonella was recognized as an increasing food-borne disease. In 1974, Salmonella was dismissed as an adulterant by two judges ignorant of the then current science. Now 135 years later in the 21st century FSIS has the ability to seriously address this deadly pathogen. Will it?
Salmon, D. E. 1889. The necessity for a more rigorous inspection of meat-producing animals at the time of slaughter. Public Health Papers and Reports, 15:173–175.]
The need to control Salmonella in poultry products is because of three public health risks:
The major risk is cross-contamination within home and retail kitchens. Enteric pathogens survive treatments within Official Establishments primarily because they are embedded in emptied follicles during defeathering. Thus, consumers bring raw poultry into their homes carrying those pathogens into kitchens that are often not designed to prevent cross-contamination.
Kosa, K.M., Cates, S.C., Bradley, S., Chambers, I.E. and Godwin, S., 2015. Consumer-reported handling of raw poultry products at home: results from a national survey. Journal of Food Protection, 78:180-186. )98 citations)
The second risk is contamination of the environment, including produce fields, from production operations. The fomites include runoff and noncomposted manure. There are numerous scientific articles attributing contamination of the environment and produce via manure, air, water, insects, and other animals.
The third risk is undercooking poultry products.
The outbreaks involving breaded chicken and Chicken Kiev are examples.
Because eliminating enteric pathogens from raw poultry products is difficult, providing incentives to control Salmonella carriage in preharvest is the best option. An additional benefit would be reducing personal, environmental and produce contamination.
The science and technology to eliminate Salmonella carriage by poultry has advanced since Pomeroy accomplished producing Salmonella-free turkeys using 1970’s technology. Innovations such as pre/probiotics also increase feed conversion. Incentives such as the Salmonella Performance Standard and litigation have promoted implementation and reduction in Salmonella prevalence. CDC reports of salmonellosis indicate that reduction is not enough and many cases are from produce (see environmental contamination above).
In the past decade, the detection of Salmonella and other zoonoses is more rapid and sensitive. Prevention is better. The EU is implementing Logistic Slaughter or “Risk-Based Meat Safety Assurance System.” A quick search for “Logistic Slaughter” will raise numerous scientific reports. This system is more scientific than the 19th century visual inspection system. A recent review is: Trevisani, M., Rosamilia, A., Micheli, M.R., Guidi, E. and Goga, B.T.C., 2024. Perspectives in the implementation of risk-based meat safety assurance system (RB-MSAS) in broiler meat production. Food Control. 160:110308.
Lastly, what about Campylobacter, another non-visible fecal-borne enteric zoonotic pathogens? Fecal contamination of poultry has been mitigated by cloacal plugging or evisceration prior to defeathering. An incentive to better prevent “non-visible” fecal matter containing pathogens would be to implement rapid detection of non-visible feces on poultry carcasses. USDA ARS scientists have published on spectral procedures over the past quarter century. A 2021 publication on portable spectral detection has four ARS co-authors and currently has 23 citations.
Sueker, M., Stromsodt, K., Gorji, H.T., Vasefi, F., Khan, N., Schmit, T., Varma, R., Mackinnon, N., Sokolov, S., Akhbardeh, A. and Liang, B., 2021. Handheld Multispectral Fluorescence Imaging System to Detect and Disinfect Surface Contamination. Sensors, 21:7222.
Implementing spectral detection would be controversial. FSIS could reserve it for processors that have not implemented fecal or preharvest controls. An advantage is the results are instant; there is no need to hold product waiting for results.
There is a large body of scientific and technological information on reducing Salmonella and other zoonotic pathogens in meat an poultry products. Lacking are regulatory incentives. The proposed FSIS regulation should provide a beginning.
(To sign up for a free subscription to Food Safety News,click here)
