NCC yesterday delivered public comments at a U.S. Department of Agriculture Food Safety and Inspection Service (FSIS) virtual meeting about the agency’s recently announced regulatory framework for Salmonella in poultry products. NCC’s comments addressed each of the three components the agency said it is currently considering as part of a new strategy.

Food safety is a top priority for the broiler industry, and NCC supports changes in food safety regulations that are based on sound science, robust data, and are demonstrated to positively impact public health.

As part of the framework, FSIS said it would be proposing three components, including:

  • Requiring incoming flocks be tested for Salmonella before entering an establishment;
  • Enhancing establishment process control monitoring and FSIS verification;
  • Implementing an enforceable final product standard, while considering whether Salmonella at certain levels and/or types of Salmonella should be considered as an adulterant.
Ashley Peterson, Ph.D.

Regarding component one, Preharvest Testing, NCC’s Senior Vice President of Scientific and Regulatory Affairs, Ashley Peterson, Ph.D., told the agency the biggest concern is the potential to negatively impact the welfare of the birds and the potential to limit the supply of chicken in the marketplace. “This component risks reverting to a long-abandoned command-and-control approach whereby FSIS inspectors make decisions about how plants operate,” said Peterson. “In this time of extreme inflation coupled with ongoing food security challenges, a command-and-control approach will do nothing to improve public health, it will only remove chicken from the meat case.

“The industry is and should be expected to control potential pathogens, but there is not a one-size-fits-all approach in doing so,” Peterson commented in response to component two, Process Control. “Overall, this approach will stymie innovation and technology which seems counter to a collaborative food safety approach.” She recommended FSIS use verification sampling results, to include enumeration results, in a risk assessment model to help understand what impacts, if any, changes in indicator organisms and/or Salmonella load at various processing locations will have on public health.

Regarding the third component about a Final Product Standard, Peterson encouraged FSIS to build on the successful path established through performance standards, whereby the industry and agency collaborated to meet voluntary standards. “However,” she added, “we do not believe that the Poultry Products Inspection Act provides statutory authority to create an enforceable, adulteration-based final product standard for Salmonella in raw poultry… After scientifically determining the impact on public health, FSIS could consider a quantitative approach and give industry the opportunity to meet an enumerative performance standard.”

Peterson also expressed NCC’s appreciation for FSIS’s interest in data sharing. “We believe it is critical that we all start with robust data, and from there collaborate on the best way to approach Salmonella control,” she said.

“We look forward to a continued meaningful dialogue with FSIS on the proposed Salmonella framework and are hopeful we can come up with a science-based, data-driven approach that will not only improve public health but also ensure that consumers of America’s favorite protein still have an affordable product available to feed their families,” Peterson concluded.