Following the Food Safety and Inspection Service’s (FSIS) recent public meeting on “Exploring Practical Strategies to Reduce Salmonella in Poultry Products,” NCC this week submitted comments to the agency outlining suggested strategies to reduce Salmonella in poultry products. “We appreciate FSIS’s partnership in this process and the Agency’s commitment to identifying practical, implementable solutions grounded in common sense and gold standard science,” wrote Ashley Peterson, Ph.D., NCC senior vice president of scientific and regulatory affairs.
“NCC’s members are committed to reducing the presence of Salmonella in raw poultry products and as described in these comments, we believe this can be achieved by modernizing the current performance standard system, which would not impose additional regulatory burdens, including on the small processors,” Peterson said. The comments also identify areas where current data collection efforts could be streamlined to promote efficiencies that will help ensure poultry products remain a healthy, low-cost protein source for Americans.
Peterson delivers remarks at the FSIS public meeting in January (Washington D.C.- photo by Brien Aho).
Peterson noted that the current performance standards focus on whether Salmonella is present, but an enumeration-based approach would focus on how much Salmonella might be present. “We firmly believe that meeting the Agency’s Salmonella performance standards has resulted in safer poultry products and that these performance standards served a meaningful purpose,” she continued. “With the availability of new technologies including Salmonella enumeration, we believe now is the appropriate time to reevaluate current performance standards and consider other regulatory strategies to further drive down human salmonellosis rates attributed to chicken.”
Coupling the proven effectiveness of Salmonella performance standards with an enumeration-based approach would help the Agency and industry focus on identifying and reducing higher levels of Salmonella that might be present, leading to meaningful public health benefits.
NCC comments also focused on product testing. “While we support robust product testing by both FSIS and industry alike, testing alone will not make food safer,” Peterson said. “Testing acts as a verification of the activities an establishment has implemented to control its processes, and it is critically important that plants control their processes to prevent contamination in the first place. With this dynamic in mind, we recommend process control be included as an important component of a threshold-based standard.”
In regard to retail not-ready-to-eat (NRTE) breaded stuffed chicken products, NCC reiterated the petition that was filed in 2016 and subsequently updated in 2022 requesting that FSIS establish labeling requirements and issue a compliance guideline for developing and communicating validated cooking instructions for NRTE breaded stuffed chicken products. Peterson expanded this request by suggesting that retail NRTE par fried chicken products should also be covered under the existing petition. Finally, NCC’s comments supported consumer education initiatives regarding the safe use of air fryers for cooking poultry products.
“NCC looks forward to continued collaboration with FSIS to reduce the presence of Salmonella in raw poultry products,” Peterson concluded.
The comments come as FSIS closed a comment period, which was extended 30 days, on Tuesday.
