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Controlling Salmonella Would Cost Producers

Opinion

Controlling Salmonella or other pathogens would cost producers, and the cost would be expected to be transferred to processors and consumers.

For animal pathogens, the USDA’s APHIS bears some of the burden and indemnifies producers for destroyed flocks. Many producers currently bear the cost of preventing animal pathogens from infecting their flocks and herds through biosecurity measures and vaccinations. The National Poultry Improvement Plan (NPIP) and Specific Pathogen-Free Swine (SPF) management programs are two examples.

A few producers also implement measures to control human pathogens. The cost of controlling Trichinella spiralis in swine has a benefit because of the reputation of the pathogen and the strict requirements in 9 CFR 318.10(b).

The costs of preventing Listeria monocytogenes in processed ready-to-eat meat and poultry are borne by the processors. The costs of preventing Shiga Toxin-positive Escherichia coli, such as E. coli O157:H7, in ground beef and hamburger, are borne by slaughterhouses and grinders. Those costs are likely passed on to customers.

The benefits of preventing animal pathogens include wider markets. For instance, it is easier to export animals to other countries. Preventing L. monocytogenes in foods reduces liability for any illness, as well as recalls and other interventions by FSIS.

Controlling Salmonella, particularly outbreak-related strains, has recently been reported to have been implemented by Foster Farms. A recent (Jan. 10) recall by Tysons might have been avoided if the poultry product from those positive grower-producers had been sent to cooking.

Should the financial burden of controlling human pathogens be borne by producers or partially borne by government as are the APHIS programs for animal diseases? Or, should the human health and environmental effect of zoonoses be controlled by law?

The Congressional Statement of Findings in 21 USC 451 and 602 suggests that the financial burden should not be borne only by those who implement human pathogen controls: “Unwholesome, adulterated, or misbranded  . . . products impair the effective regulation of  . . . products in interstate or foreign commerce, are injurious to the public welfare, destroy markets for wholesome, not adulterated, and properly labeled and packaged  . . . products, and result in sundry losses to  . . . producers and processors of  . . . products, as well as injury to consumers.”

Thus, those producer-growers who implement controls for virulent strains of Salmonella should not have to compete with producer-growers who do not.

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