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FSIS Denies CSPI Petition to Declare Antibiotic-Resistant Salmonella an Adulterant

Thursday was a busy day for the Department of Agriculture’s Food Safety and Inspection Service. In addition to publishing its new poultry inspection rule, the agency also released its response to the Center for Science in the Public Interest’s petition, denying the organization’s request to have antibiotic-resistant Salmonella declared an adulterant.

CSPI’s petition, originally filed on May 25, 2011, called on FSIS to issue an interpretive rule declaring antibiotic-resistant (ABR) strains of Salmonella Hadar, Salmonella Heidelberg, Salmonella Newport and Salmonella Typhimurium to be adulterants when found in ground meat and poultry. The declaration would mean that the agency would have to test for these pathogens and remove contaminated products from the food supply.

“We have concluded that more data are needed to determine whether ABR Salmonella should have a different status as an adulterant under the [Federal Meat Inspection Act] and [Poultry Products Inspection Act] than Salmonella strains that are susceptible to antibiotics,” reads the FSIS response.

“The petition asserts that the crucial legal difference between ABR Salmonella and susceptible Salmonella strains is that ABR Salmonella occurs as the result of human intervention, i.e., the administration of antibiotics to live animals used in the production of meat and poultry,” the letter continues.

FSIS responds that ABR microbes can be present in food animals even if they haven’t been exposed to antibiotics, so more data would be needed on how much the administration of antibiotics contributes to the presence of ABR Salmonella in ground meat and poultry.

Another important aspect of the issue is whether “proper cooking” kills a pathogen. FSIS states that, in the case of E. coli strains that have been declared adulterants, consumers sometimes consider ground beef cooked rare, medium-rare or medium to be properly cooked even though it hasn’t reached a high-enough internal temperature to kill off the pathogen.

But for Salmonella, the agency says it is not aware of data to suggest that consumers think ground poultry, pork or lamb is properly cooked if it is less than “well-done.”

Other areas where FSIS said the request lacks data are:

  • the number of Salmonella per serving in different known food products responsible for outbreaks in order to understand the actual effective dose of different strains
  • whether ABR Salmonella causes more severe illnesses
  • that ABR Salmonella is more heat-resistant than susceptible strains

“USDA’s failure to act on antibiotic-resistant strains of Salmonella in the meat supply ignores vital information about the public health risk posed by these pathogens,” said CSPI Food Safety Director Caroline Smith DeWaal. “Despite numerous examples of outbreaks linked to resistant pathogens, USDA leaves consumers vulnerable to illnesses that carry a much greater risk of hard-to-treat infections leading to hospitalization.”

After three years of waiting for a response, CSPI filed a lawsuit on May 28, 2014, asking the court to require the agency to respond. FSIS’ denial is “without prejudice,” meaning that CSPI can submit a revised petition with additional information if they choose to do so.

© Food Safety News
  • Gene

    “The declaration would mean that the agency would have to test for these pathogens and remove contaminated products from the food supply.” It would be interesting to know just how testing is done to differentiate antibiotic resistant from antibiotic susceptible? Biochemical or genetic? Plating or PCR?

  • johnmarkcarter

    Part of FSIS support in this decision comes from the following statement, made 40 years ago by a US Circuit Court:
    “American housewives and cooks normally are not ignorant or stupid and their methods of preparing and cooking of food do not ordinarily result in salmonellosis,”
    (American Public Health Association, et al., Appellants, v. Earl Butz, Secretary of Department
    of Agriculture, et al., United States Court of Appeals, District of Columbia Circuit. 511 F.2d 331, 1974)

    to Gene:
    Current testing for Salmonella is already a fairly expensive burden. Surveillance requires microbiological culture, to amplify tiny numbers of bacteria, for subsequent testing via biochemical phenotype, immunochemical, and PCR methods. PFGE and sequencing-based methods are currently used to support trace-back of outbreaks. CSPI’s petition didn’t suggest how we should validate routine antibiotic testing as a part of that general work-flow. I assume that would have to be done by plating all isolates of the indicated Salmonella strains against all antibiotics of interest.