U.S. Department of Agriculture statements and subsequent news reports have given the impression that, under the USDA’s new poultry inspection program announced last week, poultry plants will be required to test for Salmonella and Campylobacter. That is simply not true. It is true that, under the final rule, USDA will require poultry plants to test at two points along the production line. However, the agency will leave it up to the company to decide what organism to test. There is no requirement that plants test for pathogens. A plant could decide to test for enteric pathogens such as Salmonella or Campylobacter. Or the plant could decide to test for indicator organisms such as generic E. coli or Aerobic Plate Count (APC) instead. USDA leaves that decision up to the plant. That means the public has no guarantee, under the final rule, that poultry plants will test for the pathogens which make people sick. Consumer advocates, in comments on the proposed rule, urged USDA to require plants to test specifically for Salmonella and Campylobacter, the two pathogens most commonly associated with illnesses from raw poultry. According to the CDC, millions of consumers are sickened by these pathogens every year, with almost no improvement in more than a decade. A study by the University of Florida ranked poultry contaminated with Campylobacter (No. 1) and Salmonella (No. 4) in the top five pathogen/food combinations that cause the greatest disease burden to the public. If these pathogens are responsible for high rates of illness, wouldn’t it be reasonable to assume that poultry plants should be testing for them? Yet USDA rejected the idea that plants should have to test for specific pathogens. Instead, USDA stated that the purpose of the new testing requirements is “to ensure that establishments are effectively monitoring process control on an ongoing basis,” and this could be achieved “by sampling pre- and post-chill for enteric pathogens, such as Salmonella and Campylobacter, or for an appropriate indicator organism.” USDA further explained that the cost of analyzing samples for Salmonella and Campylobacter is “much greater” than the cost of analyzing indicator organisms and concluded that the costs were not justifiable with regard to monitoring process control. Consumers who are sickened from Salmonella or Campylobacter would undoubtedly disagree. Testing to monitor process control and testing for pathogens should not be mutually exclusive. It doesn’t have to be one or the other; it should be both. Some poultry plants already test for Salmonella and Campylobacter, in addition to indicator organisms, and the cost of analyzing samples has not put those plants out of business. USDA touted its final rule as a “modernization” effort. But USDA rejected a prime opportunity to update its regulatory program to require plants to test for the pathogens that make people sick.
 Batz MB, Hoffman S, Morris JG, “Ranking the Risks: The 10 Pathogen Food Combinations with the Greatest Burden on Public Health.” University of Florida Emerging Pathogens Institute, 2011.
 Food Safety and Inspection Service, Modernization of Poultry Slaughter Inspection final rule, July 31, 2014.