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[1] 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.”[2] 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.

[1] 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.
[2] Food Safety and Inspection Service, Modernization of Poultry Slaughter Inspection final rule, July 31, 2014.

  • John Munsell

    Very interesting, Christopher. The most devious ploy I see in the agency’s new poultry inspection program is that FSIS doesn’t specify minimum amounts of testing its inspectors will collect. From the very beginning, the agency stated that removing inspectors from the line will then allow them to perform other food safety functions, such as testing for pathogens. Absolutely no mention of how much agency-conducted testing, if any. Thus, once the new program is up & running, we can’t complain that FSIS inspectors are performing an inadequate amount of testing, because the agency never committed to any certain incidence in advance. Why? For the same reason FSIS isn’t requiring poultry plants to specifically test for salmonella and campylobacter. Why? Because if the agency were ever to possess factual evidence of the true incidence of these pathogens, the agency would logically be required to do something about it; namely, implement MEANINGFUL enforcement actions against the plant, a delicately uncomfortable task which the agency avoids at all costs. And it can be argued that under HACCP’s deregulatory umbrella, FSIS intentionally emasculated itself from policing authority. Just as the agency publicly stated prior to HACCP’s implementation, the agency would no longer police the industry, and the industry would police itself. Face it, FSIS no longer wants to INSPECT meat, preferring to merely monitor company-generated paperwork. Yup, this is true science, centered on FSIS’ ability to greatly reduce its payroll costs. John Munsell

  • hu_sna

    Proposed Solution (opinion only)

    Pathogenic bacteria like Salmonella and Campylobacter survive in the gut of birds, “due to lack of adoption of adequate interventional measures” at the farm. Large corporations that are liable for the dispersion of the poultry to the consumers can benefit from the risks of recalls, defamation and lawsuits by working out with the poultry farmers and offering them resources to reduce the bacterial contamination at the source of the problem :Unsanitary living conditions (piling up the birds in the coop) and early feed withdrawal. Interventional measures at the processing plant is only secondary and will generally not work if the problem is not addressed at the source.

  • Jim

    “According to the CDC, millions of consumers are sickened by these
    pathogens every year, with almost no improvement in more than a decade”

    Seems that FSIS should spend more time educating the consumers instead of the processors. If the consumer cooks their poultry correctly any and all pathogens will be eliminated. Furthermore FSIS nor USDA have outlined any ideas that can help reduce or eliminate Campylobacter throughout processing. Instead of coming up with an answer they are forcing plants to discern what can be done to reduce the pathogens. Leave it up the government to implement a “Standard” that they cannot not provide any help with. USDA has once again forced enterprise to reduce something that they don’t know how to do without the use of antibiotics.

  • Jim

    A decade without improvement but during that decade USDA has crucified plants on controlling pathogens. This proves that the consumer is the only person that can control pathogens. Cooking will kill every pathogen known to man. Yet lets harp on plants and not the consumer.