A petition to USDA’s Food Safety and Inspection Service asking for the listing of 31 Salmonella strains as meat and poultry adulterants raises a question. How did FSIS respond the last time someone wanted to list Salmonella as an adulterant?

That someone was the Center for Science in the Public Interest, which spent much of the past decade trying to persuade FSIS to declare four Salmonella strains as adulterants because they are antibiotic-resistant (ABR) strains. The four ABRs are: Hadar, Heidelberg, Newport, and Typhimurium.

The new petition, filed Sunday by food safety attorney Bill Marler, asks FSIS to declare adulterant status for the four ABS strains and 27 others that he calls the “Salmonella Outbreak Serotypes.”

They are: Salmonella Agona, Anatum, Berta, Blockely, Braenderup, Derby, Dublin, Enteritidis, Hadar, Heidelberg, I 4,[5],12:i:-, Infantis, Javiana, Litchfield, Mbandaka, Mississippi, Montevideo, Muenchen, Newport, Oranienburg, Panama, Poona, Reading, Saintpaul, Sandiego, Schwarzengrund, Senftenberg, Stanley, Thompson, Typhi, and Typhimurium.

The CSPI wanted the four ABR strains declared adulterants. It also wanted FSIS to ensure adequate sampling and testing for the pathogens and then remove contaminated meat and ground poultry products from the human food supply.

“After thoroughly reviewing the available data, FSIS has concluded that the data do not support giving the four strains of ABR Salmonella identified in the petition a different status as an adulterant in raw ground meat and raw ground poultry than Salmonella strains that are susceptible to antibiotics,” FSIS said in response to the CSPI petition.

“Additional data on the characteristics of ABR Salmonella are needed to determine where certain ABR Salmonella could qualify as adulterants under the Federal Meat Inspection Act, ” it continued. “Therefore, FSIS denies your request without prejudice.”


The ruling said most foodborne pathogens, including Salmonella, are not considered adulterants of raw meat or poultry because of ordinary cooking, which is usually sufficient to destroy the pathogens.

A 1994 ban of E. coli O157:H7 — and 2011’s addition of six other STEC serogroups (026, 045, 0103, 0111, 0121; and 0145) — in meat and poultry was enacted because they can survive home cooking.

The FSIS said the banned E. coli strains “contain a poisonous or deleterious substance and are adulterated with the meaning of (the Food and Drug Act).”

The agency does not consider raw meat and poultry products, including ground meat and poultry, to be adulterated when they contain Salmonella because ordinary methods of cooking and preparing food kill Salmonella.

The CSPI tried to make the argument that the ABR Salmonella strains had “distinguishing characteristics” that support its classification as an adulterant in raw ground meat and poultry. But to scientific studies, FSIS said more data would be needed for CSPI to make its case.

CSPI leaders thought the human involvement in antibiotic-resistant would help lift ABR Salmonella strains over the others, but FSIS found the petition lacked a definition of “antibiotic resistance.” It also said ABR can occur with or without human involvement.

“Further, most Salmonella species are pathogenic in that they can cause disease, ” the 9-page FSIS ruling continued. “Thus, the issue is whether ABR Salmonella strains are more virulent than susceptible strains. The level of virulence of a pathogen may vary and determine whether a pathogen carries virulence attributes that can be objectively determined.”

FSIS also found ABR Salmonella strains are no more heat resistant than other Salmonella strains. It also said there is a need for more data on what constitutes an infectious dose of ABR Salmonella.

Finally, FSIS said international Codex Guidelines do not require listing Salmonella as an adulterant, and there is no reason to believe that raw meat and raw poultry containing specific strains of ABR Salmonella is unfit for human consumption.

The FSIS is responsible for the safety of the nation’s commercial supply of meat, poultry and egg products. As part of this responsibility, FSIS issued the “Pathogen Reduction; Hazard Analysis and Critical Control Point (PR/HACCP) Systems, Final Rule” in 1996.

That rule sets Salmonella performance standards for establishments slaughtering selected classes of food animals or those producing selected classes of raw ground products to verify that industry systems are effective in controlling the contamination of raw meat and poultry products with disease-causing bacteria, like Salmonella.

FSIS inspectors make sure the establishments are meeting the standards by collecting randomly selected product samples and submitting them to an FSIS laboratory for Salmonella analysis.  FSIS requires all plants to reduce bacteria by means of the PR/HACCP system.

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