Julie Larson Bricher recently wrote an article on MeatingPlace.com outlining a petition that asks the USDA to declare 31 Salmonella serotypes as adulterants in meat and poultry. The move would make what is now legal against the law. Bricher’s piece has generated a lot of comments.

Today I write not to discuss Bricher’s article — which is based on an interview with the lawyer who filed the petition, Bill Marler. Today I want to discuss comments regarding Bricher’s story. Commenters on MeatingPlace.com can post anonymously or with pseudonyms. Some recent comments on Bricher’s coverage of the petition, and my responses, are shown here in a modified question-answer format.  

“Mr Alright” posted: Make sense to me. It really takes too long to find out who is making hundreds of individuals sick. Test and hold for salmonella testing makes complete sense. It’s time to step up and move out those who don’t care about consumers.

“Sure Jan” replied: Most Salmonella strains aren’t pathogenic. Methods don’t exist to rapidly and cost effectively identify just the 31 strains he is asking for. This is a supply chain nightmare and would unjustly affect the most food insecure in our country.

Carl’s response: True, many Salmonella serotypes are not pathogenic to humans, or in past feeding trials it took thousands to cause disease. Interestingly two serotypes that are poorly pathogenic to humans, S. Gallinarum and S. Pullorum, are highly regulated by USDA’s subagency APHIS because they are pathogenic to poultry. 

There are currently rapid methods to identify the 31 serotypes in the petition based on Polymerase chain reaction (PCR) technology. And, with additional development of Whole Genome Sequencing (WGS) there will be more specific rapid methods.

As for declaring these pathogens as adulterants being “a supply chain nightmare” it should stimulate the industry to apply logical controls on ingredients. The animals coming into slaughter bring the majority of pathogens that end up on the product entering commence. FSIS-inspected establishments perform thorough clean ups thus, preventing resident pathogens contaminating product. 

Those familiar with slaughter procedures and the scientific literature know the sources of fecal bacteria on carcasses. In beef slaughter, aerosols from hide pulling are a common pathogen source. In pork and poultry slaughter, the defeathering and dehairing procedures press fecal material into the empty follicles where they are protected from subsequent interventions. The petition references Galton’s 1954 observation of swine dehairing, “The carcass is subjected to vigorous treatment, and in the process, fecal leakage from the completely relaxed anus inevitably will occur.” (Galton, M. M., W. V. Smith, H. B. McElrath, A. B. Hardy. (1954). Salmonella in Swine, Cattle and the Environment of Abattoirs. J Infect Dis. 95(3):236-245.) Mark Berrang, in 2001 published a solution to the problem in poultry processing by eviscerating the poultry before defeathering (Berrang, M. E., R. J. Buhr, J. A. Cason, J. A. Dickens. (2001). Broiler Carcass Contamination with Campylobacter from Feces during Defeathering. J Food Prot. 64(12):2063-2066.). 

The most practical intervention is likely preharvest control of human pathogens in live animals. Pomeroy in the 1970’s successfully produced Salmonella-Free turkeys starting with Salmonella-free chicks and biosecurity (Pomeroy, B.S., Nagaraja KV, Ausherman LT, Peterson IL, Friendshuh KA. 1989. Studies on feasibility of producing Salmonella-free turkeys. Avian Dis. 33:1-7.). The preharvest controls have advanced since then based on research by industry, government, and universities. What’s lacking is the incentives for implementing those controls, the realization of how important preharvest controls are on the ingredients, and thus, the final product and environment. For instance, in the early days of regulating Escherichia coli O157:H7 in ground beef and the Salmonella Performance Standards, I found several grinders who did not realize the source of the pathogens was the trim. Now, many grinders require their trim suppliers to have both validated interventions and verification. Sadly, the epidemiology indicates not all grinders and not all grinders require Salmonella interventions.  

“Sam Johnson” posted: A fool’s errand

Intellectually. there’s little justification to say that E. coli O157:H7 and the Shiga-toxin producing E. coli are adulterants but salmonella is not. This is a true statement. Intellectually there is no justification to say any naturally occurring bacteria. virus. or prion is an adulterant given the definition of adulterant. This is a non sequitur argument.

[Carl]: There are several definitions for adulterant in the Code of Federal Regulations (CFR). Here are the most important ones for meat: 

9CFR 301.2 Definitions.

Adulterated. This term applies to any carcass, part thereof, meat or meat food product under one or more of the following circumstances:

(1) If it bears or contains any such poisonous or deleterious substance which may render it injurious to health; but in case the substance is not an added substance, such article shall not be considered adulterated under this clause if the quantity of such substance in or on such article does not ordinarily render it injurious to health;

[Carl]: Thus, any Salmonella on lettuce is an adulterant because it is an added substance. Is Salmonella on meat or poultry an “added substance”. The papers by C.O. Gill and others indicate the flesh of animals after slaughter is sterile. Leucocytes remain active after slaughter for a while scavenging any bacteria introduced by the bleeding knife. Here are two: (Gill CO, Penney N, Nottingham PM.1978. Tissue sterility in uneviscerated carcasses. Appl Environ Microbiol. 36:356-359. Gill, C.O. 1979. Intrinsic Bacteria in Meat. J. Appl. Bacteriol. 47: 367-378.) Thus, if the muscle comes into the slaughter establishment sterile, then any Salmonella is an added substance. In the Washington Post article on the Salmonella petition, Katie Rose McCullough, a food scientist with the meat institute was quoted, “Unlike E. coli (sic), salmonella (sic) can be part of the animal’s flesh — in the lymph nodes — which filter and collect potentially harmful pathogens to keep animals healthy. “You can’t remove all of it; that’s impossible.” 

[Carl]: The lymph nodes can be excised and inspecting lymph nodes is a part of current meat inspection. In fact inspectors slicing lymph nodes has been cited as one vector of Salmonella contamination for meat. The ideal means of preventing lymph nodes carrying pathogens such as Salmonella or Shiga Toxin positive Escherichia coli (STEC) would be preharvest control of those pathogens in the live animals. A bonus benefit of preharvest control would be less environmental contamination from animal production via manure, runoff, air and wild animals. But that’s another article.

Two other definitions of adulterant are:

“(3) If it consists in whole or in part of any filthy, putrid, or decomposed substance or is for any other reason unsound, unhealthful, unwholesome, or otherwise unfit for human food;

(4) If it has been prepared, packed, or held under unsanitary conditions whereby it may have become contaminated with filth, or whereby it may have been rendered injurious to health;”

[Carl]: USDA in the Supreme Beef Processors, Inc. v. USDA used (4) in arguing that the establishment had failed three Salmonella Performance Standard test because the ground beef at the plants was produced under “insanitary conditions. Supreme Beef’s winning argument was that the trimmings they bought contained the Salmonella and not insanitary conditions within their establishment. Most grinders now require more of their trim suppliers. 

“eye-roller” replied to “Sam Johnson:” Seriously. If people butcher their own chicken at home they too will find salmonella. How are we supposed to consider something an adulterant when it’s just there naturally?

[Carl]: Excellent reply and the premise for the petition. The petition identifies 31 serotypes of Salmonella that are associated with outbreaks, many of them from poultry. Thus, epidemiology demonstrates that these serotypes are injurious in the hands of ordinary consumers. Therefore, according to 9CFR 301.2 (1) or 9 CFR 381.1(I) those serotypes are adulterants. If people butcher their own chickens and it contains one of those serotypes, it’s not an issue. If they attempt to sell it, then it’s a regulatory issue on several levels. 

“|” posted: Further info needed It would be nice if the article went into the details of the implications of this being passed versus current regulation. Some of us are a little distant from QA and regulatory.

[Carl]: Hopefully, this article will help you. 

“bockchain” posted: cool fantasy but. . . One need only look at the processing differences between beef and poultry to understand that this proposition is absurd. There is no way to implement such a strategy, and more importantly, no need to do so. The food safety environment now is a vast improvement over that which led to the Jack in the Box outbreak.

[Carl]: Thank You. We hope the petition will fulfill the fantasy. 

Yes, the biggest difference between beef and poultry — and swine — processing is the dehairing and defeathering process that presses fecal material into empty follicles. That aside from carriage is the principal reason the tolerance for Salmonella, based on baseline surveys, is higher for pork and poultry and ground pork and poultry. Beef is skinned thus, there are no empty follicles protecting fecal borne pathogens from interventions, only cuts and creases.

Scientific research over the past half century shows it is possible to implement this strategy. This petition will provide an incentive to implement those interventions. The epidemiological record demonstrates the need for implementing this petition. Declaring E. coli O157:H7 an adulterant in ground beef after the Jack in the Box outbreak stimulated both research and interventions for that pathogen. At the time, salmonellosis was a greater food-borne hazard but FSIS did not act on it. The rate of salmonellosis has diminished little since then. Therefore is long past time for action.

“Matt F” posted: “We’re smarter than this, aren’t we?

Sure, Salmonella isn’t something to be trifled with, for particular strains anyway, but simple safe handling and preparation will eliminate the hazard easily enough. Declaring Salmonella an adulterant would be a monumental mistake.

[Carl]: Yes, I suspect you, me, and many readers of MeatingPlace.com are competent in handling raw meat and poultry. We prevent cross contamination, wash our hands and, check internal temperatures correctly. However, the epidemiological record, Aside from the environmental contamination of produce, illustrates that the incompetent are numerous. For example, I have witnessed a NASA engineer, a House Agricultural Committee staff member, an architect, and USDA staffers mishandle grilled meat and poultry. These were not stupid people but they were ill-trained in handling potentially hazardous products. I often advised the hot line on the science of food safety. Once, I suggested some of their recommendations were too simplistic and could be more sophisticated. “Oh no”, was the reply, “The consumers who we usually communicate with are those smart enough to find our telephone number or to email us. Their ignorance is scary enough. We fear for those who don’t contact us.” 

One of the four options I suggested in 2014 was, with tongue in cheek, “Continue the status quo and let the incompetent suffer the consequences: While seeming cruel, it would provide continuing incentives for educational efforts such as those at CDC, FSIS and FDA. It would also not impose a greater burden on producers and growers, and, thus, raise the cost of food.”

(Custer, C.S. 2014. Controlling Pathogens: Options and a Recommendation.) 

In conclusion 
Not declaring the 31 serotypes of Salmonella adulterants would be a monumental mistake. Salmonellosis has been a leading food-borne cause of death as reported by CDC for decades. I believe the major cause of USDA dragging its feet is the wrong-headed decision in APHA vs Butz 1975. That decision was largely based on a 1971 unsubstantiated political opinion that consumers were competent. That opinion was contrary to the previous decade’s science, the 1969 NAS Report, “An Evaluation of the Salmonella Problem”, and the USDA’s 1970 report, “A Review of the NAS-NRC Report.  An Evaluation of the Salmonella Problem”. It’s past time for USDA and FSIS to correct those mistakes and enforce to Meat and poultry Inspection Acts.

Carl Custer

About the author: Carl Custer is an independent consultant for food safety microbiology. He retired from USDA FSIS in 2007 after over 34 years as a bench and a desk scientist. Carl also served as a trainer for FSIS inspectors, the FSIS Hotline, retail processors and inspectors, small farm processors, and country ham processors. Carl is a lifetime member of the International Food Protection Association (IAFP) and the American Society for Microbiology. Carl started his Food Microbiology career in 1966 as a technician then as graduate student for Dr. Carl Vanderzant at Texas A&M. Projects included dairy, meat, and seafood microbiology.

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