Editor’s note: Steven Mandernach, AFDO executive director, presented these comments on the organization’s salmonella position earlier this fall.

Let me start by thanking Under Secretary Dr. Mindy Brashears and FSIS (USDA’s Food Safety and Inspection Service) for the opportunity to provide comment on this important topic.

The Association of Food and Drug Officials, or AFDO, is a regulatory organization that connects food and medical-products safety stakeholders. The organization impacts the regulatory environment by shaping sound, science-based rules, laws, and regulations while sharing best practices that protect public health. Founded in 1896, AFDO is a professional organization consisting of state, federal and local regulatory officials.  AFDO and its members were among the early advocates working with Dr. Wiley for the adoption of the nation’s first food safety laws including the Meat Inspection Act and Pure Food Acts in 1906.  

In January, 2020, AFDO convened over 130 thought leaders in food safety to brainstorm and prioritize strategies to reduce foodborne illness.  Representatives from all levels of government, academia, industry, consumer groups, and trade associations examined a variety of commodities and pathogens including Salmonella. We are committed to advocating for the implementation of strategies that result in real progress in reducing Salmonella illnesses.

As we continue this work, focusing on improving the results for Healthy People 2030, we have identified a handful of key concepts for Salmonella: 

First, all stakeholders must focus on the top five key Salmonella serotypes or strains and work to eradicate these strains or serotypes that are most impactful to public health including antibiotic resistance. Performance standards must incorporate this concept to be effective. 

Second, the strategies should include a variety of techniques.  Eradication of the most damaging Salmonellas will require a public/private partnership at a level never before implemented in food safety.  This will include vaccine development and requirements for their use, buyer specifications promoting good practices for meat and poultry entering the supply chain, and also good husbandry techniques at the farm levels must be implemented to achieve success.

Third, we must recognize regulations likely will be a tool toward the reduction of Salmonella illnesses in the United States, but the solutions often are at the private sector level.

AFDO and its members look forward to partnering with all those engaged in the food safety system so that by 2030 the Salmonella reduction targets have been met and exceeded, resulting in fewer people being impacted by foodborne illness.

We will be filling expanded written comments.

— Steven Mandernach
Executive Director of the Association of Food and Drug Officials