The trade group addressed three components from FSIS, starting with incoming flocks being tested for Salmonella before entering an establishment.
Ashley Peterson, PhD, NCC’s senior vice president of scientific and regulatory affairs, told the agency how the preharvest testing was the biggest concern and could potentially impact the welfare of the birds along with limiting the supply of chicken.
“This component risks reverting to a long-abandoned command-and-control approach whereby FSIS inspectors make decisions about how plants operate,” Peterson said. “In this time of extreme inflation coupled with ongoing food security challenges, a command-and-control approach will do nothing to improve public health, it will only remove chicken from the meat case.
The second component brought up by the FSIS was enhancing establishment process control monitoring and FSIS verification.
Peterson stated that the industry should be expected to control potential pathogens but there is no one-size-fits-all tactic.
“Overall, this approach will stymie innovation and technology which seems counter to a collaborative food safety approach,” Peterson said during her comments on component two. “She recommended FSIS use verification sampling results, to include enumeration results, in a risk assessment model to help understand what impacts, if any, changes in indicator organisms and/or Salmonella load at various processing locations will have on public health.”
The third component laid out by FSIS was implementing an enforceable final product standard that considered whether Salmonella should be regarded as an adulterant at certain levels and/or types of Salmonella.
Peterson urged FSIS to build on the successful path established through performance standards with the industry and agency collaborating to meet voluntary standards.
“However,” she added, “we do not believe that the Poultry Products Inspection Act provides statutory authority to create an enforceable, adulteration-based final product standard for Salmonella in raw poultry … After scientifically determining the impact on public health, FSIS could consider a quantitative approach and give industry the opportunity to meet an enumerative performance standard.”
Peterson also expressed NCC’s appreciation for FSIS’s interest in data sharing.
“We believe it is critical that we all start with robust data, and from there collaborate on the best way to approach Salmonella control,” Peterson stated. “We look forward to a continued meaningful dialogue with FSIS on the proposed Salmonella framework and are hopeful we can come up with a science-based, data-driven approach that will not only improve public health but also ensure that consumers of America’s favorite protein still have an affordable product available to feed their families.”