WASHINGTON – The Food Safety and Inspection Service (FSIS) of the US Department of Agriculture took a significant step in its plan to reduce incidents of Salmonella infections from the consumption of poultry products. FSIS released “a proposed determination” to declare Salmonella an adulterant in breaded stuffed raw chicken products when such products exceed a very low level of Salmonella contamination.
Under the proposal, any breaded stuffed raw chicken products would be considered adulterated after testing positive for Salmonella at 1 colony forming unit (CFU) per gram prior to stuffing and breading.
“USDA is taking science-based, decisive action to drive down Salmonella illnesses linked to poultry products,” said Agriculture Secretary Tom Vilsack. “Today’s proposal represents the first step in a broader effort to control Salmonella contamination in all poultry products, as well as a continued commitment to protecting American consumers from foodborne illness.”
FSIS plans to implement verification procedures, including sampling and testing of the chicken component of the product prior to stuffing and breading, to ensure processors control Salmonella in these products. The product lot represented by the sampled component would not be permitted to be used to produce the final breaded stuffed raw chicken products if the chicken component in these products does not meet the standard. Instead, the chicken component in the sampled lot would need to be diverted to a use other than breaded stuffed raw chicken products.
The National Chicken Council (NCC) expressed concern that the proposed policy shift would shutter poultry processing plants.
“NCC is gravely concerned that the precedent set by this abrupt shift in longstanding policy has the potential to shutter processing plants, cost jobs, and take safe food and convenient products off shelves, without moving the needle on public health.
“As these products often appear ready to eat, but contain raw chicken, we recognize their nature raises special considerations that merit additional attention. The National Chicken Council (NCC) and our member companies have invested millions of dollars and have worked for more than a decade to develop and refine best practices for these products to reduce Salmonella and protect public health. These efforts have been paying off, demonstrated by a significant decline in illnesses over the past seven years.”
FSIS first announced its intention to declare Salmonella an adulterant in breaded stuffed raw chicken products in 2022 as part of a proposed regulatory framework intended to help control Salmonella contamination in poultry products. Shortly thereafter, the National Chicken Council delivered its public comments to the agency.
FSIS based its proposal to declare Salmonella an adulterant in breaded stuffed raw chicken products on several factors. Breaded stuffed raw chicken products are pre-browned and may appear cooked. However, these items contain raw vegetables, butter, cheese, or meat such as poultry or ham. FSIS reasoned that consumers may have difficulty determining an accurate internal temperature of these products because they contain multiple ingredients that may cook at different rates.
Since 1998, FSIS and other public health agencies have investigated 14 Salmonella outbreaks and approximately 200 illnesses associated with these products. The most recent outbreak was in 2021 and resulted in illnesses across 11 states. Furthermore, the Atlanta-based Centers for Disease Control and Prevention (CDC) estimates that Salmonella bacteria cause approximately 1.35 million human infections and 26,500 hospitalizations in the United States every year. Of those infections, more than 23% are attributed to poultry consumption.
NCC noted one outbreak associated with these products since 2015.
“NCC estimates that on an annual basis, over 200 million servings of this product will be lost, 500-1000 people will lose their jobs, and the annual cost to industry is significantly higher than USDA’s estimates. It is likely that this proposal would drive smaller producers of this product out of business entirely.
“This administration has prioritized addressing concerns with food availability and affordability. This proposal would undermine these goals by driving up food costs, reducing the supply of convenient, nutritious chicken, and forcing lower-income consumers of these products to purchase more expensive alternatives.”
Consumer advocacy groups have urged USDA to go further and declare certain “outbreak serotypes” of Salmonella to be adulterants in all meat and poultry. Proponents of this strategy say it would encourage increased monitoring efforts and ensure public health and safety.
NCC added that USDA-FSIS’s rationale “… was not science-based and not driven by data, risk assessments, product testing or scientific analysis.”
Industry stakeholders countered that not all Salmonella serotypes impact public health. Research projects are underway to determine whether reductions in foodborne illness can be achieved by regulating Salmonella and poultry using metrics that account for different impacts of specific strains, or high levels on the risk of the disease, according to Denise Heard, DVM, MAM, ACPV and vice president, Research Programs at the US Poultry & Egg Association (USPOULTRY), Tucker, Ga.
“Going back to the passage of the Poultry Products Inspection Act in 1957, the mere presence of Salmonella has not rendered raw poultry adulterated,” NCC said. “We believe FSIS already has the regulatory and public health tools to work with the industry to ensure the continued safety of these products. We’ve been asking the agency for years to collaborate on these efforts, including two petitions for stricter regulations, requests that have gone largely ignored.
FSIS acknowledged that labeling of breaded stuffed raw chicken products has changed significantly over time to better inform consumers that the products are raw and to provide instructions on how to prepare them safely. Despite improvements, these products continue to be associated with Salmonella illness outbreaks.
“Additionally, data from outbreaks and FSIS’ consumer research show that some people may not realize these products contain raw chicken because the outside may appear browned and cooked, which leads them to believe that the product is safe to eat as is or not cook the product to a safe internal temperature,” the agency added.
“There is no silver bullet or one-size-fits all approach to food safety, which is why we employ a multi-stage strategy,” NCC said. “The only way to ensure our food is safe 100 percent of the time is by following science-based procedures when raising and processing chicken, and by handling and cooking it properly at home.
“NCC remains confident these products can be prepared and consumed safely, and the industry remains committed to continuing their efforts to further enhance the safety of these products.”
FSIS is seeking public comments on the proposed determination and the proposed verification sampling program. Comments must be received within 60 days after publication in the Federal Register.