The National Chicken Council on Monday submitted comments to the Food Safety and Inspection Service (FSIS) on “Changes to the Campylobacter Verification Testing Program: Revised Performance Standards for Campylobacter in Not-Ready-To-Eat Comminuted Chicken and Turkey.”
“NCC member companies are deeply committed to food safety,” wrote Ashley Peterson, Ph.D., NCC senior vice president of scientific and regulatory affairs. “Chicken processors implement a wide variety of interventions to control and reduce Salmonella throughout the production continuum, and they take Campylobacter reduction just as seriously. NCC recognizes that developing performance standards is complex and raises numerous scientific and policy issues. Our collective scientific understanding of Campylobacter is limited and there are key research gaps that need to be addressed. Because so much remains to be learned about Campylobacter, industry needs appropriate time to adjust to the new performance standards once they are finalized and to continue to research and refine intervention strategies. We know that Salmonella and Campylobacter are very different bacteria and respond differently to reduction and control strategies, but many scientific gaps remain to be filled. Finally, at a fundamental level, NCC believes that all regulatory actions related to food safety, including performance standards, must have a demonstrable benefit to public health.
The comments address how the proposed performance standard was developed, implementation issues, and enforcement issues. In particular, NCC urged FSIS to tailor the Campylobacter performance standard to reflect differences in bird size, to adopt a single uniform effective date for all the Campylobacter standards under development, and not to post establishment-specific information without at least providing a meaningful opportunity for establishments to adjust to the new performance standard.
The comments can be found in their entirety by clicking here.
