NCC today filed comments to USDA regarding its recently Proposed Framework for Salmonella in poultry production.
USDA’s Food Safety and Inspection Service (FSIS) on October 17 announced a new Proposed Framework for controlling Salmonella in poultry production along with a virtual public meeting.
In addition to the meeting, which provided very limited stakeholder feedback on the wide-ranging proposal, the Agency also made public a comment docket for stakeholders. Comments were due on December 16 after the Agency granted a one month delay.
While the Proposed Framework is not a proposed rule, it demonstrates an approach FSIS is likely to take in future rulemaking. The Proposed Framework primarily consists of three components that FSIS views as a “comprehensive approach to controlling Salmonella in poultry,” namely:
- Requiring that incoming flocks be tested for Salmonella before entering an establishment;
- Enhancing establishment process control monitoring and FSIS verification; and
- Implementing an enforceable final product standard.
NCC’s comments outlined the enormously successful efforts the industry has made in driving down Salmonella rates in recent years in conjunction with significantly tightened existing Salmonella performance standards, a new scientifically driven modernized poultry inspection system, and numerous new interventions to control Salmonella.
“As with FSIS,” NCC’s comments said, “food safety is a top priority for the broiler chicken industry, and we support changes in food safety regulations that are based on sound science, robust data, and are demonstrated to positively impact public health. For years the industry has implemented a multi-hurdle approach focused on the continual reduction of Salmonella from farm to fork – implementing robust vaccination, biosecurity, sanitation, and other effective measures.
“While NCC appreciates FSIS’s interest in thinking creatively about food safety issues, the Proposed Framework is not the right approach,” NCC’s comments said.
“First, the Framework appears premised on legally infirm conclusions that Salmonella may be considered an adulterant in raw poultry and that FSIS can mandate on-farm activities,” the comments continued. “Second, the Framework is presented nearly devoid of data, and it lacks the specifics as to how the Agency plans to implement and enforce the proposed changes.”
There appears to be a “significant misunderstanding about how the broiler industry operates, the industry’s supply chain structure, and current industry practices regarding the control of Salmonella,” the comments said of the Framework.
However, “as written,” the comments concluded, “the Proposed Framework threatens the economic viability of the entire poultry sector and threatens negative impacts on family farmers, company employees, and consumers. It would have negative impacts on both the availability of chicken and the cost of chicken to consumers of U.S. chicken around the world.”
NCC’s full comments can be found here.
