In recent comments submitted to USDA’s Food Safety and Inspection Service (FSIS), NCC said the agency’s proposed Salmonella Framework for Raw Poultry Products is based on a mischaracterization of the presence of Salmonella in raw poultry, relies on misinterpretations of the science, and is legally unsound.
“America’s chicken producers remain committed to further reducing Salmonella and fully support changes in food safety regulations that are based on sound science, robust data, and are demonstrated to positively impact public health,” said Ashley Peterson, Ph.D., NCC senior vice president of regulatory and scientific affairs. “We are concerned this proposal is not based on any of those.
“The key points for consumers are that: This proposal could increase the price of chicken without any health benefits; Salmonella rates on chicken are at all-time lows and chicken producers are working to reduce them even further; and all chicken is safe to eat when properly handled and cooked.”
In summary, the Proposed Framework:
- Will not adequately address human salmonellosis attributed to raw poultry;
- Will cause significant supply chain disruptions, food waste, food price increases, and environmental challenges, as well as national security concerns stemming from food and supply chain vulnerabilities;
- Is not reasonably implementable based on current technology limitations;
- Is not based on sound science; and
- Lacks legal footing.
To support Salmonella reduction efforts, the chicken industry has invested tens of millions of dollars or more in pathogen control measures for raw chicken products, including numerous preharvest intervention strategies to reduce Salmonella loads before chickens are processed. These strategies include robust programs in hatcheries, feed mills, and breeder and broiler houses, such as strict biosecurity protocols, equipment sanitation, feed and litter treatment, water sanitation programs, use of pre- and probiotics, pest control, cleanout programs, and vaccinations.
These efforts have been paying off. Salmonella prevalence rates at chicken processing plants are at all-time lows and the industry continues to exceed the government’s Salmonella performance standards. Taking into account a 48 percent increase in chicken consumption over the past 28 years, salmonellosis cases have decreased significantly on a per-pound basis of chicken consumption. Put simply, each pound of raw chicken is markedly safer today than 25 or 30 years ago.
“NCC urges FSIS to rescind the Proposed Framework and consider alternative approaches for addressing Salmonella in raw poultry products, mainly through the use of quantitative performance standards and statistical and process controls that the Agency could implement almost immediately and would have a direct and significant impact on public health,” said Peterson in the comments. “NCC and our members stand ready to work with FSIS on this.”
NCC comments also included an independent analysis by a leading veterinary public health expert that identified numerous flaws in USDA’s Risk Assessment. Further, NCC joined in commissioning an independent economic analysis that identified numerous deficiencies in FSIS’s cost analysis, which indicates that the agency has grossly underestimated the costs of the Proposed Framework by hundreds of millions, potentially billions, of dollars.
“The chicken industry shares FSIS’s goal of reducing the number of Salmonella illnesses resulting from raw poultry products,” Peterson concluded. “While the efforts and mission of the Proposed Framework are appreciated, it will not result in a significant public health benefit, is not legally tenable, and should be rescinded.”
NCC’s comments can be read in their entirety by clicking here.
