Sometimes, when we are giving specific tasks that require immediate attention, we get so busy working on completing these tasks appropriately that we lose sight of our long-term objectives. I recently attended the Poultry Federation’s Salmonella Summit, and even though the focus was on Salmonella control for broilers, some of the talks got me refocused on food safety objectives for eggs.
The U.S. Department of Agriculture Food Safety and Inspection Service performance standards for Salmonella in broilers are based on the number of carcasses that test positive for any Salmonella on a post-chill carcass test. Each Salmonella serovar counts the same on this test; the idea was that there would be a public health benefit derived from reducing the total Salmonella “load” (number of cells) on carcasses, which was expected to be correlated with the number of positive birds in a given sample.
The broiler industry has added a number of chemical rinses, dips and chiller treatments to reduce the Salmonella loads on carcasses and has had success in reducing the percentage of positive carcasses post-chill. Public health data doesn’t suggest that human salmonellosis cases have been positively impacted by the efforts of poultry processors even though performance standards have been lowered and met by the industry.
There was criticism of the performance standards presented at the meeting from a statistical standpoint. The argument is that it is the Salmonella load and the type of Salmonella (some serovars aren’t human pathogens while a few are highly pathogenic) on the carcass that matters from a public health standpoint, more so than whether or not a given carcass has one cell on it.
Keeping your eye on the ball
This debate got me thinking again about Salmonella control for table eggs and the difference between regulatory compliance and protecting public health. There has been discussion in the egg industry about FDA statements regarding Salmonella Heidelberg and where control of this Salmonella serovar fits into compliance with the Salmonella enteritidis rule. Every egg producer has to meet regulatory standards in order to ship products, that is a given, but egg producers have another, more important standard that they have to meet.
As producers of food for human consumption, the responsibility for the safety of eggs lies on producers, not regulators. If there is reputable scientific evidence that the presence of specific microorganisms inside the egg represents a significant health risk to consumers and that these microorganisms may be found on layer farms, then the industry should consider these in the hazard analysis in their HACCP plans. It is up to the producer to interpret the science and decide if a given microorganism is enough of a risk that it should be tested for in the house environment, egg, bird or packing plant. A HACCP plan is a living document, and it should be updated as the science progresses.
Today’s task for an egg producer may be assuring regulatory compliance, but the long-term goal should be ongoing improvement of food safety. If the egg industry pursues continuous improvement in food safety, egg producers will always be in compliance.