Since the Jack-in-the-Box tragedy so many years ago involving E. coli O157:H7, USDA pathogen reduction initiatives have come and gone with some regularity. A few, though introduced with much fanfare in their day, were so flawed that they were effectively dead on arrival. They were inert. Not much more than words on paper. Not all, but at least a couple in the early days after the tragedy. It wasn’t that intentions were wrong on the part of USDA or the industry, but the so-called “war on pathogens” brought USDA and the industry up against a formidable enemy on a battlefield that has belonged to that enemy since time began.
So, is it hubris for USDA officials to stand up today and say to the poultry industry about salmonella reduction, ‘We have the answers. The battle is ours’? We’ve heard that clarion before, though perhaps with less steel than this time around.
USDA’s Under Secretary for Food Safety recently said, “We’ve got a new Administrator, a new Deputy Administrator, a new Under Secretary and a new Secretary, and we believe strongly that it is going to happen this time.” Of course, the “it” to which Dr. Richard Raymond refers is salmonella reduction. And he continued, “And we’re going to tell you how, and we’re going to tell you why.” I must admit that this last utterance left me musing, “Oh, really?”
Can FSIS bring the approach that worked to reduce E. coli O157:H7 in beef to the poultry industry and make it work to reduce salmonella? The inputs, rearing programs, processes and animals are dissimilar in the two industries.
Speaking on the same podium as the Under Secretary, Richard Roop, senior vice president of science and regulatory affairs for Tyson Foods, put his finger on a central problem that has plagued past pathogen reduction campaigns. Processing factors that USDA addresses in its regulations haven’t made a difference on the pathogen battlefield. Dr. Roop, for example, exposed a fallacious tenet of the Pathogen Reduction/HACCP rule – that fecal contamination is a major vehicle for spreading pathogenic organisms such as salmonella in poultry. Equally fallacious was the rule’s reliance on fecal contamination being a reliable indicator of the likely presence of microbial pathogens. He cited well-known research studies to support these points.
“I think the important point here is that it’s important to focus on visible fecal contamination from a quality and a regulatory standpoint, but don’t focus on visible fecal contamination in an effort to reduce salmonella,” Dr. Roop concluded.
So where can our common enemy, salmonella, be effectively engaged? This, in fact, is where my outlook on the new salmonella reduction initiative turns hopeful – if not positive. It appears that FSIS officials seem to believe that their “answers” lie in creating the regulatory atmosphere where individual companies and plants have an incentive to find the answers. This approach recognizes the complexities involved in producing poultry and the differences among the industry’s products, processes and plants.
There are other issues, however, that are of concern about the agency’s approach, and one was touched on by Randy Huffman, vice president of scientific affairs for the American Meat Institute Foundation. He provided insight from the beef industry’s experience that may be of value to the poultry industry and FSIS.
Dr. Huffman noted, “Better data about processes will lead to more effective control measures, and these data can be used to verify that best practices are working.”
At the same time, the agency isn’t hiding the fact that it intends to keep the pressure on industry in order to drive change – partly by releasing various performance data to the public. Fostering openness and data sharing on the part of industry is not compatible with applying pressure – especially when the agency has already stated one of its tactics will be to use data as a stick.