Why food safety inspection of poultry is on the wrong track

With health statistics in the United States showing no change in human salmonellosis since the introduction of Hazard Analysis and Critical Control Points 15 years ago, and despite a considerable reduction in incidence of Salmonella in raw products, what can be said about the failure of HACCP’s promise to reduce human illness?

Food Safety and Inspection Service data on Salmonella in inspected raw poultry are seriously flawed due to changing sampling and testing methods.
Food Safety and Inspection Service data on Salmonella in inspected raw poultry are seriously flawed due to changing sampling and testing methods.

With health statistics in the United States showing no change in human salmonellosis since the introduction of Hazard Analysis and Critical Control Points 15 years ago, and despite a considerable reduction in incidence of Salmonella in raw products, what can be said about the failure of HACCP’s promise to reduce human illness? The simplest conclusion is that pathogen reduction performance standards for Salmonella in the Pathogen Reduction: HACCP Final Rule have little or no relationship to the risk of getting a Salmonella infection from meat and poultry.

HACCP systems for inspection were recommended by several publications, including the National Research Council’s 1985 report, “Meat and Poultry Inspection: The Scientific Basis of the Nation’s Program.” Reviewing the National Research Council committee’s observations from 1985 might offer some insight into the current situation. In that report, the committee complained that it could find no systematic accumulation of data, no comprehensive statement of criteria, and no complete technical analysis of the risk to human health under different inspection systems.

Performance standards don’t relate to human health risk

Today, the Food Safety and Inspection Service has collected mountains of data concerning Salmonella in inspected raw products. With important exceptions, much of that is available from the Food Safety and Inspection Service website, but the expert committee in 1985 complained about the lack of “systematic” accumulation of data. The current Food Safety and Inspection Service data are seriously flawed due to changing sampling and testing methods in HACCP verification sampling for Salmonella.

Even worse, HACCP Salmonella sampling has never been conducted randomly and has become more arbitrary due to changes in sample scheduling, so regular program monitoring between baselines is of little use in analyzing the overall results. The Baseline sampling program is the most important measure of the success of the effort to control microbiological hazards, but those studies also suffer from major changes in sampling and lab methods that have never been documented to be comparable to the methods used in the original study conducted immediately before the start of HACCP.

Many Food Safety and Inspection Service reports acknowledge that HACCP Salmonella data cannot be used as estimates of national prevalence or serotype trends, even as the agency uses the HACCP data for exactly those purposes in other reports. The five most common serotypes usually cause between 50 percent and 60 percent of human salmonellosis in the U.S., but the Food Safety and Inspection Service insists that it is valid to be concerned about Kentucky, the 33rd leading serotype in human illness and the number-one serotype in chicken. The inclusion of Kentucky in the Salmonella prevalence rate for chicken guarantees that the calculated prevalence rate has no relationship to the risk of human illness, despite the use of Salmonella prevalence numbers by the Food Safety and Inspection Service.

Aesthetics and clerical details get emphasis

Along with the recommendation to adopt HACCP systems in meat and poultry inspection, the National Research Council also said that for inspection to be scientific, critical control points must be given “foremost importance over other control points related to aesthetic considerations or those considered as violations of regulations.” Nonetheless, under the current inspection system, control of visible fecal contamination before the chiller is a required critical control point for Salmonella even though carcasses with visible contamination have not been shown to have a greater risk of being Salmonella-positive. So the only required critical control point that HACCP plans must contain is based on aesthetic considerations.

In terms of technical violations of regulations being less important than actual risk, some plants are still being given Noncompliance Reports when employees put the date in the space for initials and initials in the space for the date in HACCP records.

Five false claims in the HACCP Rule

What about the technical analysis of risk to human health that the National Research Council could not find in Food Safety and Inspection Service materials in 1985? Concerning the microbiology of processing, the Pathogen Reduction: HACCP Final Rule makes many specific claims that are wrong:

  • False claim 1 : The processing plant is the first and main opportunity for fecal and pathogen contamination, which is “largely preventable.”
  • False claim 2 : 90 percent of contamination occurs in the plant
  • False claim 3 : 90 percent of the cost of human illness results from contamination in the plant
  • False claim 4 : E. coli = feces = pathogens
  • False claim 5 : Variation in E. coli counts and Salmonella prevalence indicates “in control” versus “out of control” rather than normal variation around a baseline set by the condition of incoming carcasses.

Faulty Food Safety and Inspection Service paradigm

The most troubling aspect of the Pathogen Reduction: HACCP Final Rule is the underlying philosophy that Salmonella is easy for the processing plant to control just by avoiding fecal contamination and using a few antibacterial chemicals. In fact, carcasses are already contaminated on arrival, and antibacterial treatments have their main effect on carcasses carrying low numbers of Salmonella, making them test negative by killing or injuring a few cells. The risk of salmonellosis is not reduced by increasing the number of false negative tests, even though that helps plants pass HACCP requirements.

The scientific literature indicates that processing plants cannot do much to control Salmonella if incoming flocks are contaminated, but the Food Safety and Inspection Service has changed the paradigm. The presence of Salmonella in samples now indicates “loss of control,” according to the Food Safety and Inspection Service. With so many basic fallacies in the technical analysis of Salmonella risk, it is unlikely that the current regulatory path will lead to reductions in human salmonellosis.

www.WATTAgNet.com/149881.html 

Without proven ways to reduce the risk of foodborne illness from poultry, USDA policy continues to be, “We have to do something.”

 

Salmonella link between humans and chickens is obscured , June, 2012

www.WATTAgNet.com/150810.html 

Seasonal and serotype differences in human and chicken Salmonella statistics confound efforts to characterize relationship between them by simple annual correlations.

 

HACCP sampling schedule affects Salmonella prevalence , August, 2012

www.WATTAgNet.com/152050.html 

Scheduling of HACCP verification samples can interact with seasonal variation to affect Salmonella prevalence estimates.

 

Changing methods in Salmonella sampling make comparisons uncertain , September, 2012

www.WATTAgNet.com/153482.html 

Un-validated changes in FSIS Salmonella sampling and lab methods make comparisons uncertain.

 

FSIS should release data on generic E. coli and Salmonella in poultry , October, 2012

www.WATTAgNet.com/153915.html   

The FSIS has a mountain of unreleased data on the supposed relationship between generic E. coli and Salmonella in poultry samples.

 

Regulatory HACCP in poultry: Still in search of the science , November, 2012

www.WATTAgNet.com/154766.html 

The basic microbiological assumptions for the argument that Salmonella can be controlled in the poultry processing plant have not been confirmed.

 

Unscientific thinking about Salmonella control hampers food safety progress , December, 2012

www.WATTAgNet.com/155220.html 

HACCP in poultry inspection has to be judged on its merits, not by what we wish that it might have done.

 

The problem with Salmonella prevalence testing in chicken , January, 2013

www.WATTAgNet.com/155828.html   

H ACCP Salmonella prevalence testing has no relationship to the actual risk of human illness associated with Salmonella in chicken.

 

HACCP used by poultry processors much different from NASA version , February, 2013

www.WATTAgNet.com/156288.html 

The two HACCP systems do not produce the same results, as shown by the failure of meat and poultry HACCP to reduce the rate of human salmonellosis.

 

Will tougher Salmonella standards for poultry reduce human illness? April, 2013

www.WATTAgNet.com/157659.html 

FSIS analyzes Salmonella trends in HACCP samples using data the agency has described as “no longer useful as an indicator of trends.”

 

Why food safety inspection of poultry is on the wrong track, June, 2013

Basic fallacies in the technical analysis of Salmonella risk make it unlikely that the current regulatory path in meat and poultry inspection will lead to reductions in human salmonellosis.

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