USDA’s Food Safety and Inspection Service (FSIS) published a Federal Register Notice (FR) in January 2008 detailing the Salmonella Initiative Program (SIP). Thirty days later, as the public comment period for the FR Notice was closing, FSIS announced its intention to reopen the comment period and issue another Notice to address aspects of the SIP that had prompted a multitude of questions. Now, a year and a half has passed, and the poultry industry is still awaiting publication of the next SIP FR Notice.
So, where is the SIP today? Through mid-March of this year FSIS has continued to issue “no objection” letters in conjunction with the program. That’s despite the fact that USPOULTRY and two other poultry trade organizations wrote FSIS Administrator Alfred Almanza, in late August 2008, requesting that the Agency immediately publish a new SIP FR Notice that would give each waiver request equal weight and consideration, address all questions/concerns previously submitted in response to the original SIP Notice and be completely open to public comment for a period of no less than 60 days.
While questions and concerns over the sharing of industry data, salmonella isolates, etc., as well as the manner and timeline for addressing previously existing waivers are critical, they by no means constitute the entire list of unresolved issues associated with the first SIP FR Notice. Numerous, very specific, questions about SIP criteria were submitted by the poultry industry in response to the first FR Notice. These questions include the frequency of required daily testing, available testing methodologies, FSIS evaluations of laboratories that perform microbial testing for establishments, and the action(s) establishments should expect if/when the FSIS determines a “match” to have been made when comparing serotype and PFGE subtype patterns of isolates against clinical isolate patterns in PulseNet, If the Agency chooses not to address, and/or will not allow public comment on, these issues in the next SIP FR Notice, then such questions will persist, and continue to serve as impediments to the implementation of this program.
Presently, only certain aspects associated with the SIP have been defined, and only with those few stakeholders who have been granted waivers. This has made it extremely difficult for all but a handful of establishments to make an informed decision regarding whether or not they should participate in the SIP. It has also caused many to postpone, or abandon, plans to improve their processes for fear that such modification will force them into a program they do not completely understand and have had no voice in helping to create. Consequently, if the FSIS insists on continuing to pursue its current course with respect to the SIP, the Agency runs the considerable risk of helping to establish food safety as a competitive issue within the poultry industry.