Dr. Alling H. Yancy, vice president, food safety and production programs for the U.S. Poultry and Egg Association recently outlined the proposed policy of the FSIS regarding Salmonella Enteritidis (SE) in broilers. Addressing an attentive audience at the North Carolina Poultry Health Meeting in early November, Yancy raised a red flag and urged preemptive action to avert a crisis in the broiler industry.
The intended action by FSIS on SE was telegraphed by Dr. Dan Engeljohn, then Deputy Assistant Administrator of the FSIS, in a presentation made on January 28, 2009, at a meeting of the General Conference Committee of the National Poultry Improvement Plan. In his address, Dr. Engeljohn announced a new FSIS initiative aimed at reducing the prevalence rate of SE in broiler carcass rinse samples.
Dr. Engeljohn’s 2009 presentation included the following statements, “Know that broilers, not eggs, are a primary source for SE” and “There is no known industry-wide or collective focus on addressing SE.” Those statements were reinforced by a subsequent comment, made earlier this year, which indicated the FSIS had considered the notion of declaring SE an adulterant. All of these comments have potentially ominous implications for the broiler industry. It is apparent that the FSIS is of the dubious opinion that SE can be prevented from entering the food chain and that on-farm controls are practical and feasible.
FSIS puts focus on plants
It seems the FSIS intends to target SE and collect information on the prevalence and source of the organism in rinse samples collected in plants. Concurrently, the FSIS has proposed to correlate available public health information from sources local to plants where SE is found in an attempt to define the epidemiology of SE outbreaks.
This appears to be a superficial and unproductive approach since processing plants distribute their products through wide geographic areas and to diverse consumer and institutional segments. The situation is further complicated by the range of items the industry’s plants produce including whole birds, carcasses, cut-up and further processed items It is noted that with respect to the U.S. only 50% of SE outbreaks can be attributed to a specific vehicle, and data obtained from FoodNet suggest that approximately 64% of outbreaks of SE occur where the transmission is identified as from eggs.
Tracking from plants to grow-out farms?
It is understood that the FSIS may attempt to identify individual growers with a “prior record of SE” and that it will then be necessary to address SE as a hazard by applying HACCP principles. If so, Dr. Yancy suggested that the FSIS will effectively extend its authority from the plant backward into live production. This is a fallacious approach, since experience gained in the industry demonstrates that SE infection is vertically transmitted. It is expected that individual grow-out farms may become contaminated, but there is no practical or available modality that can be used to consistently eliminate Salmonella infection in earth-floored broiler grow-out housing.
Lessons available from egg industry experience
The industry must obviously take the initiative, and identify objectives and develop appropriate programs to develop a realistic strategy to address SE. It is noted that the U.S. egg industry through its producer association developed a patently defective and self-serving surveillance program, which did little to reduce the prevalence of SE in commercial flocks. Inactivity, self-deception based on a concern for costs and denying the epidemiologic realities of SE infection in consumers of eggs, resulted in the Food and Drug Administration developing and implementing the “Final Rule” to reduce the incidence rate of SE in consumers. This mandate now forces producers to perform regular assays, and divert eggs to breaking and pasteurization if a two-step detection process, involving an environmental screen and assays of egg pools, confirms the presence of SE in flocks.
Broiler industry to take initiative on SE
The U.S. Poultry & Egg Association took the initiative to identify poultry industry specialists who developed a voluntary SE monitoring program for parent broiler breeder flocks that was recently adopted by the General Conference Committee of the National Poultry Improvement Plan (NPIP) at its 40th biennial conference. This group of specialists comprises representatives from the American Association of Avian Pathologists, the National Chicken Council, the Association of Veterinarians in Broiler Production and the USA Poultry and Egg Export Council. A program is necessary to counter the contention that there is “no known industry-wide or collective focus on addressing SE.” Establishing a structured and consistent SE-Monitored Program under the NPIP will gather data on the prevalence of SE in broiler production and will help facilitate development of appropriate countermeasures.
Vertical transmission dictates focus on breeders
Based on the fact that SE is vertically transmitted, prevention programs must focus on parent breeding. The NPIP SE monitoring program does just that, and does not designate specific corrective actions or preventive measures that must be taken following isolation of SE as a result of the requisite assays.
Dr. Yancy urged the formation of a poultry industry coalition to address SE and indicated he was actively in the process of doing so. The primary purpose of such a group would be to gather and present scientific evidence and economic justifications to oppose the previously proposed FSIS SE policy and offer an alternate, more meaningful approach to address the risk of this food safety hazard associated with chicken meat.
The experience of the egg industry should be a salutary lesson to broiler producers. Unless a viable, practical and economically sound program is developed and implemented by the broiler industry, it is obvious that regulatory agencies will impose draconian rules, which will seriously impact efficiency and profitability.
