John Cason retired from the Agricultural Research Service of the USDA in December 2011 after 40 years in poultry-related jobs, including two years working with chickens as a Peace Corps volunteer. He spent the last 21 years investigating poultry processing and food safety issues as a research physiologist at the Russell Research Center in Athens, Ga. His PhD is from the University of Georgia.
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?
Despite all of the Salmonella data collected by different agencies, there is no clear evidence that HACCP has reduced the incidence of human salmonellosis or that a further tightening of HACCP standards will produce an improvement in the future.
La determinación de la cantidad de células de Salmonella en muestras de enjuague de pollo sale cara, por lo que generalmente en dichas muestras sólo determinan la presencia de este microorganismo, con lo cual los resultados notificados son de prevalencia o el porcentaje total de muestras positivas.
The Hazard Analysis & Critical Control Point system used today by meat and poultry processors, as regulated by the Food Safety and Inspection service, is much different than the version of HACCP as developed by Pillsbury and NASA in the late 1960s.
Several recent scientific papers have concluded that only limited data are available to judge whether national Salmonella control programs have had an impact on human illness rates. There is no limit, however, on the supply of speculative interpretation that is available, including a common style of analysis that can be described as unscientific thinking.
The 1996 Pathogen Reduction: Hazard Analysis and Critical Control Point Final Rule was one of the earliest claims that processing plants can control the prevalence of pathogenic bacteria such as Salmonella on raw meat and poultry. Previously, most authorities believed that Salmonella controls could be successful only at the farm level or in post-processing kill steps such as cooking or irradiation.
The Food Safety and Inspection Service has a mountain of unreleased data on the supposed relationship between generic E. coli and Salmonella in poultry samples. FSIS should release the data immediately.
In January, the Food Safety and Inspection Service published a proposed rule, “Modernization of Poultry Slaughter Inspection,” with important changes in the rules of processing, including the intention of FSIS to drop the requirement that plants test chilled carcasses for E. coli. Individual establishments will be allowed to use “other, more relevant” but unspecified indicators of process control, with individual HACCP plans identifying what bacterial monitoring is to be done. Dropping the E. coli testing requirement is a sharp departure from the dogma of poultry HACCP as mandated by FSIS in the last 15 years.
How has Salmonella prevalence changed in poultry since the implementation of Hazard Analysis Critical Control Point regulations by the Food Safety and Inspection Service in 1998? Nobody can say with assurance. Comparing test results over time demands continuity in testing methods. Unfortunately, the lack of continuity in regulatory sampling of raw meat and poultry makes it impossible to say with any confidence exactly how Salmonella prevalence has changed in the last 15 years.
The Food Safety and Inspection Service says that the Hazard Analysis and Critical Control Point system is the foundation of its “strategic, data-driven inspection program,” but scheduling of HACCP verification sampling sometimes drives the Salmonella data. A limited amount of quarterly Salmonella information is available for analysis, but it shows the limitations of the Salmonella prevalence data that the service uses to justify policy.
Government agency websites and peer-reviewed papers continue to search for a correlation between annual figures for human salmonellosis and Salmonella prevalence in HACCP regulatory samples over the last 15 years. Testing for correlations in annual Salmonella numbers has the problem that these figures typically include all data with no recognition of known sources of variability in the numbers. Both FoodNet and HACCP Salmonella data, for example, show distinct seasonal variation with large numerical and temporal differences between high and low points.
The Food Safety and Inspection Service has stated an intention to “drive down human illness rates” by reducing Salmonella prevalence in meat and poultry. The link between human illness and Salmonella in meat and poultry is not so clear, however. Food Safety and Inspection Service activities can reduce human illnesses only by the number of cases being generated by meat and poultry, and reductions in prevalence in raw meat and poultry will have no effect on human illness unless the method of measuring Salmonella prevalence is related to the risk of human illness.