The administrator of the U.S. Department of Agriculture Food Safety and Inspection Service (USDA FSIS) established the Strategic Performance Working Group (SPWG) to solicit and coordinate ideas to improve agency performance. The SPWG decided to evaluate Salmonella control measures in meat and poultry production, because, nearly two decades after the implementation of hazard analysis and critical control points (HACCP) in poultry and red meat slaughter facilities, human Salmonellosis cases attributed to meat and poultry products have not declined. The SPWG’s recently-released Salmonella Action Plan puts it succinctly: “Salmonella illness estimates have continued at a steady high or slightly increased rate, despite FSIS interventions.”
Since the rate of human Salmonellosis cases aren’t declining, it really does seem to be time to try something different. Unfortunately, in many ways, the FSIS’s Salmonella Action Plan is just a re-emphasis of the same strategies that the agency has already employed. A case in point is the establishment of more Salmonella performance standards based on generic Salmonella incidence rates for more product categories and continuing tightening of the existing product category standards. Because of this, the poultry industry will continue to put effort into reducing Salmonella numbers of serotypes that are not known to be human pathogens. The processor then stays comfortably in Category 1 and keeps his plant off the naughty list on an FSIS website, but the goal is supposed to be healthy people.
From the description given in the Salmonella Action Plan, the SPWG was trying to get ideas from throughout the FSIS and really attack the problem from all angles. To me the obvious “outside the box” tactic is to try a targeted approach to Salmonella control. Pick the top three or four Salmonella serotypes in terms of causes of human illness attributed to poultry over the last decade and set a performance standard to work towards virtual elimination of these serotypes. Who cares if a poultry complex reduces the incidence of Salmonella Kentucky by 90 percent but still has Heidelberg or enteritidis coming into the plant?
Shouldn’t we work together?
Another aspect of the Salmonella Action Plan that disappointed me was the strict teacher-versus-the-naughty-children tone expressed in action items five and seven. From action item five in the plan:
“Data indicate that posting the names of broiler and turkey establishments that are in Category 3 for Salmonella set results led to improved control of Salmonella in those establishments. FSIS ceased web-posting of Category 2 establishments as of June 2011. Data collected by the Agency since then, however, do not show continuous improvement in industry performance, and FSIS believes that making more information about the process control performance of these establishments available will provide a valuable incentive for industry to improve process control.”
Does the agency really think that “spare the rod and spoil the child” is the strategy that is going to drive continuous improvement in food safety? Ramping up the threats to processors isn’t the best way to encourage sharing of data and the free flow of ideas. I think that a more collaborative approach, including the industry in the process, would be more successful.
I welcome your comments on the Salmonella Action Plan. I haven't fully digested it, and I hope that there are some good aspects that I haven't recognized yet.