In recent years, we have seen a gradual uptick in the robustness of USDA’s and FDA’s approach to pathogens in the food supply. On the USDA side, the agency has continued is long march against Salmonella in raw poultry products, culminating in the more recent rules declaring Salmonella to be an adulterant: (1) in raw breaded stuffed chicken products when they exceed a specific threshold (1 colony forming unit (CFU) per gram or higher) for Salmonella contamination; and (2) in raw chicken and ground poultry products generally.  

The first rule, which has now been finalized by the agency, was recently followed by the second proposed rule, which states that raw chicken carcasses, chicken parts, comminuted chicken and comminuted turkey are adulterated if they contain any type of Salmonella at or above 10 colony forming units (CFU) per milliliter (mL) or gram in analytical portion (i.e., milliliter (mL) of rinsate or gram of product), and contain any detectable level of at least one of the Salmonella serotypes of public health significance. For raw carcasses, chicken parts ,and comminuted chicken proposed rule identifies the Salmonella serotypes Enteritidis, Typhimurium and I 4,[5],12:i:-. For raw comminuted turkey proposed rule identifies Salmonella serotypes Hadar, Typhimurium, and Muenchen.

With its targets focused on Salmonella, USDA has also been more actively involved than ever in Listeria control. Since the Boar’s Head outbreak, which reportedly has led to the deaths of 10 people and sickened dozens of others, developed on the heels of alleged violations in the company’s Jarratt, Va., facility.  In response, USDA not only focused its resources heavily on the facility in question, but also fanned out across the US, demanding to review microbiological testing data from wide swaths of USDA-regulated food manufacturers. We also see the agency broadening its definitions of Zone One food contact surfaces and, when contamination is found in the environment, requesting that recalls be expanded to include larger amounts of product produced on seemingly unaffected lines.

The same has been true on the FDA side, as well, with the agency continuing its aggressive march against Listeria in food facilities. Here too, the agency continues to operate on a three strikes and you’re out basis, considering the issuance of Warning Letters to food companies when the agency cultures the same strain of Listeria from a processing environment over subsequent inspections.  Like USDA, we have also observed FDA require recalls to be broadened to include seemingly unaffected lines or products when Listeria is cultured generally in the food processing environment.

So, what does this mean for industry?  It means that the federal agencies will continue to tighten the chains on food companies as they continue to wage their war on pathogens. So, in order to avoid becoming the next victim of USDA’s or FDA’s Fight for Food Safety, now would be the time to invest additional resources into pathogen elimination and control in your food facilities, production lines, and finished products.