Since 1957, the United States Department of Agriculture, or USDA, has been inspecting poultry produced in the United States. In 1957, the emphasis was on visible defects in the poultry carcasses as they progressed along the inspection line, and to a large part that remained unchanged until very recently. Since 1957, however, with scientific knowledge and understanding growing every day, the emphasis has slowly shifted to an understanding of the presence of microscopic organisms whose presence cannot be visually captured. Now, the USDA is taking additional steps to update the types of requirements that poultry producers are obliged to follow – with the most recent changes being implemented this year. Ironically, while the linkage between these new policies and the long Salmonella Heidelberg outbreak that has plagued West-coast producer, Foster Farms, is not linear, few food safety advocates would deny that these changes are long overdue.
Foster Farms, like other poultry producers, has a choice among five inspection protocols, with each grower opting for the one that best fits its operation. The most recent protocol, aptly called the New Poultry Inspection System, was added this year. And even though poultry producers may still opt for one of the previous four protocols, regardless of the protocol, all poultry producers are obliged to conform to the newly updated pathogen control and testing requirements that have also been implemented this year (some of the key provisions are discussed below).
The New Poultry Inspection System, or protocol number 5, is unique in several ways, representing the culmination of a 15 year pilot program aimed at developing the best system for the reduction of food borne illness inducing pathogens like Salmonella and Campylobacter. The New Poultry Inspection System has proven to generate higher compliance scores in sanitation, greater compliance with HACCP regulation, and equal or lower levels of the presence of Salmonella bacteria. It is the first inspection protocol that stations the online poultry inspectors at the end of the process, relying almost completely on company employees to performed their inspections properly during the production process. As such, it requires fewer inspectors than the other four protocols, with inspectors no longer assisting in sorting the carcasses during the production process. The idea is that inspectors, who might have allowed partially contaminated chicken to progress along the production line in anticipation that proper sorting would occur at a later stage, are no longer used. Instead, all online inspectors are stationed at the end of the process to verify the safety of the poultry and to engage in oversight of the company’s own activities to control the spread of deadly pathogens like Salmonella and Campylobacter. These end-of-production inspectors will have a zero-tolerance for fecal contamination as no other action is foreseeable at this stage of the production.
Under the New Poultry Inspection System, USDA has assured food safety advocates that offline FSIS inspectors will continue to engage in the activities they have traditionally conducted, including: pulling 10 carcasses per hour from production lines to assess for the presence of fecal matter and proper slaughter and/or cleaning; verifying compliance with sanitation standard operation procedures; verifying compliance with sanitation performance standards; and enforcing the zero-tolerance for the visible presence of fecal matter or material. USDA anticipates that FSIS inspectors will be able to perform these tasks with greater regularity under the New Poultry Inspection.
Meanwhile,under the new regulations governing all poultry producers whether they opt of the newest protocol or participate in one of the previously promulgated four protocols, all producers will be required to:
1. Treat Salmonella as a food safety hazard and establish effective controls over its presence in their product or face suspension of activities; and
2. Conduct microbial testing at two stages of the slaughter/production process, and to specifically include salmonella in that testing;*
*Previously, only one test was required, and only generic E. coli was targeted for testing. Even now, very small operations will only be required to conduct one test, but again, Salmonella will be among the pathogens tested for. The offline inspectors with the Food Safety and Inspection Service (FSIS) will continue to conduct their own microbiological testing in support of company testing.
The USDA anticipates that these new protocols, along with reliance upon more thorough end-of–production inspections for those who employ protocol number 5, are more likely to produce a lower occurrence of Salmonella and other pathogens than previous regulatory requirements.
“These new regulations are long overdue,” says Ron Simon, a food safety lawyer who is representing victims of the Foster Farms Salmonella outbreak that has sickened many hundreds of consumers in over 25 states in the last two years. According to Ron Simon, the emphasis on Salmonella as a “food safety hazard” under the new regulations finally, and appropriately, places the proper emphasis on food safety that producers like Foster Farms have been ignoring. “The fact is,” says Simon, “these producers will do only as much as they are required to do to prevent food borne illness.”
