I was teaching Poultry 201 last week in Dallas. It was a great course. As usual, we had a lot of great discussions and engagement with all the attendees on several topics including marination troubleshooting, ingredient functionality, batter and breading, frying temperatures, and yield. I learned just as much from each of the attendees as they did from us.

After these courses I always think about my biggest takeaway. I didn’t have to think much, as my mind immediately focused on food safety. During this talk, we discussed Appendix A and B changes (especially Appendix A regarding humidity) and the proposed framework for controlling Salmonella in poultry with the upcoming notice of public hearing. I asked a simple question, “What do y’all think?” Silence, followed by more silence. The information filter to this level of the industry (supervisors, superintendents, engineers, R&D, ingredient suppliers, etc) was very minimal, and I am not going to lie — I was flabbergasted.

We discussed in more detail the proposed framework including Salmonella as an adulterant in breaded and stuffed raw chicken products, the proposed limit at 1 colony forming unit (CFU) of Salmonella per gram for these products, notice of public hearing (Docket No. FSIS-2022-0029), and the details of the proposed framework. It includes three components:

Component 1: Requiring incoming flocks be tested for Salmonella before entering an establishment
Component 2: Enhanced Establishment Process Control Monitoring and FSIS Verification
Component 3: Enforceable Final Product Standard

After discussing in more detail with the attendees, there were more questions and more engagement about how this could impact each employee. Discussions ensued and people really became engaged, even during breaks and after the course.

I remember trying to engage equipment companies, engineers, R&D, and allied industries in the Appendix A and humidity discussions and they were vaguely aware (if at all) about what was happening in Washington DC regarding regulatory changes. Many of them missed a significant opportunity to explain the why or why nots by providing data regarding the impact of the proposed regulations on feasibility, cost, impact on labor, equipment functions, etc. during the comment period.

I cannot emphasize this enough: This public hearing is a time where everyone needs to speak up as individual establishments affected by these proposed changes. I can assure you that FSIS reads every comment and considers each submission. I understand that companies may not want each individual employee to respond to a comment, as that would be chaos and non-cohesive; however, each company affected directly or indirectly needs to have open discussions and comment. Beef and pork need to comment, as well. This proposed framework affects all of us.

I am asking our industry to use your voice and submit comments with scientifically valid data and reasons regarding the why or why nots. Whether you agree with the proposed framework or not is irrelevant. Industry has data and industry knows the feasibility of executing this proposed framework — what works and what doesn’t. This is your time to speak up and use your voice to engage FSIS with actual data to support or to negate any of the proposed framework components. Each individual company should be having discussions at all levels and all facets of the company to determine the impact of this proposed framework.

The notice of the public hearing is Thursday, Nov. 3, from 10am-4pm EST. The comment period is currently open, and all comments must be submitted by Nov. 16. Click here for more information.

Public meeting alert: Time to speak up

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