How time flies. In 1994, on the heels of the Jack-in-the-Box outbreak, USDA publicly declared, in a policy statement, that it would deem the presence of E. coli O157:H7 in ground beef to be an adulterant. That declaration literally changed the beef industry overnight, forcing companies to begin testing their beef trim for the presence of the pathogen. That policy has since evolved, extending, logically, to other non-intact products, such as mechanically tenderized and needle injected steaks. In the years that followed, USDA further extended its adulteration standards to include other non-O157:H7 STECs, such as E. coli O26, O45, O103, O111, O121 and O145.

Now, in the beginning months of 2023, USDA has proposed, for the first time ever, to deem the presence of Salmonella in certain poultry products to be an adulterant. While I have routinely predicted in my nearly 15 years writing for Meatingplace that the agency would eventually cross this line, I must admit I was nevertheless surprised when I first heard the news. Is this really happening, I asked myself?

Yes, it is. Speaking very generally, under the new proposal, any breaded stuffed raw chicken products that test positive for Salmonella would be deemed adulterated. According to USDA, the policy shift is needed because, historically, there have been numerous Salmonella outbreaks involving these products. The simple hypothesis is that, because the exterior of these products is typically breaded and browned, they could potentially appear to the consumer to be fully cooked. As a result, USDA reasons, consumers may not routinely fully cook these products adequately, potentially resulting in illness.

If adopted, the declaration of Salmonella as an adulterant in certain poultry products would likely result increased testing requirements throughout the poultry industry. Supporters argue that declaring Salmonella as an adulterant could provide stronger incentives for poultry producers to implement more rigorous food safety measures and reduce the prevalence of Salmonella contamination. Opponents, on the other hand, argue that declaring Salmonella as an adulterant would place an unrealistic burden on the industry and potentially lead to unintended consequences, such as increased costs, potential supply chain disruptions, and less options for consumers.

Thinking back a few decades, I recall that, when E. coli was first declared to be an adulterant in ground beef, industry claimed vehemently (and, correctly at first) that producing ground beef completely free from pathogens such as E. coli was not possible. USDA softly conceded as much, also requiring that safe handling labels be affixed to all raw beef products. With that said, eventually, USDA accomplished its intended goal, overseeing an industry that worked successfully to drive the prevalence of pathogens such as E. coli O157:H7 in beef products to their lowest levels ever. Indeed, when contrasted with the large numbers of recalls for E. coli in decades past, we rarely see them anymore.

Regardless of your position on the Salmonella issue, there can be no mistake that this day has finally arrived. Moving forward, it will be quite interesting to see: (1) if industry can successfully control the presence of Salmonella in the targeted products; and (2) whether USDA’s most recent declaration, over time, eventually proves to be the prelude to the ultimate expansion of new poultry adulteration standards to an even wider scope of raw poultry products.

Adulteration palpitation

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