1. Controlling Salmonella and Campylobacter in Raw Poultry An Overview of the 2015 Draft FSIS Compliance Guideline Ashley B. Peterson, Ph.D. National Chicken Council

2. Background Draft version issued on December 11, 2015 Comments due March 18, 2016 (was Feb 16, 2016) An update to the 2010 version oAid in meeting Healthy People 2020 reduction goals oAid industry in meeting newly proposed performance standards for chicken parts and comminuted chicken and turkey Food safety issues since last issuance o2011 - two Salmonella outbreaks associated with ground turkey o2012/13 and 2013/14 – two Salmonella outbreaks associated with chicken parts o2013 – one Salmonella outbreak associated with MSC o2013-2015 – four Salmonella outbreaks associated with NRTE but appears RTE stuffed poultry products

3. Goal of The Guidance Document To help poultry establishments: oComply with regulatory requirements pertaining to HACCP and Salmonella/Campylobacter control oOutline pre- and post- harvest interventions that may help control Salmonella and Campylobacter oRecommend methods for microbial testing to monitor HACCP system efficacy and to inform decision making

4. Changes to the Guidance Document Clarify that effectively designed and consistently implemented HACCP systems can reduce risk from pathogens Provide additional information on establishment sampling and testing for decision-making, including informing whether establishments are maintaining process control Emphasize the role of maintaining sanitary operations and preventing contamination by implementing sanitary dressing procedures and minimizing cross contamination during slaughter and further processing. Discuss further the use of antimicrobial interventions to control pathogens.

5. Sections of Compliance Guide Sanitation Lotting practices Intervention use Using microbiological sampling and testing Pre-harvest interventions and management practices Slaughter Further processing

6. Sanitation Provides a review of cleaning methods, detergents, and sanitizers for use when cleaning processing equipment and surfaces Employee hygiene and contact with product during tasks should be monitored to prevent cross-contamination

7. Sanitation Concerns Unnecessary prescriptive practices oSanitizing knives between each individual carcass increases handling time, may not significantly reduce pathogens, and may not be feasible given production practices. oTracking employee travel and health status is excessive oLimit injectable marinate use All should be establishment- specific options www.foodsafetynews.com

8. Lotting Practices Establishments are required to inform the FSIS District Office of the type, amount, origin, and destination of any adulterated or misbranded product (9 CFR 418.2) Section provides suggestions for defining microbiologically independent lots to prevent carryover exposure and minimize scope of potential recalls oLots by flock or supplier oLots based on microbiological testing oLots by processing intervention oLots based on Sanitation SOP’s

9. Lotting Practices Concerns Suggestions for lot control are similar to those designed for RTE products or products like ground beef oSalmonella and Campylobacter are not adulterants in raw poultry Salmonella and Campylobacter may lawfully be present in raw product and their mere presence does not affect the integrity of a production lot nor is there scientifically valid reasons to require microbiological independence (minimize scope of a recall) Relying completely on microbiological sampling for lot independence would be difficult and unreliable for even most advanced establishments

10. Lotting Practices Concerns Requiring information on growout houses, hatcheries, and breeding flocks for lotting is inappropriate oNot FSIS jurisdiction oNot realistic: most facilities run multiple lines How to maintain independence of flocks during processing?

11. Intervention Use Establishments must maintain scientific support of intervention efficacy, and maintain records as supporting documentation for HACCP Measurements of interventions should take place where they are applied to product, not where they are mixed Adequate carcass/product coverage is crucial Using a new intervention, or using it differently than intended, requires review of protocol by FSIS/FDA www.foodproductiondaily.com

12. Intervention Use Concerns Multiple recommendations to adjust intervention use on product according to Salmonella or Campylobacter status of flock, lot, or source material oEstablishments must apply interventions uniformly for optimal reduction oIndustry treats all flocks as if they were 100% positive Guideline suggests interventions that work on Salmonella will likely work on Campylobacter oNot reflective of current scientific understanding; interventions may or may not work on both A number of recommended interventions are not yet approved for use by FSIS

13. Microbiological Sampling and Testing Establishments should develop a program that addresses multiple points through production process, further processing, and slaughter Process mapping for assessing verification & control Statistical process control to interpret data from HACCP verification procedures oEarly warning to process issues Indicator organisms to estimate pathogens of interest www.foodsafetymagazine.com

14. Sampling and Testing Concerns Inconsistent recommendations for statistical analysis of process control oSuggests using tables providing median target organism values to evaluate process control

15. Sampling and Testing Concerns Guideline indicates that illnesses resulting from a product are sign of loss of process control oNot necessarily true: raw products inherently have the potential to contain foodborne pathogens Stated in Agency policy and PPIA Guideline recommends referencing FSIS raw poultry product performance standards to assess process control oPerformance standard and category ranking system may not be applicable to assessing establishment- wide process control

16. Pre-Harvest Interventions and Management Practices Slaughter and processing establishments should receive birds from growout farms, hatcheries, and breeder flocks that implement a multi-hurdle Salmonella/Campylobacter approach Obtain broiler chicks from breeder flocks/hatcheries that participate in National Poultry Improvement Plan (NPIP) Broiler feed, water, and environment should minimize potential contamination Flocks should be tested for Salmonella/Campylobacter prior to slaughter

17. Pre-Harvest Interventions and Management Concerns Pre-harvest considerations are not within authority of FSIS or within scope of the Compliance Guideline Not feasible for establishments to require only pathogen- free birds at slaughter Some Guideline recommendations not applicable oContract incentives for growers to provide pathogen- free birds oNew, dry bedding between each flock oWashing and drying coops between each transport

18. Slaughter and Processing Employee traffic patterns and air flow can prevent contamination Schedule flocks for slaughter based on pathogen loads Utilize stunning that minimizes flapping/bird contact Monitor quality of scalding tank water Keep evisceration equipment in good sanitary condition Sanitary dressing is just as important as intervention application “Carcasses must be free of visible fecal contamination prior to entering the chilling system” 9CFR 381.65(f)

19. Slaughter and Processing Concerns Guideline recommends the use of controlled atmosphere stunning (CAS) oScientific evidence does not support this recommendation Guideline references outdated NCC processing practices document oNo longer followed by industry

20. Further Processing and Sourcing Distinguish between in-house source materials and outside source materials oSource of material incorporated into HACCP system Require suppliers to follow good sanitary dressing procedures Raw but heat treated poultry products (NRTE) must be processed to reduce frequency/contamination before packaging

21. Further Processing and Sourcing Concerns HACCP plans are proprietary to the originating establishment and not shared between companies Purchase specifications for raw products are based on a wide variety of business factors Prevalence rate of Salmonella in mechanically separated chicken is not an accurate indicator of risk oProduct is subjected to a heat lethality treatment

22. Conclusion The 2015 Draft Compliance Guideline provides many generally applicable and useful recommendations to help prevent Salmonella and Campylobacter Misuse of Cox and Pavic (2010) publication o“…implementation in extensive trials or true commercial operations have proven problematic.” o“…the role of the consumer cannot be ignored” Many suggestions were highly prescriptive, while other items remain vague oDefinition of “acceptable levels” of pathogens oInaccurate use of pathogen “prevalence” versus “load” Important differences Guidelines would benefit from allowing flexibility in processing design, while stressing that all best practices should be applied uniformly to achieve highest goals for food safety

23. Questions?