Last December, the U.S. Department of Agriculture (USDA) Food Safety and Inspection Service (FSIS) released a draft of the Compliance Guideline for Controlling Salmonella and Campylobacter in Raw Poultry Fourth Edition to help control food safety hazards in poultry production (FSIS will accept comments on this draft document through March 18, 2016).

In this post, we will overview portions of the draft compliance guideline addressing microbiological testing and highlight concerns with Salmonella and Campylobacter.

Pathogens and Poultry

The Centers for Disease Control and Prevention (CDC) estimates there are approximately 1.2 million foodborne illnesses caused by non-typhoidal Salmonella in the U.S. each year, and an estimated 450 deaths each year are associated with acute Salmonellosis. A Salmonella infection usually results in diarrhea, fever, vomiting and abdominal cramps.

Animals are the main reservoir of the Salmonella organism. Salmonella may be naturally present in the intestinal tract of many animals including chickens. It is often part of their normal flora. Chickens can obtain Salmonella from the soil or possibly contaminated feed because the bacteria are found in fecal material.

To reduce the chances of the birds acquiring Salmonella from the environment, some poultry plants keep barns closed up so no wild birds come into contact with the chickens. However, during slaughter and processing, there is a chance bacteria from the intestines may contaminate the finished product.

According to the CDC, Campylobacter is one of the most common causes of diarrheal illness in the U.S., affecting over two million people annually. Campylobacteriosis, an infectious disease caused by this bacteria, exhibits with diarrhea, cramping, abdominal pain and fever within two to five days of exposure. Campylobacter jejuni grows best at 37°C to 42°C, approximately the same body temperature of a bird. Birds may carry this fragile bacteria without becoming ill, but infection can be spread through raw or under-cooked poultry.

FSIS Draft Compliance Guideline

In its fourth edition, the draft guidance document is intended to assist poultry establishments in controlling Salmonella and Campylobacter. FSIS notes it is important to consider the elimination of both pathogens when designing food safety systems. Specific to the food laboratory, the draft guideline recommends these establishments utilize microbial testing results to monitor the performance of their Hazard Analysis Critical Control Points (HACCP) system.

The draft guideline focuses on improving management practices at poultry establishments. For example, federally inspected establishments must implement a hazard analysis which monitors for food safety hazards occurring before, during and after entry. A HACCP plan is used to prevent or reduce these hazards from occurring. In addition to using microbial test results, protocols such as environmental monitoring, water testing and verification may be implemented.

There are a number of reasons why poultry establishments may conduct or have a third-party laboratory perform microbiological testing including:

• supporting the on-going verification of a HACCP plan,
• supporting decisions regarding a hazard analysis,
• evaluating the effectiveness of a sanitation program,
• complying with customer specifications,
• and fulfilling regulatory requirements.

FSIS states, “By performing microbiological analyses at several points within a process, it is relatively easy to identify the segment of the process where control has been lost.”

To monitor and interpret the data collected from ongoing HACCP verification, the draft guideline recommends strongly using statistical process control (SPC). The draft guideline notes that lower statistical control limits may incorrectly indicate that process control issues are present, and higher limits may miss potential process weaknesses.

FSIS suggests that when selecting a microbiological testing laboratory, establishments should consult the Establishment Guidance for the Selection of a Commercial or Private Microbiological Testing Laboratory to obtain details on the necessary testing criteria. FSIS also shares that the elements for a well-designed microbiological sampling program include:

• intended purpose of testing programs,
• targeted organisms for testing,
• product subject to testing,
• sample collection procedures and locations,
• procedures for ensuring sample integrity,
• testing methods for sample analysis,
• laboratory performing the analysis,
• method for evaluating the test results,
• and actions taken based on the test results.

FSIS notes, “Only pathogen testing can effectively verify that pathogens are controlled to acceptable levels in finished product.”  The agency continues, “Indicator organisms can provide evidence of control, while periodic testing for pathogens may verify that the establishment is reducing pathogens to acceptable levels.”

FSIS recommends that establishments direct testing laboratories to any necessary testing protocols, including ones stated in this compliance guideline.  The agency clearly states establishments that “…select a laboratory that does not apply appropriate testing methods of effective Quality Control/Quality Assurance (QC/QA) practices may not receive reliable or useful testing results.”

FSIS advises that although this edition of the compliance guideline is labeled as a draft, its recommendations may be used in agency’s current decision-making processes.

Safety Tips and Resources for Consumers

There are important steps consumers should take to reduce their risk of exposure to Salmonella, Campylobacter and other pathogens from raw poultry:

• Properly wash hands, utensils, cutting boards, counter tops and anything that may have come in contact with raw poultry meat or juice with hot soapy water.
• Refrain from washing raw poultry. Washing is actually thought to cause more harm than good. The overspray and splash from washing the chicken can easily cross-contaminate the preparation area.
• Promptly refrigerate or freeze fresh poultry products.
• Always use a food thermometer to ensure poultry is being cooked to a minimum internal temperature of 165°F.

Consumers can access “Ask Karen”, the FSIS virtual representative, for food safety questions. Go to AskKaren.gov (m.askkaren.gov by smartphone). The USDA also offers a toll-free Meat and Poultry hotline for consumers: 1-888-MPHotline (1-888-674-6854). To submit a consumer complaint, visit the Electronic Consumer Complaint Monitoring System: http://www.fsis.usda.gov/reportproblem.