A federal shot over raw poultry's bow?

Sandra Eskin was appointed Deputy Under Secretary for Food Safety on March 24, 2021.

In this role, Mrs. Eskin leads the Office of Food Safety at the U.S. Department of Agriculture, overseeing the Food Safety and Inspection Service (FSIS), which has regulatory oversight for ensuring that meat, poultry and egg products are safe, wholesome and accurately labeled.

Prior to joining USDA, Mrs. Eskin was the Project Director for Food Safety at The Pew Charitable Trusts in Washington, D.C., a position she held since November 2009. She also served as the Deputy Director of the Produce Safety Project (PSP), a Pew-funded initiative at Georgetown University from 2008-2009. While at PSP, she was a senior scholar with the O’Neill Institute for National and Global Health Law at Georgetown University.

Mrs. Eskin spent nearly 20 years as a public-policy consultant to numerous consumer advocacy and public-interest organizations, providing strategic and policy advice on a broad range of consumer-protection issues, in particular food and drug safety, labeling, and advertising. She has served as a member of multiple federal advisory committees related to consumer information on prescription drugs, meat and poultry safety, and foodborne illness surveillance. During her career, she has written numerous reports and articles on food-safety topics. Mrs. Eskin received her J.D. from UC Hastings College of the Law, and her B.A. from Brown University.

(From USDA web-site)

From Meatingplace.com August 01, 2022

Dr. Raymond is smart, clever and a very pragmatic man, and someone who I respect highly - a straight shooter - if there ever was one.

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Tell me, Mrs. Sandra Eskin, appointed Deputy Under Secretary for Food Safety or anyone else for that matter --- .

Just how common is salmonella poisoning from raw "poultry?"

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"About 1 in every 25 packages of chicken at the grocery store are contaminated with Salmonella.

One can get sick from contaminated chicken if it's not cooked thoroughly or if its juices leak in the refrigerator or get on kitchen surfaces and then get on something you eat raw, such as salad.

Sept. 21, 2021 - from Chicken and Food Poisoning | CDC."

Thanks, CDC.

I knew it.

How about that?

The USDA / FSIS seems committed to finally declaring breaded and stuffed raw chicken products - as the Adulterant of the Year for 2022 and beyond.

It is a historical move by USDA.

And I love it.

A harbinger of more to come?

Or, a mere shot over the bow?

Actually it's a direct hit, Captain.

It's certainly a landmark for the poultry plants that manufacture such delectable poultry products.

?William (Bill) Marler?is a food-borne illness lawyer who is based in Sleepless in Seattle, Washington and has become an enforcer in food policies not only domestically and around the WWW world.?Marler Clark, The Food Safety Law Firm, has represented thousands of individuals in claims against food companies whose contaminated products have caused life altering injury and even death.

Love it.

Mr. Marler is clever.

Mr. Marler knew very well he was asking for way too much, too soon.

"31 Flavors,"of salmonella serotypes to be declared as adulterants in his ancient letter to the USDA.

All Mr. Marler needed was just one (1).

Mr. Marler got what he wanted.

Mr. Marler is certainly on the right track and has the - "Right Stuff.".

I like Mr. Marler and respect him.

Always have.

I bet Mr. Marler is a good chess player as well.

I'd like to play Mr. Marler one day.

I bet he loves his white Squire the most.

They win.

Congratulations, Mr. Marler, and co - workers on a job well done - and - executed.

And thank you mostly, Mr. Marler, for helping to start changes in our industry - and to save lives of kids and the many people like me that has a compromised immune system.

Good karma is heading your way again - Mr. Marler.

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Welcome to the Jungle nRTE breaded poultry processors.

We the people - deserve it.

We all do.

nRTE with stuffing and all the fixings will forever live in infamy in a kaleidoscope of future food safety articles world wide - even in Meatingplace.com.

We earned it.

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SPIN THE WHEEL

Cook your 100% raw poultry to at least 165 Degrees F., internally, whether its whole muscle breasts, wings, drumsticks - all raw chicken.

At least if E. coli O157:H7 is on the surface of your favorite Tri-Tip steak - the pathogen shall be eliminated on your burning grill or frying pan.

I always like my steak to be medium / rare.

Not chicken.

Nope.

Salmonella unlike whole 100% raw muscle beef - affects internally poultry muscle sections as well as externally - especially if the delicious skin is still attached.

That's a double-double if there ever was one.

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SIDE NOTE

Once again, the National School Lunch Program for Poultry remains stricter than AMS' Big Brother USDA concerning virulent pathogens.

Listed directly below are the microbes CL (limits) for NSLP concerning frozen / raw poultry.

Coliform's that exceed 50 CFU/gram - Out you go you Gram-Positive!

E. coli 50 CFU/gram - Outta of here!

Coagulase-positive Staphylococcus aureus results must be les than 10 CFU?/gram - See 'ya!

Salmonella shall not be detected - Thanks, AMS!

Listeria monocytogenes shall not be detected - Beautiful AMS!!!

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The National Chicken Council, the trade association for supposedly 95% chicken producers and processors, said it was "concerned" about the precedent set by the abrupt shift in federal policy.

Why?

The stats evinces the truth - loud and crystal clear.

Before the Mega Reg was published in the Federal Register on Jul. 1996, I clearly recall a completely different mindset of the National Meat Association (NMA) and the American Meat Institute (AMI) than what the National Chicken Council is currently displaying on the www.

They had better re-think this one.

“It has the potential to shutter processing plants, cost jobs, and take safe food and convenient products off shelves. We’re equally concerned that this announcement was not science-based or data-driven,” said NCS spokeswoman, Ashley Peterson.

She went on and scribbled, "... the government already has the regulatory and public health tools to work with the industry to ensure product safety, adding that companies producing chicken meat have invested millions of dollars and have worked for more than a decade to reduce salmonella in raw chicken.

Not nearly good enough.

However, it appears Pandora's Box has been opened.

Good luck on this one General Armstrong Custer.

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This is the very same council that claims OSHA safety has improved its record in poultry.

Mis - information again.

Yes, injuries and illness are down. It had been so high, high, high - it had to decrease.

There was no other way to go!

Occupational safety and health in poultry still needs va$t improvement$.

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FINAL NOTE - FOR NOW

Meatingplace.com had an exclusive interview with USDA's Sandra Eskin about the new salmonella declaration. It's under XTRA XTRA XTRA.

My favorite line of USDA's Mrs. Sandra Eskin?

"I would give them the names and numbers of families whose children have been horribly impacted by a salmonella issue."

Checkmate.

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XTRA XTRA XTRA !

INDUSTRY NEWS - PM

Exclusive:

An interview with USDA's Sandra Eskin about new salmonella declaration

By?Peter Thomas Ricci?on 8/1/2022

This morning,?Meatingplace?reported that the?USDA's Food Safety and Inspection Service (FSIS) will declare salmonella an adulterant in breaded and stuffed raw chicken products.

Framing the declaration as part of its continuing efforts on food safety, FSIS stated that if such chicken products have?levels of 1 colony forming unit (CFU) per gram or higher, they will be considered adulterated.

Given the significance of the USDA's announcement,?Meatingplace conducted an in-depth interview with Sandra Eskin, the agency's deputy under secretary for food safety, for further insights. In the following interview (which has been edited for length and clarity), Eskin details why the USDA made its declaration, what its next steps are, and how the agency will welcome input from poultry processors and other animal agriculture professionals.

"Are we done? By no means are we done," Eskin says. "We know where we are now, but we really want to hear from the community."

Meatingplace: What were some of the main reasons for this new salmonella declaration? And why focus on NRTE stuffed/breaded chicken products?

ESKIN: Last fall, we initiated a broad reevaluation of how we regulate salmonella contamination and poultry. What we saw, based on our sampling data, was that product contamination was decreasing, but looking at illness data, there was no change, which begs the question — are we measuring the right thing in the right way? And are we targeting salmonella that makes people sick? FSIS prides itself on being a public health regulatory agency, which means our goal is to reduce illness. So we are still in the middle of the broader strategy development, but while we were doing work on this and talking about adulteration and other things, we zeroed in on this particular product for a number of reasons.?

[Since 1998], there have been 14 outbreaks linked to these products — these raw stuffed chicken breasts that look like they're ready to eat, but they're not. And they're almost always sold frozen. So we have a lot of outbreaks. We also have this situation where even though we've tried — and we've worked with industry to revise the labeling instructions, warnings, whatever — it's just not making a difference. The most recent outbreak, I might add, was in 2021, so these are persistent. [And] in our determination of any pathogen and whether or not it's an adulterant, we look at things like outbreaks, consumer handling and any challenges that poses, we look at the infectious dose, and when appropriate — and not in this situation — if we know there are particular strains that are involved, we'll want narrow on those.?

So bottom line, these products are continued to make people sick. Consumers are confused. We've done our own kitchen research with consumers — they're confused. The [product package] photo looks like it's fully cooked; for the photo, it might be, but it doesn't necessarily relate. So our goal overall with this is to identify product pathogen pairs, salmonella and raw poultry products, that have the strongest case for adulteration. And I think that's why we focused in on this.?

Are we done? By no means are we done. How are we going to approach things going forward? Are we going to identify other pathogen product pairs? Are we going to have, perhaps, a standard that cuts across all raw poultry? We're still discussing that, but I want to make clear that we want this to be a collaborative process. And what that means is, No. 1, for these particular products, we are planning to declare salmonella to be an adulterant. We are proposing a quantitative standard, one CFU per gram, but we're inviting comments on whether or not, obviously, should it be an adulterant? And if so, if it is an adulterant, maybe it needs a zero tolerance standard, or maybe it needs a serotype-based standard. We know where we are now, but we really want to hear from the community.?

But that's specific to this particular product and salmonella, but more broadly, we've said that we're developing a framework — a draft framework that will address all stages of production that we have the authority to regulate. We want to release that in October, and we are having a public meeting in November, and we're looking forward to a robust conversation at that public meeting; and then, we're going to start moving into a proposed rule on this. We should do a policy statement on that, throughout 2023. So again, I'm going to reiterate: This product stood out to us as one that made the strongest argument for treating salmonella as an adulterant.

Meatingplace: Back in June, the USDA denied a petition to declare 31 serotypes of salmonella as adulterants in meat and poultry products. How does this new announcement compare/contrast with that petition?

ESKIN: So when we're talking about salmonella, right? And if we agree that it should be treated as an adulterant, we can have the whole spectrum. I could start with one product, [which is] what we're doing. Again, we're starting, we're not ending. Going all the way to the other extreme where it's all salmonella in all products. What [attorney Bill] Marler's petition did was identify 31 'outbreak strains.' We just did not believe that there was enough data to go through those criteria for each of those serotypes, [regarding] dose response, outbreaks, consumer handling.

So at that point, when we denied it, we did say, 'We're looking at a lot of the issues that are raised in the petition.' So while we absolutely denied it, we've continued to look at some of the issues. [But] we felt that the 31 identified serotypes was just too broad a brush to paint at this point.

Meatingplace: What does this announcement mean for FSIS policy on specific serotypes of salmonella? Might salmonella in other poultry products be declared an adulterant?

ESKIN: So we, as you well know, are testing and sampling, and the standard is prevalence — either you're contaminated or you're not. And many experts in food safety and policymakers have come to understand that maybe prevalence is not effective in reducing illness. So our own labs are moving ahead with quantification. Many companies use quantification, and it's more widely available in testing.?

Where would we like to go? Meaning not just us, but the ability to detect, and that will be relevant to what your standards are? Ultimately, we'd like to get to a point where we can identify viral genes. There's research being done on that, because we know that these genes hop from serotype to serotype. And also, we want to move also, where appropriate, to stereotypes.

But one of the concerns is that we need to have testing that we can do cost effectively and quickly. These are raw products, right? We can't wait three days. And our understanding is we're not there yet. But again, these are the types of conversations we want to have — we've been having them with testing companies, we've been having them with our own labs.

So let me answer your question. We are looking at, in light of this particular declaration, how to go forward. So one possibility is to continue to identify pathogen product pairs. But I think what we're also discussing right now is if there is a way to set a standard that would be appropriate across all raw poultry products.?

Again, in the stuffed chicken basis, we're using quantification based on risk assessments and testing capabilities. We may get a lot of comments saying, 'No, it should be this, that, or it should be serotype, it should be that.' We will listen to those. So the bottom line is, that's the first step. We may be walking in that same direction with pathogen product, but I think ideally, we'd like to see if we can develop a sound public health-based standard. I'll just say quantification, let's start there. Right? That we could apply across products, all raw products.

Meatingplace: You already talked about how you have a?Federal Register?publication in October, and then public engagement in November. So is it possible, at this stage, to give us any kind of timeline on implementation, or does it stem from that November session?

ESKIN: It really does stem toward that November session, but I will say this — Secretary Vilsack is supportive of this initiative. The leadership at FSIS is supportive of this initiative. The general administration knows what we're doing, and they're supportive ... We want to keep this moving, and it's really important for us that we get out proposals as early as 2023 as we can.?

But I also want to underscore, these are some big changes. They haven't been discussed in the context of a regulatory proceeding, and I believe, based on my own experience, that the best policies develop out of collaboration. So there's a lot we have to do, but I think one of the reasons we decided to do this framework [is to] get input from the public that would help us craft, and get a better sense, when we get into the more formal regulatory process.

Meatingplace: Finally, there are some in the food science space who argue against any salmonella strains/products being declared adulterants, given how different salmonella is from, say, E. coli. What would you say to those skeptics, when it comes to this new FSIS standard??

ESKIN: I would show them that chart that shows contamination going down, but illnesses not budging. I would show them the fact that poultry is linked to about 23% of the 1.35 million illnesses each year. I would give them the names and numbers of families whose children have been horribly impacted by a salmonella issue. And I would also, again, look at the homepage for FSIS. We are a public health agency. Our responsibility is to do everything we can to ensure that the people and the companies who do a great job, generally, do everything they can to reduce salmonella. We can have a conversation about the factors that we use in making a determination of salmonella, [but] our current system, which does not treat salmonella as an adulterant, is not working to reduce illness.

So if they have a better idea, I'm all ears. But I do believe with all the data we have, all the information, and our mission to improve public health, this is appropriate. We are being mindful of the impact of any policy we develop on the industry. Obviously, we don't want to cause any disruption that could potentially impact supply or price. We're very mindful. So in light of that, I encourage them to come in and I'll listen. Anyone in the industry, do this in a way that improves public health and that's workable. We get that. We know it has to be able to work in a plant or else, what's the point?

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WHAT WASN'T SAID

For every case of?Salmonella?illness confirmed by laboratory tests, almost 30 other cases are not reported. That’s because most people with?symptoms?of foodborne illness do not go to the doctor or submit a sample to a laboratory, so we never learn what germ made them sick.

Strains of?Salmonella?spp. with resistance to antimicrobial drugs are now widespread in both developed and developing countries.

CDC estimates that?Salmonella?causes more than 1 million food-borne illnesses in the United States every year.

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Don't overlook Campy-Lo!

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