The USDA Food Safety and Inspection Service has proposed that the presence of Salmonella at a level of 1 CFU per gram in raw breaded stuffed chicken products would constitute adulteration. This is effectively a zero tolerance for any Salmonella irrespective of pathogenicity in this class of product.
The problem of salmonellosis arises from failure by consumers to read and follow clear label instructions to prepare raw frozen breaded products. The appearance of frozen chicken Kiev and chicken cordon bleu, with a slight browning, may confuse those who are either negligent or illiterate. This would result in their thawing and heating products in a microwave or for short duration in an oven. Failure to reach 165 F for at least 30 seconds through the entire product will allow Salmonella that may be present to remain viable. The number of confirmed cases of salmonellosis attributable to consumption of raw breaded stuffed chicken products in the U.S. is extremely small in relation to the volume of consumption. It is however likely that infection from breaded chicken products is under-reported. Through 2022, Canada experienced a disproportionate incidence of salmonellosis attributed to breaded stuffed raw chicken products.
Predictably the National Chicken Council is opposed to the FSIS proposal. In the first instance, declaring Salmonella in any product as an adulterant can be regarded as a slippery slope. This is especially in view of the petitions submitted by William Marler requesting that a range of pathogenic Salmonella serotypes be regarded as adulterants in any chicken product.
The NCC response appears a little extreme noting that, “200 million servings of these products will be lost, and 5,100 people will lose their jobs and that the proposal will drive small producers of this product out of business entirely.” The NCC response continues, “the Council remains confident that these products can be prepared and consumed safely and NCC member companies will continue to work day-in and day-out to implement sound, science-based safety programs that will continue to make Americas most popular protein even safe.” There are science-based solutions available. Electron beam irradiation would effectively destroy Salmonella and Campylobacter but the technology analogous to an X-ray, although safe and effective, is considered to be unacceptable by consumer advocacy organizations.
Since it is evident that precautionary labeling and education are not absolutely protective,
the question arises as to why the industry is marketing a raw product. If cooked to the critical temperature, foodborne non-spore forming pathogens would be destroyed and all those claimed jobs would be saved!
It is currently a question of conjecture whether the proposed action by USDA-FSIS is justified in relation to the balance between the public good and the financial impact on the industry. What does stand out is the optics of the NCC, representing the chicken industry, opposing on the basis of financial impact, what consumers may regard as an acceptable regulatory action, irrespective of validity or potential benefit.