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Controlling Salmonella and Campylobacter in Raw Poultry

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

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Title: Controlling Salmonella and Campylobacter in Raw Poultry


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
  • Aid in meeting Healthy People 2020 reduction
    goals
  • Aid industry in meeting newly proposed
    performance standards for chicken parts and
    comminuted chicken and turkey
  • Food safety issues since last issuance
  • 2011 - two Salmonella outbreaks associated with
    ground turkey
  • 2012/13 and 2013/14 two Salmonella outbreaks
    associated with chicken parts
  • 2013 one Salmonella outbreak associated with
    MSC
  • 2013-2015 four Salmonella outbreaks associated
    with NRTE but appears RTE stuffed poultry
    products

3
Goal of The Guidance Document
  • To help poultry establishments
  • Comply with regulatory requirements pertaining to
    HACCP and Salmonella/Campylobacter control
  • Outline pre- and post-harvest interventions that
    may help control Salmonella and Campylobacter
  • Recommend 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
  • Sanitizing knives between each individual carcass
    increases handling time, may not significantly
    reduce pathogens, and may not be feasible given
    production practices.
  • Tracking employee travel and health status is
    excessive
  • Limit 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
  • Lots by flock or supplier
  • Lots based on microbiological testing
  • Lots by processing intervention
  • Lots based on Sanitation SOPs

9
Lotting Practices Concerns
  • Suggestions for lot control are similar to those
    designed for RTE products or products like ground
    beef
  • Salmonella 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
  • Not FSIS jurisdiction
  • Not 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
  • Establishments must apply interventions uniformly
    for optimal reduction
  • Industry treats all flocks as if they were 100
    positive
  • Guideline suggests interventions that work on
    Salmonella will likely work on Campylobacter
  • Not 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
  • Early 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
  • Suggests 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
  • Not 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
  • Performance 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/Campylobact
    er 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
  • Contract incentives for growers to provide
    pathogen-free birds
  • New, dry bedding between each flock
  • Washing 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)
  • Scientific evidence does not support this
    recommendation
  • Guideline references outdated NCC processing
    practices document
  • No longer followed by industry

20
Further Processing and Sourcing
  • Distinguish between in-house source materials and
    outside source materials
  • Source 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
  • Product 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
  • implementation in extensive trials or true
    commercial operations have proven problematic.
  • the role of the consumer cannot be ignored
  • Many suggestions were highly prescriptive, while
    other items remain vague
  • Definition of acceptable levels of pathogens
  • Inaccurate 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?
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