Consumer fault is a red herring; Salmonella should be an adulterant in poultry

In recent days the CDC and FSIS updated information on a continuing salmonellosis outbreak connected to raw and live turkeys. Since July 19 announcement of the outbreak, 74 more people from 26 more states have been reported.

That brings the totals, as of Nov. 5, to 164 infected people from 35 states. Sixty-three have been hospitalized and one person has died. Of 135 people with information available, 63 of them, or 47 percent, have been hospitalized. That is a high rate; this is a virulent strain highly pathogenic to humans. 

This outbreak is similar to the 2013-2014 outbreak from Salmonella Heidelberg. CDC reported 634 persons were infected with seven outbreak strains in 29 states and Puerto Rico; 38% of ill persons were hospitalized, and no deaths.

Salmonellosis from virulent strains borne by poultry is a decades old continuing problem. According to the definitions in the meat and poultry inspection acts,1.2. these Salmonella strains pathogenic to humans are adulterants. The cases and outbreaks prove they are ordinarily injurious to public health. FSIS has been reluctant to name them as adulterants, sometimes citing APHA vs Butz.3 However, that court decision was based in part on a letter written by USDA in August 1971. That letter wrongly averred that consumers were knowledgeable and competent. It had no scientific validity and was contrary to a 1970 USDA committee’s finding on a 1969 NAS report “An Evaluation of the Salmonella Problem.”11 and a USDA report evaluating that NAS report.10

Depending on consumers to safely handle raw meat and poultry contaminated with virulent pathogens has failed time and again. The CDC report continues with “Advice to Consumers and Retailers.” This is helpful to CDC, FSIS, and the poultry industry. Decades of educational programs by federal, state and private entities show little progress. A half century of scientific opinion and research demonstrate that most consumers are inept. Here are a few examples:

In 1963 Kampelmacher wrote, “The real problem under discussion is: are poultry products a potential danger to public health, and if so, what objective criteria can be applied in the assessment of this danger? … However, the public is usually badly informed on the possible danger of poultry and poultry products to public health. Educating the public on these matters is a  difficult task. ” “In contrast to red meat, raw poultry is not consumed or prepared in any country. The danger lies in the processing, starting with the producers of poultry products and ending with the consumer.” 

Decades later, Kosa concluded “Based on the survey findings, we conclude that education is needed to improve consumer handling practices for raw poultry to decrease illness attributed to Salmonella and Campylobacter in raw poultry products.”9 

This summer, at the 2018 International Association for Food Protection meeting, Quinlan presented: “Mishandling of Poultry Products by Consumers: Identification of Gaps in Knowledge and Safe-handling Practices of Raw Turkey.” 8 The talk focused on a survey of consumers cooking turkey. Contrary to recommendations, a significant number washed turkeys, cooked with stuffing inside the bird, and held the cooked turkey at room temperature for more than two hours before serving. 

These three examples underline the need for better consumer education and training. There are many other scientific papers on consumer mishandling and – even after more than three decades of USDA’s Hot Line and others’ initiatives. These scientific results give lie to the frequent chant “just cook it” often on the internet. 

The attention given to cooking ignores the greater threat of cross contamination in kitchens. Echoing Kampelmacher, in 2009, Luber, citing 58 papers, wrote, “In conclusion, cross-contamination events from activities such as use of the same cutting board for chicken meat and salad without intermediate cleaning or spreading of pathogens via the kitchen environment seem to be of greater importance than the risk associated with undercooking of poultry meat or eggs.” Her paper currently has 108 citations, eight in 2018 so far. 

Virulent strains of Salmonella pathogenic to humans is an old problem. One solution would be to declare them adulterants and thus provide a regulatory incentive for control.

References

1.21 U.S.C. 453 – Definitions: (g) The term “adulterated” shall apply to any poultry product under one or more of the following circumstances:

(1) if it bears or contains any poisonous or deleterious substance which may render it injurious to health; but in case the substance is not an added substance, such article shall not be considered adulterated under this clause if the quantity of such substance in or on such article does not ordinarily render it injurious to health;

2. 21 USC § 601 – Definitions (m) The term “adulterated” shall apply to any carcass, part thereof, meat or meat food product under one or more of the following circumstances:

(1) if it bears or contains any poisonous or deleterious substance which may render it injurious to health; but in case the substance is not an added substance, such article shall not be considered adulterated under this clause if the quantity of such substance in or on such article does not ordinarily render it injurious to health; 

3. American Public Health Association et al., Appellants, v. Earl Butz, Secretary of Department of Agriculture, et al.. United States Court of Appeals, District of Columbia Circuit. – 511 F.2d 331. Argued Jan. 22, 1974.Decided Dec. 19, 1974.Rehearing En Banc Denied April 9, 1975

4. Kampelmacher, E. H. (1963). Public health and poultry products.  British Veterinary Journal 119, 110.

5. 9 CFR 311 Disposal of Diseased or Otherwise Adulterated Carcasses and Parts. 

6. 9 CFR 315.2  Carcasses and parts passed for cooking; utilization for food purposes after cooking.

7. Luber, Petra. 2009. Cross-contamination versus undercooking of poultry meat or eggs — which risks need to be managed first?.  International Journal of Food Microbiology 134 (2009) 21–28. 

8. Quinlan, Jennifer J. 2018. Mishandling of Poultry Products by Consumers: Identification of Gaps in Knowledge and Safe-handling Practices of Raw Turkey. T6-07 Tuesday, July 10, 2018 10:30 AM – 10:45 AM. International Association for Food Protection. Salt Palace Convention Center – Room 151 D-G

9. Kosa, Katherine M.; Cates, Sheryl C.; Bradley, Samantha; Chambers IV, Edgar; Godwin, Sandria. 2015. Consumer-Reported Handling of Raw Poultry Products at Home: Results from a National Survey. J. Food Prot. 78:180-186. 

10. Microbiological Subgroup of the USDA Food Safety Committee.  1970.  Food Protections by the Department of Agriculture.  A Review of the NAS-NRC Report. “An Evaluation of the Salmonella Problem”

11. National Academy of Sciences/National Research Council/Committee on Salmonella. 1969. An Evaluation of the Salmonella Problem. Prepared by the Salmonella Committee of the National Research Council, Washington, DC.: National Academy of Sciences, Publication No. 1683.

FSN

 

By |2018-11-12T13:48:56+00:00November 12th, 2018|

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