Historically, USDA FSIS has not considered Salmonella an adulterant in raw meat and poultry because the organism is killed during ordinary cooking of products. However, as part of the agency’s Framework to Reduce Salmonella, FSIS recently proposed declaring Salmonella an adulterant in raw breaded stuffed chicken products.
Because breaded stuffed chicken products may appear ready-to-eat to a consumer, but are actually raw, FSIS determined consumers may only reheat the products instead of fully cooking. FSIS studies found consumers believed these products to be ready-to-eat, even when the product labels specified the products were raw. The reheating process undertaken by consumers is unlikely to kill any Salmonella present, and therefore, any Salmonella present could pose health concerns. In addition, FSIS stated these types of products have been associated with a number of Salmonella outbreaks historically.
The agency determined existing labeling controls are insufficient to address the public health risk of Salmonella associated with these products, and as such, proposed declaring Salmonella an adulterant in raw breaded stuffed chicken products. The proposal, if finalized, would cause a raw breaded stuffed chicken product to be adulterated if the product contains Salmonella at a level of 1 colony forming unit (CFU) per gram or higher.
Comments on the proposal can be submitted until June 27, 2023 on Regulations.gov.
Liz Presnell is a food industry consultant and lawyer and has worked in the food industry for nearly a decade. She can be reached at presnell@foodindustrycounsel.com.