Salmonella: Latest Happenings

Barb Masters

OFW Law

April 15, 2015

Salmonella

• FSIS received a petition to make certain ABR serotypes adulterants in raw ground beef (Newport and Typhimurium) and raw ground poultry (Hadar and Heidelberg)

• FSIS denied the petition without prejudice They were not precluded from submitting a revised

petition with additional supporting information.

Salmonella

• A second petition was submitted requesting that “ABR Salmonella Heidelberg, ABR Salmonella Hadar, ABR Salmonella Newport, and ABR Salmonella Typhimurium when found in meat and poultry, to be adulterant

FSIS has not responded to this petition

Salmonella (raw product)

• If at any point FSIS determines there is specific product (specific lot, specific product date) in commerce making people sick… They WILL ask for a voluntary recall of that specific production of product.

Outbreak Recall

• For a regulatory agency to “request” a recall, all four of the factors below must be present:1. There were related illnesses (an outbreak) as determined

by the DNA analysis of samples from case patients,

2. The evidence supports the conclusion that the likely source of the illnesses was a specific product,

3. The plant produces that specific product, and

4. A specific production of that plant’s product was purchased by, or available to, the case patients at the time and location of the illnesses.

Salmonella In Poultry

• Once tied to an outbreak it “appears” the Agency is considering the “strain” of Salmonella an adulterant in that facility (it is entering the facility and creating insanitary conditions)

Salmonella Action PlanOutlined the steps that it would to address Salmonella in

meat and poultry products

Poultry Slaughter Rule

Test comminuted poultry to develop performance standards

Exploratory sampling for pork products

In-plant training activities

Evaluation of PHIS data

Focus on Sanitary Dressing in Hogs

Enforcement Strategies

Lymph nodes in cattle

Pre-Harvest

Salmonella Action Plan – Year One Update

• Final Rule for Poultry Slaughter Modernization

Indicate implementation later this year…

“Rolling implementation”

• All establishments were required to incorporate written program to control contamination from enteric pathogens and fecal throughout the entire slaughter and dressing operation (process control) and a microbial sampling program to verify the effectiveness of the written procedures.

• Voluntary for establishments to incorporate sorting of carcasses

▪ Increase of linespeeds up to 140 bpm in plants that sort birds.

Salmonella Action Plan – Year One Update

Proposed performance Standards for poultry parts and comminuted products

Extended comment period

Anticipate once finalized –• End of set letters with results and serotypes (as today)

• Follow-up sampling (16 or 8 depending on plant size)

• FSA in plants not meeting standards (or questionable process control)

▪ Enforcement action based on FSA results

Product Salmonella Standard Campylobacter Standard

Comminuted Chicken 13/52 or 25% 1/52 or 1.9%

Comminuted Turkey 7/52 or 13.5% 1/52 or 1.9%

Chicken Parts 8/52 or 15.4% 4/52 or 7.7%

Salmonella Action Plan – Year One Update

• FSIS announced for poultry will publish all Categories (1, 2 and 3)

• FSIS moved to a “moving window” for all products under performance standard

To ensure consistent sampling through out year to demonstrate process control

• Anticipate additional Cat 2 and Cat 3 plants due to seasonal variations (in all products under standards)

• “Moving window” begins for poultry carcasses May 1st

Draft Salmonella Compliance Guidelines: Market Hogs

• According to FSIS - between 2000 and 2007, approximately four outbreaks and one hundred and two illnesses per year, on average, have been associated with pork. These estimates were calculated for outbreaks where pork was sole implicated food vehicle or identified as the sole contaminated ingredient.

Salmonella in Market Hogs

• FSIS focused on pork - yet the baseline data suggests very low Salmonella numbers on carcasses

• No recalls for outbreaks in pork products

• Area to continue to study outbreaks – identify “lessons learned” and determine real causes and prevention

Salmonella in Market Hogs

• FSIS historical data – head cheese (lymph node association?)

• Foodborne Outbreak Online Database (FOOD) primarily “BBQ pork” and roasted pork

FSIS has issued information on BBQ at the establishment level

• Spices?

Allergens and micro count should be considered

Salmonella Action Plan – Year One Update

• Initiated exploratory sampling in pork

FSIS collected and analyzed (for Salmonella) approximately 120 ground samples at retail.

In FY 2015, FSIS will conduct a two phase program• initially collecting approximately 1200 various cuts from

establishments. These will be analyzed for Salmonella at a contract laboratory.

▪ Based on the results, FSIS will target specific cuts (and possibly ground) and collect another 1800 samples. These will be analyzed for Salmonella as well as non-traditional pathogens such as MRSA and toxoplasma.

▪ FSIS will use this information in updating pork performance standards.

Salmonella Action Plan – Year One Update

• The exploratory sampling is “truly exploratory”

What is the possible pathway for Salmonella in pork?

• An internal draft FSIS Directive for Sanitary Dressing in swine has been developed

working on training prior to issuing the Directive

Salmonella Action Plan – Year One Update

• FSIS is evaluating lymph nodes in cattle

FSIS partnered with other USDA agencies to evaluate the potential contributions lymph nodes make to Salmonella contamination.

The percentage of samples that tested positive for Salmonella is significantly lower in the AMS-purchased ground beef for school lunch compared to all FSIS sampled ground beef, however

the differences could not be directly attributed to the presence or absence of lymph nodes because of other confounding factors.

Salmonella Action Plan – Year One Update

FSIS continues to review information on how inspection and inclusion of different lymph nodes in ground beef affects Salmonella contamination in the product. Findings will be incorporated into future revised slaughter guidance materials.

Salmonella in Ground Beef• Considerable research on lymph node

contamination

Salmonella In Beef

• Not just a sanitary dressing – multiple hurdle/cold chain management approach to address

• Pre-harvest

Vaccines

Direct fed microbials

????

Salmonella Action Plan – Year One Update

• Pre-Harvest

Pre-harvest contamination can affect the level of Salmonella on FSIS-regulated products.

Information about pre-harvest interventions was collected from previous public meetings and included in a new draft of a guidance document under development that is entitled FSIS Compliance Guideline for Controlling Salmonella and Campylobacter in Raw Poultry. The document is in Agency clearance.

• Anticipate continued “focus” on pre-harvest for all species.

Salmonella Action Plan – Year One Update

• Outreach

FSIS delivered a well-received Salmonella blog on FoodSafety.gov in 2014.

In June 2014, the Agency conducted two Twitter chats about Salmonella.

New Public Service Announcement on Salmonella

On the Salmonella Testing Methods Horizon

325 Gram Sample

• FSIS announced it would use a 325 gram analytical sample for Salmonella analysis with each STEC sample

Effect of increase on incidence unknown

• FSIS conducting 325 gram analytical sample for poultry

Incidence has increased - but not to degree FSIS anticipated

• FSIS announced (March 15) will conduct a 325 gram analytical sample for Salmonella analysis with each STEC sample for imported samples

Whole Genome Sequencing

• Genome is the genetic material of the organism, the complete package:

Gene and Chromosome

• By analysis, it is possible to plot out the entire DNA sequence of an organism.

Whole Genome Sequencing• To put in perspective, imagine the human genome is a

book -

The book (genome) would contain 23 chapters (chromosomes) and

Each chapter would contain 48 to 250 million letters (A,C,G,T) without spaces.

• The human genome book contains over 3.2 billion letters total.

• Salmonella is a “short story” in comparison, around 4.5 million letters depending on serotype.

Whole Genome Sequencing

• Genome Sequencing (GS) analysis is looking for differences at a single nucleotide — A, T, C or G – in the genome that is different between members of the same species

• Can use whole genome or “SNPs”

Whole Genome Sequencing

• In the future, the public health agency will run GS on any product samples, samples from case patients, and historically and geographically disparate food sources.

This will broaden the ability to identify the “culprit” food source.

• FSIS is part of a public health agency (FSIS, CDC, FDA) group determining how to use GS in the future.

Salmonella

In Conclusion…poultry• FSIS continuing to update performance standards

and include additional categories

• FSIS using moving window, posting all Categories

• FSIS adopting new inspection system to provide more “off-line” inspection tasks

• FSIS requiring establishments to have written process control programs and micro verification

• FSIS incorporating additional pre-harvest information in Compliance Guidelines

Salmonella

In Conclusion…pork• FSIS has a high priority focus on pork at this time….

• FSIS conducting exploratory sampling and intends to update performance standards

• FSIS issued draft Compliance Guidelines for Salmonella

• FSIS intends to issue sanitary dressing Directive

Salmonella

In Conclusion…beef• FSIS using moving window approach for performance

standards

• FSIS intends to issue sanitary dressing Directive

• FSIS evaluating how to significance of lymph nodes and how/where to incorporate

Questions