By Steve Suppan, Institute for Agriculture and Trade Policy
With Thanksgiving and Christmas comes the U.S. Department of Agriculture’s reminder to cook turkey to 165 degrees to kill salmonella, a harmful bacteria, as in “Why a Salmonella Outbreak Shouldn’t Ruin Your Thanksgiving.” The reminder is particularly timely since an outbreak of salmonella-infected turkey resulting in foodborne illness was officially detected a bit more than a year ago. USDA, while active in detecting the slaughterhouse sites of the infected turkey, has yet to name those sites publicly and issue a whole turkey or turkey parts recall. USDA has recalled Jennie-O ground turkey products and issued a list of retailers carrying those products.
This inadequate response should raise serious questions about the proposed USDA takeover of all federal food safety duties. In July, the Trump administration proposed to transfer the food safety duties of the Food and Drug Administration (FDA) to the USDA. The proposal has many hurdles to realization, not the least of which is that new legislation would be required to transfer to USDA the duties assigned to FDA in the Food Safety Modernization Act. Even if such legislation were proposed, any Congressional hearings on the proposal must review USDA’s performance history of protecting consumers, other than reminding them of how to prepare turkey and other foods to prevent foodborne illness.
On November 15, the Safe Food Coalition asked the USDA’s Food Safety Inspection Service (FSIS) to declare a public health alert and recall turkey products from the 22 slaughterhouses and seven processing plants where FSIS identified the presence of Salmonella Reading, a particularly virulent serotype that is resisting a multi-drug antibiotic given to consumers of the infected turkey. The letter noted that FSIS’ recommendation for “proper handling” of turkey, with separate knives, cutting boards and preparation areas, “subjects consumers to an unrealistic standard for ‘proper’ handling and cooking.” The groups added that the “World Health Organization has estimated that cross-contamination [e.g. between infected meat and fresh vegetables] causes ten times as many Salmonella infections as eating undercooked poultry.” FSIS rejected the Safe Food Coalition request, characterizing it as “Monday morning quarterbacking” by NGOs in comfortable offices remote from turkey production facilities.
However, despite the dismissal of the Safe Food Coalition letter, on November 26, FSIS released data, naming names, on chicken processing plant compliance with FSIS permitted salmonella thresholds. For the first time in the FSIS monthly salmonella performance report, the data were based on sampling of chicken parts, which consumers commonly eat, rather than of whole chicken carcasses. Performance grades varied greatly. For example, Tyson Foods slaughterhouses complied with the performance standard, while three-quarters of Perdue Farms slaughterhouses did not.
The Centers for Disease Control and Prevention (CDC) have laboratory confirmed 164 cases of the Salmonella Reading strain in turkey, which has caused one death and 63 hospitalizations in 35 states as of November 5. The first case was detected on November 20, 2017. According to an undated presentation by Dr. Patricia M. Griffin, Chief of the CDC’s Enteric Diseases Epidemiology Branch, based on 2015-2017 data, the CDC estimates there are 29 cases of all serotypes of Salmonella infection for every laboratory confirmed case (slide 7). (This presentation, “Salmonella Enteritiditis Infections in the United States,” is not posted to the CDC website.)
Thanks to Food and Water Watch’s analysis in September of data obtained through the Freedom of Information Act, we know that of 34 chicken processing plants that failed to meet the FSIS permitted thresholds for salmonella, 16 had implemented FSIS’s New Poultry Inspection System (NPIS). NPIS, launched in 2012, delegated FSIS inspection authority to chicken and turkey slaughterhouses and processing plants. The purpose of NPIS was to “modernize” poultry inspection to reduce the incidence of salmonella and other foodborne illness-causing pathogens.
However, under NPIS, plant inspectors have as little as one second on average to determine if a turkey carcass meets FSIS standards. According to a Food and Water Watch letter to USDA’s Acting Undersecretary for Food Safety, FSIS inspectors are pressured by poultry processing plants to maintain line speeds and not interrupt production, even when inspectors report fecal matter on carcasses. A Food and Water Watch press release cited Stan Painter, Chairman of the National Joint Council of Food Inspection Local Unions: “I have been an inspector for over 30 years and inspection has deteriorated because FSIS management has permitted it to do so.”
Even if the FSIS privatized inspection program performed as promised to reduce pathogen levels and foodborne illness from meat and poultry products, however, consumers cannot be complacent about what is on their plate, at Thanksgiving or any time of the year. On November 20, the CDC reported that 32 consumers in 11 states had become sick from eating E. coli contaminated romaine lettuce. The CDC advised consumers to throw out their romaine lettuce, even if they had not become ill by eating it.
On Thanksgiving Day, FDA Commissioner Scott Gottlieb tweeted to explain the November 20 alert, “Some lettuce packing is labeled in a way that doesn’t make it clear where the product was grown. If you look at a package of lettuce, it’s most likely going to have the address of the company on the back; not the location of the growing fields.” Produce industry officials urged FDA to identify the growing region of the infected romaine lettuce, so that shipping of the product could resume from uninfected growing regions.
On November 26, FDA announced that romaine lettuce not grown in the Central Coast region of central and northern California was safe to eat, if the growing region and harvest date were clearly labeled on the lettuce packaging or on a retail sign if the lettuce was not packaged. Over Thanksgiving weekend, FDA and the Produce Marketing Association agreed on a voluntary labeling plan for romaine lettuce. FDA Commissioner Scott Gottlieb announced, “The leafy greens industry has agreed to establish a task force to find solutions for long term labeling of romaine lettuce and other leafy greens for helping to identify products and to put in place standards for traceability of product.” The plan for long-term labeling of leafy greens follows repeated infected produce outbreaks.
As of June 2018, the CDC had not been able to determine the origin of an outbreak of E. coli (STEC) contaminated romaine lettuce that had first been detected in late 2017. The FDA concluded in May 2018 that there had been yet another outbreak of pathogenic E. coli contaminated romaine lettuce: “Any contaminated product from the Yuma [AZ] growing region has already worked its way through the food supply and is no longer available for consumption.”
As IATP noted in June about that FDA conclusion: “If these words were intended to comfort consumers, a highly-detailed diagram in the blog, redacted to prevent publication of what FDA regarded as Confidential Business Information (CBI) (i.e. the commercial contamination sites), will irritate, if not infuriate, them.” The categorization of public and environmental health information as CBI, together with the failure of FDA and USDA to work to prohibit and prevent the fertilization of fields with non-composted manure from Confined Animal Feed Operations (CAFOs), all but ensures that leafy greens will continue to be a high-risk food every day. Because pathogenic E. coli is in the romaine lettuce tissue, no chemical rinse can disinfect it—few would wish to eat leafy greens cooked to 165 degrees.
Although the FDA has the legal responsibility to prevent contamination of horticulture products, it cannot do so without the cooperation of the USDA. The Food Safety Modernization Act requires FDA to develop standards for biological soil amendments, and FDA has approved two scientifically validated methods for composting manure to reduce pathogens. However, FDA does not have the staff nor the infrastructure in the field to determine if CAFOs manage and apply manure in a way that prevents pathogens from entering fruit and vegetable plant tissues when that manure is applied on fields. USDA has staff that it could use to help implement FSMA manure standards, but it doesn’t do so.
Indeed, proponents of having USDA take over FDA’s food safety duties should read the series of USDA Office of the Inspector General audits and General Accountability Office (GAO) reports that have documented FSIS shortcomings to effectively manage its present duties. For example, a GAO report from March 2018 notes that FSIS has yet to develop Salmonella standards for turkey breasts and other commonly consumed meat products, such as pork chops. To judge by these audits and reports, FSIS is struggling to carry out its present obligations and must not be the headquarters for all federal food safety duties.