“While FSIS has traditionally viewed Salmonella as ‘naturally occurring’ in food animals, we are reassessing this interpretation as part of our Salmonella in poultry initiative and considering whether Salmonella should be considered an adulterant in any poultry products,” it continues,
FSIS says when it declared seven E. coli strains (O157:H7, O26, O45, O103, O111, O121, and O145) to be adulterants in many non-intact raw beef products and intact source materials for raw ground beef, that determination was based on, among other considerations, the fact that, for these strains, the infectious dose is low.
It said ground beef contaminated with these STEC strains may cause serious, potentially life-threatening, illnesses, and what many consumers consider to be ordinary cooking of ground beef does not destroy these pathogens.
“Regarding your arguments related to dose-response, serotypes, and virulence factors, we are reviewing the most up-to-date science to determine whether any Salmonella serotypes have a uniformly, relatively low infectious dose,” FSIS wrote to Marler. “As your petition acknowledges, the likelihood of individuals contracting salmonellosis is dependent on a variety of factors. Studies indicate that, in addition to serotype, the probability of illness associated with the dose of a pathogen may be influenced by variables including host factors and the food matrix.”
FSIS said Salmonella virulence factors, are not as well understood as for STEC strains. “Therefore, FSIS does not concur with the petitioners’ position that all of the identified serotypes in your petition necessarily represent strains with higher virulence in all meat and poultry products, ” it added.
FSIS addressed two other points in the Marler petition before telling the lawyer that he may submit a revised petition that contains additional information to support the requested or other action, Those two final points were:
- “First, although the petition refers to the identified serotypes as “Outbreak Serotypes,” not all are associated with human illness outbreaks caused by FSIS-regulated products,
- Second, the petition discusses FSIS’ decision to allow certain poultry establishments to increase line speed; it also addresses instances of inhumane handling and associated recalls.
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