February 2, 2022

Sandra Eskin

Deputy Under Secretary for Food Safety

Food Safety and Inspection Service

U.S. Department of Agriculture

Room: 201-W, Jamie Whitten Building

Delivered via electronic mail

Dear Deputy Undersecretary Eskin,

The undersigned members of the Coalition for Poultry Safety Reform, a multistakeholder coalition that 

includes individuals and organizations representing consumers, victims of foodborne illness, food safety 

scientists, current and former food safety officials, and members of the poultry industry, write to offer 

our recommendations for the agency’s recently launched effort to reduce Salmonella illnesses linked to 

poultry. 

We appreciate the commitment you and Secretary Vilsack have made to modernizing the FSIS 

regulatory program and agree that reducing Salmonella illnesses should be a top priority for the agency. 

Members of our coalition are likewise committed to do everything we reasonably can to prevent illness 

from Salmonella attributed to poultry. 

We urge the agency to focus its regulatory effort on developing new regulatory standards related to 

Salmonella covering both products and supply chains, and that these standards be informed by a risk 

assessment model based on existing data. We also ask that the agency set a specific timeline for issuing 

a proposed regulation to put this framework into effect.

I. FSIS Should Adopt Enforceable Product Standards Aimed at Reducing Risk of Illness, 

Combined with Standards to Ensure Supply Chain Risks are Appropriately Managed

The current standards for poultry, which aim to reduce human illnesses by categorizing establishments 

based on the prevalence of Salmonella positives in poultry products over a 12-month period, have not 

achieved their intended purpose. The standards were set with the objective of meeting the Healthy 

People 2020 goals established by the U.S. Department of Health and Human Services, which aimed to 

reduce Salmonellosis cases by 25 percent by 2020.

i,ii

The Salmonella performance standards did not achieve that goal. As the last decade came to a close, the 

incidence of Salmonellosis was, if anything, higher than it had been at the start, with 17.1 illnesses per 

100,000 population, compared to 15 at baseline (2006-8).

iii Even accounting for improved methods of 

diagnosis, this result cannot be regarded as anything but a clear failure.

Achieving better outcomes in the next decade will depend on the agency addressing fundamental flaws 

in its standards. In particular, the standards are not enforceable, fail to identify the products that are 

highest risk, and fail to ensure food safety from farm to fork. 

To address these flaws, we urge FSIS to adopt enforceable, science-based product standards aimed at 

reducing illness by removing the highest-risk products from commerce, combined with a standard to 

ensure supply chain risks are appropriately managed.

In developing the product standards, we urge FSIS to explore and, as discussed below, evaluate for their 

risk reduction potential a range of possible options to reduce risk. The standards should be designed to 
be achievable, and should also be designed to be revisited periodically, so that they can be adapted as 

control measures improve and the scientific understanding of risks evolves. For example, a standard that 

focuses initially on enumeration (quantification) of Salmonella spp., or focuses on a small number of 

priority serotypes could be adjusted to include new priority serotypes or to focus on specific virulence 

traits as new risks emerge. The key is to use the best science available to set standards that are 

effective in significantly reducing risk and can be updated as new science emerges.

The new product standard should be combined with a requirement that each regulated slaughter 

establishment, as part of its HACCP plan, develop, validate, and implement a supply chain program, to 

ensure that suppliers of live birds employ best practices (e.g., vaccination, sanitation practices) to 

control or mitigate identified hazards. Under this proposal, FSIS would not mandate specific on-farm 

practices, but would provide guidance on best practices and verify through inspection the 

implementation of the establishment’s supply chain program, similar to the approach it already applies 

to HACCP within establishments.

II. FSIS Should Develop and Apply a Risk Model to Understand the Illness Reduction 

Benefits of Various Product Standards

Prior to developing its new product standards, FSIS must consider public health goals for illness 

reduction, alongside what is achievable with current technology and management practices. As part of 

this assessment, the agency must develop a robust risk model to understand the illness reduction 

benefits of various product standards. This will facilitate a thoughtful assessment of the benefits of an 

array of approaches.

This risk model is an essential step that must be undertaken to assess public health impact before 

establishing a product standard.

The risk model should be informed by robust data, including:

• Product testing data, including enumeration and serotype data

• Human epidemiological data, including incidence of illness by serotype, dose-response 

effects, virulence by serotype, and antibiotic resistance by serotype

• Supply chain data, including enumeration and serotype data collected from live poultry, 

as well as pre- and post-slaughter testing 

The signatories to this letter are interested in supporting FSIS in developing this model. In particular, the 

academic partners in our coalition are prepared to provide assistance in developing the risk model, and 

the undersigned representatives of industry are interested in exploring means to share the product 

sampling data they have collected from various stages of production, to inform the agency’s risk 

assessment.

III. Publish a Timeline for Issuing Proposed Regulations

While the agency has declared a new effort to reduce Salmonella, it has not set a specific timeline for 

producing new regulatory standards. The poultry industry will need adequate time to adjust to any new 

proposed standards prior to their taking effect. Therefore, if FSIS aims to achieve public health 

improvements over the next decade, it is critical that the agency begin laying the groundwork now by 

communicating a clear timeline to stakeholders. 
We urge the agency to publicly commit to a timeline for issuing proposed regulations, which should be 

based on the risk assessment described above. This timeline is achievable because much of the data 

needed to inform such a proposal is already available in the public domain, or can be obtained 

voluntarily from industry.

FSIS has also expressed an interest in engaging in pilot projects to assess the efficacy of various 

Salmonella control and measurement strategies. While such pilots will undoubtedly provide useful data 

to the agency, they are not prerequisites to the development of a standard, and can therefore occur 

alongside the agency’s regulatory reform efforts, rather than postponing regulatory action.

We would like to request a meeting to discuss these matters further and, in particular, the specific next 

steps needed to establish a risk assessment model and to access the necessary data for that model, as 

well as a timeline for regulatory action.

Sincerely,

Alice Johnson 

Senior Vice President, Food Safety

Butterball LLC

Amanda Craten

Mother of Salmonella Illness Survivor

Gilbert, Arizona

Angie Siemens

Vice President, Food Safety, Quality & Regulatory 

Cargill Protein North America

Brian Ronholm 

Director of Food Policy 

Consumer Reports 

Former USDA Deputy Under Secretary, Food Safety

Bruce Stewart-Brown

Senior Vice President, Technical Services and Innovation

Perdue Farms

Bryan Miller

Vice President, Quality Assurance and Food Safety

Wayne Farms LLC

Craig W. Hedberg

Professor and Interim Division Head, Division of Environmental Health Sciences

University of Minnesota

J. Glenn Morris, Jr. 

Professor and Director, Emerging Pathogens Institute 

University of Florida 
James Kincheloe

Food Safety Campaign Manager

Center for Science in the Public Interest

Jerold R. Mande

CEO, Nourish Science

Former USDA Deputy Under Secretary, Food Safety 

Martin Wiedmann 

Professor, Food Science 

Cornell University

Michael Robach

Chief Executive Officer

The Robach Group LLC

Michael R. Taylor 

Board Member

Stop Foodborne Illness 

Former USDA FSIS Administrator and Acting Under Secretary for Food Safety

Mitzi D. Baum 

Chief Executive Officer 

Stop Foodborne Illness 

Sarah Sorscher 

Deputy Director, Regulatory Affairs 

Center for Science in the Public Interest 

Scott Brooks 

Senior Vice President, Food Safety & Quality Assurance

Tyson Foods

Scott Faber 

Senior Vice President, Government Affairs

Environmental Working Group

Steven Mandernach

Executive Director 

Association of Food and Drug Officials

Thomas Gremillion 

Director of Food Policy 

Consumer Federation of America
i Changes to the Salmonella and Campylobacter Verification Testing Program. 80 Fed. Reg. 3940 (January 26, 2015). 

https://www.govinfo.gov/content/pkg/FR-2015-01-26/pdf/FR-2015-01-26.pdf

ii Healthy People 2020. Food Safety. Last Updated 10/27/21. https://www.healthypeople.gov/2020/topicsobjectives/topic/food-safety/objectives

iii Tack DM, Ray L, Griffin PM, et al. Preliminary Incidence and Trends of Infections with Pathogens Transmitted 

Commonly Through Food — Foodborne Diseases Active Surveillance Network, 10 U.S. Sites, 2016–2019. MMWR 

Morb Mortal Wkly Rep 2020; 69: 509–514.