September 2, 2021

The Honorable Thomas J. Vilsack

U.S. Department of Agriculture

1400 Independence Ave., S.W.

Washington, DC 20250

RE: Poultry Food Safety Improvements

Dear Secretary Vilsack,

The undersigned coalition of food safety leaders, including public health and consumer advocates, 

scientists, and members of the food industry, request a meeting with you to discuss the United States

Department of Agriculture’s (USDA) regulatory approach to ensuring the safety of poultry.

Foodborne pathogens remain a significant threat to public health in the United States, sickening millions 

of Americans annually. Salmonella and Campylobacter, which are commonly found in poultry, account 

for over 70% of all foodborne illnesses tracked by the Centers for Disease Control and Prevention. 

Annually, these two pathogens cause approximately 3 million illnesses in the U.S. and cost over 6 billion 

dollars. 

In 2010, the Department of Health and Human Services (HHS) included foodborne illness reduction 

in its Healthy People 2020 national public health goals, setting targets for lower Salmonella

and Campylobacter illness rates. Unfortunately, these target rates were not met. Rather, recent 

surveillance data indicate that the rates did not decrease from 2010 to the present and have been 

persistently high for the last 20 years. Last year, HHS released the Healthy People 2030 goals 

and again included both Salmonella and Campylobacter illness rate targets, but they are essentially the 

same as in the 2020 goals. A better approach to meet these goals is needed.

While progress on reducing foodborne illness has been at a standstill, scientific knowledge of 

Salmonella has greatly increased and recognized best practices for Campylobacter and other pathogens 

have advanced. Science tells us that current performance standards do not effectively target the particular 

types of Salmonella and the levels of bacteria that pose the greatest risks of illness, and the overall 

regulatory framework does not adequately harness modern tools for preventing and verifying control of 

the bacteria that are making people sick. 

This combination of stagnant illness rates, outdated USDA food safety standards and policies, and 

increasing scientific knowledge has led the undersigned parties to unite behind the following conclusions 

and principles:

• While current prevalence-based pathogen reduction performance standards are leading to reduced 

Salmonella levels in products, the performance standard method is broken and the standards are 

not producing the desired public health outcomes.

• Modernized standards should be objective, risk-based, achievable, enforceable, and flexible 

enough to adapt to emerging evidence and the latest science. Modernized standards should not 

stifle innovation. Instead, they should invite innovation and technology development.

• While the USDA Food Safety and Inspection Service (FSIS) cannot directly regulate food safety 

practices on the farm, a modernized Hazard Analysis and Critical Control Point (HACCP)

framework should address risk reduction across the full production process from raw material to 
finished packaging, including defining the responsibility of poultry processors to consider preharvest practices and interventions in their HACCP plans and verify that suppliers of live birds 

have implemented scientifically appropriate risk-reduction measures in accordance with modern 

best practices. 

• Salmonella and Campylobacter should be addressed in parallel but separate proceedings as larger 

knowledge gaps exist for Campylobacter than Salmonella and different timelines and risk 

mitigation approaches may be necessary. The coalition strongly encourages USDA to review and 

reinvigorate programs around Salmonella that exist within the National Poultry Improvement 

Plan.

• While the science has advanced sufficiently to support regulatory improvements today, ongoing 

research is also needed to support continued progress towards reducing Salmonella and 

Campylobacter moving forward, including epidemiologic data and analysis to improve attribution 

of illness to specific commodities and products.

In order to finally make public health progress on Salmonella and Campylobacter illnesses and meet the 

Healthy People 2030 targets, significant change in the FSIS regulatory program is needed, guided by 

these principles.

We would appreciate the opportunity to meet with you to ensure that USDA prioritizes making 

meaningful changes in food safety regulation and policy.

Sincerely,

Mitzi D. Baum

Chief Executive Officer

Stop Foodborne Illness 

Scott Brooks 

Senior Vice President 

Food Safety & Quality Assurance

Tyson Foods

Amanda Craten

Mother of Salmonella Illness Survivor

Gilbert, Arizona

David Clubb 

Salmonella Illness Survivor

Houston, Texas

Scott Faber 

Senior Vice President

Government Affairs

Environmental Working Group

Dianna Goodpasture

Salmonella Illness Survivor

Barberton, Ohio

Mary Graba 

Campylobacter Illness Survivor

Dayton, Minnesota

Thomas Gremillion 

Director of Food Policy 

Consumer Federation of America 

Craig W. Hedberg

Professor and Interim Division Head

Division of Environmental Health Sciences

University of Minnesota

Alice Johnson 

Senior Vice President 

Food Safety

Butterball LLC

Melissa and Ruby Lee

Mother and Salmonella Illness Survivor

Sandy, Oregon
Jerold R. Mande

Senior Advisor to the President

Center for Science in the Public Interest

Former USDA Deputy Under Secretary, Food 

Safety 

Steven Mandernach

Executive Director 

Association of Food and Drug Officials

Bryan Miller

Vice President

Quality Assurance and Food Safety

Wayne Farms LLC

J. Glenn Morris, Jr. 

Professor and Director 

Emerging Pathogens Institute 

University of Florida 

Michael Robach

Chief Executive Officer

The Robach Group LLC

Brian Ronholm 

Director of Food Policy 

Consumer Reports 

Former USDA Deputy Under Secretary, Food 

Safety

Sarah Sorscher 

Deputy Director 

Regulatory Affairs 

Center for Science in the Public Interest 

Bruce Stewart-Brown

Senior Vice President

Technical Services and Innovation

Perdue Farms

Michael R. Taylor 

Board Member

Stop Foodborne Illness 

Former USDA FSIS Administrator and Acting 

Under Secretary for Food Safety

Martin Wiedmann 

Professor, Food Science 

Cornell University