Salmonella in Certain Not-Ready-To-Eat Stuffed Chicken Products

The American Frozen Food Institute (AFFI) appreciates the opportunity to provide input to the U.S. Department of Agriculture (USDA) Food Safety and Inspection Service (FSIS) regarding the proposed determination regarding "Salmonella in Not-Ready-To-Eat Breaded Stuffed Chicken Products" (the Proposed Determination). From manufacturers to distributors to suppliers to packagers, AFFI is proud to represent publicly traded and family-owned companies that help produce frozen foods and beverages for today's retail marketplace and serve as economic pillars within their communities. AFFI member companies include manufacturers of not-ready-to-eat (NRTE) breaded stuffed chicken products that would be directly affected by the Proposed Determination, as well as numerous manufacturers of frozen NRTE products regulated by FSIS and the Food and Drug Administration (FDA). AFFI members share a deep commitment to ensuring frozen foods are consumed safely and are labeled to provide consumers with clear instructions for safe handling and preparation. AFFI members also share FSIS's commitment to using science-based decision making to advance public health and make our nation's food supply even safer. To that end, AFFI members have, on their own and through the Frozen Food Foundation, committed substantial resources to advance food safety science. AFFI appreciates FSIS's interest in advancing the safety of frozen NRTE breaded stuffed chicken products, as well as efforts to identify and apply learnings from past foodborne illness outbreaks. However, we are concerned that the food safety science and pathogen testing technology are not sufficiently advanced to support such a substantial change in Agency policy toward Salmonella in NRTE products. We urge FSIS to ensure the scientific literature has fully developed before further pursuing the Proposed Determination. While the science continues to develop, AFFI supports FSIS taking additional steps, including those recently recommended by the National Advisory Committee on Meat and Poultry Inspection (NACMPI) and requested in a citizen petition, to continue improving the public health profile for this product category. AFFI offers the attached comments on FSIS's proposal.