In addition to setting new performance standards, FSIS is also reaching out to retail establishments to ensure that when retail stores grind beef products, they keep accurate records of the raw source materials for all batches. The purpose of these requirements is to allow FSIS to better trace positive Salmonella samples and outbreaks back to the beef-processing establishment from which the contaminated raw materials originated. Notably, this is a rekindling of the same efforts FSIS employed years ago to enable the agency to better investigate and trace E. coli O157:H7 positive samples and outbreaks back to their original source.

In addition to these initiatives, FSIS intends to expand its use of Whole Genome Sequencing (WGS) as a tool to solve Salmonella outbreaks and illness clusters. If a sick consumer tests positive for Salmonella, WGS can be performed on the clinical isolate to determine its precise DNA signature, and the results will be uploaded into the GenomeTrakr database. If the isolate from a positive ground beef sample matches the clinical isolate in the GenomeTrakr database, then the agency will presume there is a connection between the positive samples. WGS has enabled FSIS to track numerous Salmonella outbreaks, that would have previously remained unsolved, back to their original source.

When outbreaks are traced to a specific processing establishment, the establishment may or may not elect to issue a recall. This is because we all know that Salmonella is not a per se adulterant in raw meat and poultry. Thus, when outbreaks occur, the implicated products often remain in commerce. Perhaps, in an effort to encourage companies in those circumstances to voluntarily recall their products, FSIS has announced it will engage in greater collaboration with the media. The agency stated in its Roadmap to Reducing Salmonella that such relationships with media promote dissemination of recall and public health alerts to notify the public when they should take action to prevent foodborne illness.” Thus, we predict that, in those instances when companies refuse to recall products, the agency may issue public health alerts, highlighting the company’s name and warning consumers to beware of its products.

Because the changes in Salmonella policy and response are creating new and heightened risk to processors, we strongly recommend that you carefully review and update your supplier agreements and insurance policies. Be sure to make sure that your supplier’s contractual indemnity obligations will be triggered in the event of a Salmonella recall and/or FSIS public health alert and that your insurance policy will, in fact, provide coverage. If not, quickly renegotiate the policy.

In the end, with all the uncertainty on the horizon, be sure to take precautions today, so that, tomorrow, Salmonella doesn’t slap you around.