Although food recalls were down in 2024, as TAG illustrated in a previous article, the same was not true of serious illnesses and deaths from pathogenic contamination in foods. In fact, a new report from PIRG shows that hospitalizations and deaths from food contaminated with Salmonella, Listeria, or E. coli doubled in 2024; and the 2024 recalls from these specific bacteria actually increased by 41%, with 22% of all food recalls caused by Listeria contamination, 14% by Salmonella, and 3% by E.coli.
What does all this tell us? While the industry needs to be proactive – and, yes, reactive – to the food additive bans being enacted by states and planned by the new Administration, it is imperative that we not take our foot off the gas around managing micro issues. The report notes that nearly 1,400 people were sickened by contaminated food in 2024 … and that is only those reported and related to an outbreak recall. To put that into perspective, CDC estimates that less than 5% of lab-confirmed foodborne illnesses are related to outbreaks, with significantly higher numbers of foodborne contamination being sporadic illnesses not linked to outbreaks, resulting in an estimated 48 million people in the US sickened by foodborne illness each year, with 128,000 of those hospitalized, and 3,000 deaths.
In spite of such numbers, factions of both the industry and the government are working against increased protections. Take, for example, Salmonella. In July 2024, USDA-FSIS published an advance copy of a new regulatory framework for Salmonella in raw poultry products which would set the tolerance for any type of Salmonella at less than 10 CFU per gram/ml, and deem as an adulterant any detectable level of Salmonella serotypes of public health significance.
However, not only is industry pushing back on the proposed regulation, but a House bill was introduced in February entitled, “To prohibit the use of Federal funds to implement Salmonella framework for raw poultry products.” Even without the bill, the Executive Order for a Regulatory Freeze Pending Review on any regulatory action remains in effect, and with the current federal food activity heavily focused on additives and heavy metals, the Salmonella regulation is unlikely to take any precedence. Further, as we stated when the regulatory framework was proposed, should all else fail to keep the framework from being enacted by interested persons, the Chevron ruling (discussed in a recent TAG article) could be brought to test to usurp the authority of USDA to finalize the rule.
In a similar vein, an EPA proposed amendment to the Meat and Poultry Products (MPP) category regulation would add E. coli bacteria limitations for direct dischargers, and extend coverage to include indirect dischargers. The proposed rule is intended to improve water quality and protect human health and the environment by reducing the discharge to US surface waters. As the comment period has just ended, this rule is unlikely to move forward quickly anyway, but it will be interesting to watch where it does go – particularly with OMB’s January withdrawal of the proposed rule limiting PFAS discharged into water and the Supreme Court having recently limited the EPA’s authority to impose water quality standards.
In relation to Listeria, FSIS did begin broader Listeria species testing to all samples of ready-to-eat product and environmental and food contact surfaces in January, with a plan to add additional species testing to help provide more information about the effectiveness of a facility’s sanitation program and signal if follow up is needed. However, the furtherance of that plan will now be limited, as the FSIS approach was to “leverage the expertise of its National Advisory Committee on Microbiological Criteria for Foods (NACMCF)” which would “be given the specific charge of reviewing the agency’s regulatory approach to Listeria monocytogenes.” However, the NACMCF (along with the NACMPI) was disbanded in early March by the Trump Administration.
Given such actions, and the additional challenges the industry is facing in determining how to best mitigate the impact of the tariffs, declining trade relations, and disrupted supply chains, it can be difficult to maintain a priority focus on microbiological concerns. But given, as well, the increase in extent and severity of foodborne illnesses, it is imperative that pathogenic contamination not be relegated to the back seat but be a primary driver in all aspects of your food safety and quality assurance programs and practices regardless of outside influences. If your product causes foodborne illness in an outbreak or in a single person, it can have serious public health, and business, consequences.
All this distills down to an increasingly complex regulatory and public health environment for the food industry. Recognizing that microbiological contamination is typically found quickly and may have immediate reputational and regulatory consequences, there is a need to maintain focus in this risk area. On top of that is the significant increase in focus on chemical residues that has no clear line of sight of where it is going over the next several years. Thus, maintaining insight and understanding of how to stay informed and balance all of the risks is key to navigating this increasingly complex regulatory and public health environment.
Give TAG a call for a review of your programs or assistance in pathogen mitigation.
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