In a new report, the Consumer Federation of America examines the legal and scientific foundations for USDA policy on Salmonella in raw meat and poultry. The report explains why the law authorizes federal regulators to treat Salmonella as an adulterant in raw meat and poultry, and it describes five policy options for harnessing new research and technology to protect public health.


The report shows that reforms to reduce Salmonella in raw meat and poultry are not only long overdue, but also legally and economically feasible. In particular, the report finds that:

  • Lack of enforcement has led to widespread incompliance with Salmonella standards introduced in response to recent outbreaks.
  • Progress on reducing Salmonella infections in the U.S. has stagnated for over a decade, with five large outbreaks associated with meat and poultry occurring in just the last year.
  • Many Salmonella reduction strategies with proven effectiveness, particularly on-farm, are not applied by major U.S. companies.
  • Federal regulators have refused to adopt common sense policies on the basis of legal precedent that is woefully outdated and scientifically wrong.Conclusion and Recommendations

    The report urges USDA’s Food Safety and Inspection Service to announce an interpretiverule under which the agency will consider raw meat and poultry “adulterated” if it iscontaminated with Salmonella. The report describes the pros and cons associated with five policy options for implementing such a rule, namely:

  • A zero tolerance approach to all Salmonella
  • Prohibiting particular Salmonella serotypes associated with human illness on rawfoods
  • Prohibiting Salmonella strains associated with an ongoing outbreak
  • Prohibiting Salmonella resistant to certain medically important antibiotics

• Prohibiting high loads of Salmonella bacteria

The report explains why any of these policies would protect public health better than the status quo.

Foodborne Illness Statistics

Each year 48 million Americans are sickened, 128,000 are hospitalized and 3,000 die from foodborne disease. (CDC, 2011)

Between 2009 and 2015, 35% of outbreak associated illnesses were attributable to meat and poultry products. (CDC, 2018)

The medical costs of treating Salmonella infection in the U.S. is estimated to exceed $3.7 billion each year. (USDA ERS 2014)


1905 – Upton Sinclair publishes The Jungle. Six months later, Congress passes the Federal Meat Inspection Act (FMIA).

1974 – The D.C. Circuit rules in American Public Health Association v. Butz that Salmonella is not an adulterant under the FMIA or PPIA because “American housewives and cooks normally are not ignorant or stupid and their methods of preparing and cooking of food do not ordinarily resultin salmonellosis.”

1993 – E. coli O157:H7 outbreak in the Pacific Northwest linked to Jack-in-the-Box causes 400 illnesses and four deaths. A year later, Administrator Michael Taylor announces that FSIS considers “raw ground beef that is contaminated with E. coli O157:H7 to be adulterated”under the FMIA.

July 25, 1996 – FSIS issues landmark Pathogen Reduction/HACCP Systems rule.

December 6, 2001 – Fifth Circuit Court of Appeals rules in Supreme Beef Processors, Inc. v. USDA that FSIS cannot take enforcement action against meat processors on the basis of Salmonella testing results alone.

November 17, 2003 – European Commission issues Salmonella control rule that targets certain serotypes in livestock.

August 3, 2011 – Cargill Meat Solutions, Inc. recalls 36 million pounds of turkey for suspected contamination with Salmonella Heidelberg implicated in 136 illnesses and one death.

July 12, 2014 – Foster Farms recalls an “undetermined amount” of chicken products for suspected contamination with Salmonella Heidelberg implicated in 634 illnesses.

February 11, 2016 – FSIS finalizes updated standards for Salmonella and Campylobacter in ground poultry and poultry parts.

November 23, 2018 – FSIS publishes data indicating nearly all major poultry companies are operating plants that fail to comply with the new rules.