Essentially, USDA/FSIS is treating Salmonella as an adulterant in this situation.

I mean, it is not a bad idea to protect school kids, but why the differences?

While you all were sleeping off your “turkey coma,” I was thinking about why Salmonella is not an adulterant by reading, Michael Ollinger, John Bovay, Casiano Benicio, and Joanne Guthrie. Economic Incentives to Supply Safe Chicken to the National School Lunch Program, ERR-202, U.S. Department of Agriculture, Economic Research Service, November 2015.

Here are the highlights:

The U.S. Department of Agriculture’s (USDA) National School Lunch Program (NSLP) provides subsidized and free meals to over 31 million qualified students across the United States each school day (USDA, FNS, 2013). Chicken is a major component of the meals served to students. Some of that chicken is purchased through typical commercial channels, but schools can also obtain it via the Poultry Products Purchase Program, which is administered by USDA’s Agricultural Marketing Service (AMS). The NSLP used about $9 million worth of raw and $240 million worth of processed chicken products in the 2009-10 school year (USDA, FNS, 2012). Most of the processed chicken used in the NSLP was purchased by AMS as raw product and then further processed by State agencies prior to distribution to schools. Like all chicken sold in interstate commerce, the chicken purchased by AMS for the NSLP must meet Federal food safety standards, including tolerances for Salmonella spp. established by the USDA’s Food Safety and Inspection Service (FSIS).

Proper cooking and handling of raw chicken can reduce the risk of foodborne illness by killing Salmonella and other pathogens. Nevertheless, Salmonella remains the second-most common
cause of foodborne illness in the United States, causing an estimated 1 million illnesses, 19,000 hospitalizations, and 380 deaths each year (Scallan et al., 2011). Schools generally use processed (precooked) products such as chicken nuggets, fajita strips, etc., in school meals (Hecht et al., 2008). Processing kills harmful pathogens if it involves cooking the meat to more than 165° Fahrenheit (Burr et al., 2005). Some school systems, however, contend that processing removes some control over the nutritional content of school meals, and purchase the raw commodity (Stanley and Conner, 2013).

Both raw and processed chicken products have been recalled in recent years for food safety reasons. Between 2009 and 2012, there were six recalls of processed chicken due to Salmonella contamination, amounting to nearly 8 million pounds. Processed chicken products have also been recalled due to contamination with Listeria monocytogenes, allergens, and other reasons. Additionally, Foster Farms recently recalled over 1 million pounds of raw chicken products due to excessive Salmonella. However, to our knowledge, there have been no product recalls of raw or processed chicken products purchased by AMS for the NSLP.

Previous research (Ollinger et al., 2014) showed that, from 2006 to 2012, ground beef sold to the NSLP performed better on Salmonella spp. tests than ground beef sold to the commercial market. AMS imposes a zero-tolerance standard for Salmonella spp. in ground beef, a higher standard than that required by FSIS for ground beef sold in general commerce. This may have incentivized suppliers of ground beef to the NSLP to be more diligent when fulfilling an AMS contract, but it also likely raised costs, since suppliers may have taken extra precautions to meet FSIS standards.

AMS does not impose stricter Salmonella tolerances for raw chicken sold to AMS for the NSLP relative to the FSIS standard. AMS selects the lowest cost bidder among all AMS-registered suppliers, as long as that bidder meets FSIS standards. The combined effect gives establishments an incentive to invest in food safety up to the point that the establishment just meets the FSIS standard. However, food recalls and other announcements about the safety of food products can affect demand and profit, leading to declines in the stock prices of implicated suppliers (Thomsen and McKenzie, 2001), and in some cases, bankruptcy (Andrews, 2012; Tavernise, 2013). A food safety recall from a school could be particularly costly because the NSLP is a highly visible program and subject to particular scrutiny, potentially resulting in a greater reputation loss than that which would occur in the commercial market for a similar event. Moreover, it may be easier to trace the AMS-purchased chicken served in schools to their suppliers than chicken sold in commercial markets, making a product recall more likely.

Traceability is the ability to identify the supply chain of a product. It enhances food safety because, if a food is linked to a foodborne illness outbreak or other public health threat, then the source can be identified and the producer can be managed by regulators and may be targeted by liability lawsuits. Traceability also helps pinpoint the location of products so they can be removed from the marketplace.

There are fewer AMS suppliers than suppliers in the broader commercial market since not all chicken plants are eligible to bid on AMS contracts. This smaller number of AMS suppliers facili- tates traceability because there are fewer possible sources, and public health officials can inspect shipping records to determine the suppliers most likely responsible for shipping food associated with outbreaks of foodborne illness. Traceability becomes more complicated if the school system buys identical products in the commercial market, since there are more suppliers.

This report investigates the food safety performance of suppliers of raw chicken purchased by
AMS for the NSLP. In particular, we examine whether concerns about reputation for food safety encourage AMS suppliers to outperform commercial-only suppliers on tests for Salmonella spp.
The results could have implications for the AMS purchase specifications and the FSIS food safety program and may help policymakers and private managers better understand the conditions under which stricter standards may be warranted, and those under which private incentives are sufficient to maintain food safety.

Some more recent papers with some interesting tidbits:

Ollinger, Michael, John Bovay. 2018. Pass or Fail: Economic Incentives to Reduce Salmonella Contamination in Ground Beef Sold to the National School Lunch Program. American Journal of Agricultural Economics.100:414–433,

“… the incentives generated by the zero-tolerance standard for Salmonella are highly effective: ground beef supplied to the NSLP is 21–22 percentage points more likely to meet a zero-tolerance standard for Salmonella than ground beef tested as part of typical meat-plant inspections.”

Ollinger, Michael, Matthew Houser. 2020. Ground beef recalls and subsequent food safety performance. Food Policy.  97:101971,

“The results show that plants have high Salmonella levels before and during the year of the recall and have much lower levels afterward.”

Ollinger, M. and Bovay, J. (2020), Producer Response to Public Disclosure of Food-Safety Information. Amer. J. Agr. Econ., 102: 186-201.

“We find that (1) announcements in 2003 and 2004 were associated with improved performance by the poorest-performing chicken-slaughter plants; (2) the introduction of an easily-understood measure of food-safety quality and the threat of disclosure of the identities of poorly performing plants in 2006 were associated with improved performance by all chicken-slaughter plants; and (3) implementation of a public disclosure program in 2008 was associated with improvements among better-performing chicken-slaughter plants.”

So, why zero-tolerance for Salmonella in ground beef at schools but not at the kids’ homes?