On March 12, 2018, the Canadian Food Inspection Agency (CFIA) announced that it will be “requiring industry to implement measures at the manufacturing/processing level to reduce Salmonella to below detectable amounts in frozen raw breaded products that are packaged for retail sale.” The initiative does not include stuffed raw breaded poultry products and any raw breaded products intended for restaurant and institutional use. The CFIA justified this move, saying that efforts initiated in 2015 requiring the “labelling on frozen raw breaded chicken products that included more prominent messaging such as ‘raw,’ ‘uncooked,’ or ‘must be cooked’ as well as explicit instructions not to microwave the product as well as adding cooking instructions on the inner-packaging bags,” had not worked. This whole thing baffles me, and here is why.

Disconnect between Health Canada & CFIA

The CFIA admits that strong food safety warnings on the front of package and cooking instructions on the inner package haven’t worked after three years. Given this evidence, one has to question the effectiveness of Health Canada’s (HC) proposed legislation on front-of-package nutritional labelling. Hopefully someone will point this out to HC.

Puzzling risk assessment

Setting the level of Salmonella “to below detectable amounts,” means that the organism will have to be virtually eliminated from the product. Aside from the technical challenges industry will face in trying to conform to this standard, there are questions about the degree of risk posed by Salmonella at various levels and the need to reduce it “to below detectable amounts.” For example, “category 2” ready-to-eat (RTE) products can carry up to 100 cfu/g of Listeria monocytogenes.

Codex guidelines recommend that the level of a hazard be reduced and limited to a level that provides the “appropriate level of protection” (ALOP), which rarely needs to be “below detectable amounts.” So what does the level of Salmonella in breaded products really need to be to reduce the risk of salmonellosis from  undercooking to an acceptable outcome? I doubt that it has to be “below detectable amounts.” Another question is what have other jurisdictions around the world done to mitigate this hazard and how effective have their measures been?

Substantial added cost to consumers & industry

Like Listeria monocytogenes, Salmonella is everywhere in our environment and is very hard, if not impossible, to eliminate in raw products using sanitation alone. Ionizing irradiation is arguably the most effective way but it poses some problems. One problem is that the public doesn’t understand ionizing radiation and products so treated have not been commercially successful. Secondly, even if the public suddenly accepted ionizing radiation, the infrastructure is not in place in Canada, which would delay compliance.

The rationale for raw-breaded vs  fully cooked products includes ease of production, lower cost, superior eating quality, longer frozen shelf life and a greater variety of products. Implementing measures to virtually eliminate Salmonella as currently proposed could have the  following effects:

• The retail prices of raw breaded poultry products could increase by as much as 50 per cent over current prices. This will force some consumers to make other food choices and thus drive down sales of these products.
• Processors unable to comply with the current proposal will have to forego supplying those products.
• Given that food processors survive on paper-thin margins, red ink could flow for those that depend on this category of products.
• There could be less variety of raw breaded poultry products on store shelves, or raw breaded poultry products might disappear from retail shelves altogether.

If the CFIA is determined to go ahead with this proposal as currently written, it should first pilot the program in a facility such as the Food Processing Development Centre in Leduc, Alta. Options so developed should then be field tested in at least two (small and large) processing facilities for up to a year to validate process effectiveness and the real costs. Let the CFIA know your thoughts on this at www.inspection.gc.ca. Act now!

Dr. R.J. (Ron) Wasik, PhD, MBA, CFS,  is president of RJW Consulting  Canada Ltd. Contact him at  [email protected]