The Food and Drug Administration is more determined to squash “Bad Bugs,” setting its sights on Salmonella contamination in livestock and pet food. New regulatory guidance, posted on August 2, is open to comment for 90 days. Following that the FDA will edit the policy or release the guidance to its field investigators for action.
In summary: FDA’s new guidelines for its field staff gives them weapons to use in determining whether to seize contaminated animal feed and take enforcement action. The policy seeks to reduce risks to both humans and animals. Pet food found to contain Salmonella could be ruled adulterated because it is handled in the home and can be pathogenic to humans. Feeds for other animals containing Salmonella will also be considered adulterated when there is increased risk from feed contact with humans. Of course Salmonella also poses risks to poultry and livestock health. The FDA also seeks to reduce these threats by taking action when the Salmonella sub-species (serotype) is pathogenic to the target animal consuming the feed.
Although the entire policy is available for review on FDA’s web site, this bottom-line view of the plan’s details will help you easily see how it affects your business. The entire FDA policy can be found HERE.
Salmonella risks to humans
Although Salmonella are very common in the environment, health officials have singled out several species as risky bad-actors. As few as 15-20 bacterial cells can start an infection within 48 hours after contact. Between 40,000-50,000 Salmonella cases are reported each year in the U.S., and that number has increased dramatically in recent years. The number of unreported cases is much larger. FDA estimates Salmonella infects 2-4 million people in the U.S. annually. On average, about 1% of the cases result in death, however fatalities increase to 10-15% in certain circumstances.
The new policy guide proposes to reduce direct human exposure to Salmonella and also reduce animal infections which might be passed on to humans. FDA says a link between contaminated animal food products and human infection is well-established, and cites 4 notable cases of Salmonella-contaminated pet products leading to human outbreaks.
A quick summary regarding Salmonella and human health is available in the FDA’s “Bad Bug Book," found at the FDA’s website: HERE
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FDA’s enforcement recommendations
FDA field staff should ensure the following criteria are met before triggering product seizure and enforcement actions.
- Salmonella must be present in at least one feed or ingredient sample.
And:
- The product will not be commercially further processed with a heat treatment or other method to eliminate the Salmonella, or the investigator cannot determine if further processing will be conducted.
And:
- a. The Salmonella may be directly transmitted to humans who handle or eat the feed. FDA specifically lists pet food and treats for pets in homes, and animals in petting zoos and agricultural fairs.
Or:
b. The Salmonella serotype (subspecies) is a known pathogen for the target animal to be fed:
Milk replacers- Any Salmonella serotype
Poultry- S. pullorum, S. gallinarum, S. enteritidis
Swine- S. choleraesuis
Sheep- S. abortusovis
Horses- S. abortusequi
Dairy and Beef- S. newport, S. dublin
Reducing risk in the feed mill
This is not the first time FDA has highlighted Salmonella as an important hazard. In the Code of Federal Regulations 21: 500.35, FDA specifically named Salmonella as an adulterant in animal feeds and ingredients. Consequently, controlling Salmonella has become an integral part of many feed manufacturers’ voluntary HACCP programs, and FDA has included Salmonella contamination limits in the draft framework of their “modernized” Animal Feed Safety System (AFSS).
Some measures are available for feed manufacturers to improve ingredient hygiene. OrganiGuard® is an organically-based antimicrobial ingredient that inhibits bacterial growth. It is not an antibiotic, so it can be used in antibiotic-free programs or in combination with any medication regimen. It can easily be applied in liquid or dry form; and because OrganiGuard’s pH is neutral, it does not have the corrosive properties of acids. It has demonstrated superior protection against Salmonella, as well as other biological contaminants such as Aspergillus, Fusarium, and Penicillium molds.
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Antimicrobial comparisons by independent laboratory
Procedure: Culture plates were inoculated with 24-72 hour old Salmonella cultures. Competitive antimicrobial products were impregnated in ½ inch diameter sterile discs, and placed in the organism-inoculated plate within 15 minutes. The plates were incubated at 33-35ºC (91-95 ºF). All test samples and controls were run in triplicate.
Interpretation: In this type of comparison, effective antimicrobials prevent the organisms from growing in an area around the impregnated disc. The most effective antimicrobials produce large, clear zones with no organism growth around the sample (the “zone of inhibition”). The diameter of the zone indicates how powerful the antimicrobial product is.
Results: OrganiGuard® and the competitive products all exhibited antimicrobial activity. The larger sterile zones surrounding the OrganiGuard® discs (see figure) indicate more powerful protection against the contaminating Salmonella.
OrganiGuard’s average zone of inhibition against Salmonella was 47 mm, which was 31-135% larger than alternative products, confirming superior antimicrobial inhibition.
OrganiGuard’s powerful feed hygiene translates into more protection against both bacterial adulteration and molds. More importantly, it offers ingredient and feed manufacturers a better tool for HACCP and AFSS compliance, meaning more responsible and safer food products for livestock and pets.