CFA and other members of the Safe Food Coalition submitted the following comments in response to the USDA Food Safety and Inspection Service’s (FSIS’s) proposed performance standards for Salmonella in ground beef and beef trim. The comments note that an update to the rules protecting consumers from Salmonella in these products is long overdue, and commend FSIS for taking action. The letter urges FSIS to go further, however, and to treat raw ground beef contaminated with Salmonella to be adulterated. The comments explain that such a policy is justified given the increasing virulence and frequency of antibiotic resistance in Salmonella; the risks posed by popular ground beef cooking and handling practices; the feasibility of a zero tolerance policy for Salmonella in ground beef, as demonstrated by the National School Lunch program; and the limitations that industry lawsuits have imposed on USDA’s capacity to enforce the proposed performance standards.