This report examines the legal and scientific foundations for USDA policy on Salmonella in raw meat and poultry, and the consequences of that policy for public health. The report explains the discrepancy between federal regulators’ treatment of Salmonella and that of other pathogens considered “adulterants,” such as E. coli O157:H7, and shows how the policy gap has resulted in poor compliance and stymied progress on reducing the stubbornly high rate Salmonella infections. USDA has claimed that the law restricts how it enforces Salmonella rules. CFA’s analysis, however, demonstrates that this legal interpretation relies on outdated precedent—particularly the D.C. Circuit court’s 1974 decision in American Public Health Association v. Butz—that is unsupported by science. Finally, the report describes what has worked to reduce Salmonella illness in other countries, and proposes five policy options that regulators could use under current law to better protect consumers.
