The undersigned members of the Safe Food Coalition write to oppose the Food Safety and Inspection Service’s (FSIS’s) proposal to eliminate rules requiring the cleaning of hog carcasses prior to any incision, codified at 9 C.F.R. 310.11. Contaminated pork represents a serious public health burden in the United States, causing over half a million cases of foodborne illness each year. Consumers deserve better protections against harmful pathogens in pork, from government and industry alike. We acknowledge that shifting from a “command-and-control” approach to more performance-based criteria in regulations could ultimately benefit consumers. However, FSIS has failed to maintain meaningful performance-based criteria for hog slaughter. As a result, the proposed action presents an unacceptable risk of hurting consumers.

Prior to making the proposed changes, FSIS should:

  • Implement meaningful Salmonella reduction performance standards for pork products;
  • Publish the identities of pork processors that fail to meet performance standards, as the agency does for poultry processors;
  • Evaluate the impact that removing carcass cleaning requirements has had on pathogen levels in plants that have received waivers from the regulation;
  • Develop a plan to evaluate the food safety impact of the proposed action across all plants.

These measures, at a minimum, are needed to support FSIS’s claim that the carcass cleaning requirements are “unnecessary,” and to ensure that the “more efficient” procedures adopted in the wake of this rulemaking do not compromise food safety.

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