June 2, 2022 Docket Clerk U.S. Department of Agriculture

To Whom it May Concern, The Center for Science in the Public Interest (CSPI)1 respectfully submits these comments to the United States Department of Agriculture’s Food Safety and Inspection Service (FSIS) on the above-referenced proposed pork Salmonella performance standards. [...] Though there are no standards for some products like the primal cuts of ham or loin, the targeted products represent the majority of the pork consumed in the United States.14 The proposed standards are based on a moving window of weekly Salmonella sampling of establishment products and allow for a maximum number of positive samples in the most recent 52-week period: 13 of 52 for raw comminuted por. [...] This factor likely contributed to the benefits of performance standards in poultry: FSIS began posting the performance categorization of poultry establishments in 2006, and in the four years following that move, Salmonella rates in poultry dropped 60%.23 Thus, we support the agency’s performance standard proposal for pork, as the additional pressure on establishments to prioritize Salmonella contr. [...] 4 This discrepancy between decreased Salmonella poultry carcass contamination and the unchanged human salmonellosis rate may be due to a variety of factors, including the lack of regulatory enforceability, an initially limited scope to a minority of poultry products, and the fact that the standards allow for substantial prevalence of contamination in many products. [...] One of the consistently most common serotypes in pork is Salmonella Anatum, representing about 10 percent of samples in 2021.35 Considering the total number of serotype-identified Salmonella cases detected in 2020 in the subset of the population in the Foodborne Diseases Active Surveillance Network in the United States (5895) and the most recent salmonellosis attribution estimate for pork (12.8 pe.