…“products are adulterated or misbranded under the provisions of the FMIA or the PPIA,” the fact of recalls is by itself evidence that Salmonella is deemed an adulterant by the USDA on a case-by-case basis – especially when illnesses have occurred. Perhaps we should call Salmonella what it is – an adulterant always.

Given the relative prevalance of Salmonella, we’ll see how much traction this argument gets.