The USDA-FSIS has proposed an effective zero tolerance for any Salmonella contamination in raw, stuffed chicken products. Opposition to the proposal is probably unjustified although is based less on risks associated with the specific product than the fear of extension to a wider range of chicken preparations. It is a matter of record that Attorney Robert Marler has submitted a petition to FSIS to designate numerous known pathogenic Salmonella as adulterants in all chicken whether whole birds, portions or further processed items.
The situation with regard to raw, stuffed chicken products does not represent a major food safety concern. Over the past 25 years there have been 14 outbreaks and 200 illnesses
attributed to raw breaded products. These represent less than 0.1 percent of total consumption of chicken by volume but five percent of all chicken associated outbreaks.
The industry has justifiably contended that labeling should be adequate to inform consumers of the need to thoroughly cook raw breaded or stuffed chicken products. Unfortunately microwave reheating allows Salmonella and other potential pathogens to survive. The National Chicken Council noted, “There is no silver bullet nor a one-size-fits-all approach to food safety which is why we employ a multi-level strategy.” The NCC invokes science-based procedures and recommends handling and cooking properly in home and institutional kitchens.
From the perspective of an academic and a past researcher on Campylobacter infection, it is questioned why breaded and stuffed products are sold as raw rather than cooked presentations. If Salmonella is regarded as a risk, cooking during production would eliminate the problem. Since stuffed 
chicken products are marketed as lightly browned they create the deceptive perception of having been cooked. Labeling cannot overcome stupidity or negligence. If there are organoleptic reasons to continue marketing a raw, stuffed chicken product, irradiation using electron beam treatment could be applied as an effective kill step. By the same token, IQF products could also be free of non-spore forming bacterial pathogens including Salmonella, Campylobacter and Listeria.
It is highly likely that the FSIS will enforce the status of Salmonella as an adulterant for raw products irrespective of the opposition by the NCC. The possibility of FSIS extending restrictions beyond stuffed products to a wider range of chicken presentations is a distinct possibility with profound practical and legal implications..