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DeLauro Urges Inquiry Into Beef Testing

Congressoman Rosa DeLauro (D-CT) sent a letter yesterday to the U.S. Department of Agriculture (USDA) Office of the Inspector General (IG) calling for an investigation of beef testing protocol.

DeLauro requested that the IG look into the scientific merits and identify any shortcomings of the USDA’s N-60 testing system for beef, which requires the USDA’s Food Safety and Inspection Service (FSIS) to to remove 60 pieces of product from a lot to allow for testing for pathogens like E. coli O157: H7. 

The N-60 protocol is the method most large beef trim manufacturers use to try to verify their beef is E. coli-free.

“To protect public health, verification testing must be robust and ensure that adulterated product is not sold to the American consumers,” DeLauro wrote in the letter. “I am troubled by the shortcomings of the N-60 test and the associated food safety implications, and that is why I am requesting an investigation into the scientific merits of this beef testing protocol.”

DeLauro’s letter, addressed to Phyllis K. Fong, who has been IG at USDA since 2002, asks the agency several specific questions regarding the N-60 testing program’s statistical validity, sample collection and analysis, and application of test results.

DeLauro sent the following list of questions to the IG:

 

Statistical Validity of N-60 Testing

 

  • What is the prevalence of E. coli O157:H7 in domestic beef trim used for raw ground beef production at processing facilities in the United States? When and how was this estimate reached? How frequently will it be re-assessed?
  • What is the confidence level of the N-60 sampling method as currently performed? Is that level appropriate for ground beef?
  • What is the definition of a product “lot” used in the N-60 testing and how was this definition determined? How is this definition applied to individual processing establishments? Is this an appropriate application?
  • How does this definition affect the statistical viability of this test? How confident are we that lots testing negative are truly negative if the definition of “lot” varies among establishments?

 Sample Collection and Analysis

 

  • Are all samples collected, stored, shipped, and analyzed by trained FSIS employees?
  • Are laboratories instructed to reject samples that do not meet minimum quality standards? If so, what are those minimum quality standards? How is it assured each sample meets them? 
  • Are the minimum standards associated with sample collection, storage, shipment, and analysis adequate? What type of testing standards must be met by laboratories analyzing the samples?
  • Because E. coli O157:H7 is not necessarily distributed homogenously in a product, how did the agency decide on its current collection methodology? Are samples collected truly representative of the entire lot? 

 Application of N-60 Test Results

 

  • Has FSIS established a protocol for reassessing an establishment’s HACCP plan based upon N-60 test results? What actions are taken at an establishment after a positive N-60 test result?
  • What is the implication of a positive N-60 test result on the individual lot tested? On other lots from the same establishment produced on the same date?
  • How are the FSIS N-60 test results and the establishment’s N-60 test results correlated? How do N-60 testing protocols differ between FSIS and the industry?
  • What are the implications of the USDA label associated with a negative N-60 test?

© Food Safety News
  • jmunsell

    One question above is “What actions are taken at an establishment after a positive N-60 test result?” When a positive test result occurs on a 10,000# lot (comprised of 5-each 2,000 # combos), all 10,000# are “DIVERTED” to a plant which fully cooks it into products such as chili, ravioli, etc. The cooking process, if done right, fully cooks all e.coli, rendering the bacteria harmless. The agency has nothing but praise for the plant which diverted the adulterated meat, because the plant prevented the raw meat from going into commerce, and took actions to have the meat fully cooked prior to shipment into commerce, which protects consumers. An equally important issue however, is what corrective actions (1) are required by USDA because of this positive, and (2) what corrective actions are unilaterally implemented by the noncompliant slaughter plant whose trim was found to be adulterated with E.coli? Answer: none. Since no efficacious corrective actions are implemented on the noncompliant kill floor, the same problem occurs time and time again, and the agency could care less. The agency hides its head in the sand, and concludes that since the adulterated meat was found and DIVERTED, this action constitutes proof that the slaughter plant’s HACCP Plan is working beautifully because it caught the presence of the E.coli. However, everyone in the industry and the agency states that negative test results are no proof that the remainder of the lot is wholesome, only the portion of the lot which was tested in the lab. Both the industry and the agency are being truthful here, in claiming that there is no silver bullet providing a 100% guarantee that all meat is safe. Negative lab results are no proof that the entire lot is safe. So, USDA should be greatly concerned when positive n-60 lab tests come back positive, because positive lab test results are evidence that the kill floor has sanitation problems, which must be resolved to prevent future recurrences. These ongoing outbreaks and recurring recalls provide ample evidence that corrective actions are NOT being accomplished. John Munsell

  • John Munsell

    One question above is “What actions are taken at an establishment after a positive N-60 test result?” When a positive test result occurs on a 10,000# lot (comprised of 5-each 2,000 # combos), all 10,000# are “DIVERTED” to a plant which fully cooks it into products such as chili, ravioli, etc. The cooking process, if done right, fully cooks all e.coli, rendering the bacteria harmless. The agency has nothing but praise for the plant which diverted the adulterated meat, because the plant prevented the raw meat from going into commerce, and took actions to have the meat fully cooked prior to shipment into commerce, which protects consumers. An equally important issue however, is what corrective actions (1) are required by USDA because of this positive, and (2) what corrective actions are unilaterally implemented by the noncompliant slaughter plant whose trim was found to be adulterated with E.coli? Answer: none. Since no efficacious corrective actions are implemented on the noncompliant kill floor, the same problem occurs time and time again, and the agency could care less. The agency hides its head in the sand, and concludes that since the adulterated meat was found and DIVERTED, this action constitutes proof that the slaughter plant’s HACCP Plan is working beautifully because it caught the presence of the E.coli. However, everyone in the industry and the agency states that negative test results are no proof that the remainder of the lot is wholesome, only the portion of the lot which was tested in the lab. Both the industry and the agency are being truthful here, in claiming that there is no silver bullet providing a 100% guarantee that all meat is safe. Negative lab results are no proof that the entire lot is safe. So, USDA should be greatly concerned when positive n-60 lab tests come back positive, because positive lab test results are evidence that the kill floor has sanitation problems, which must be resolved to prevent future recurrences. These ongoing outbreaks and recurring recalls provide ample evidence that corrective actions are NOT being accomplished. John Munsell