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If I Had a Magic Wand for Food Safety

Editor’s note: If you had a magic wand, how would you conjure up sustainable ways to make the food supply safe?  We asked several people to consider the possibilities. Here is another response, from Dr. Richard Raymond, former Undersecretary for Food Safety at the U.S. Department of Agriculture.

If I had a Food Safety Magic Wand … that would be a daunting development, so to make it less daunting and to stay more focused, I am going to assume my Magic Wand is to primarily make our meat and poultry products safer.  I will let the former FDA food safety leaders pen their own cures for what ails the food safety arena that FDA has responsibility for.

But before I focus primarily on the U.S Department of Agriculture’s (USDA) responsibility for meat, poultry and egg products safety, I want to repeat, briefly, what I said in an article for Food Safety News that was posted Jan. 3, 2011, and can be read in its entirety here.

 

magicwandX-featured.jpg

I am going to use my Magic Wand to improve food safety by using its powers to give the USDA and its Food Safety and Inspection Service (FSIS) regulatory authority over all animals and animal products, including all fish and seafood, bison, dairy products and eggs, and to give FDA regulatory authority over all canned and bottled goods, and processed entities like frozen pizzas, sandwiches and flavoring.

 

The meat in these proposed FDA products has already been inspected and passed.  Adding pepperoni to a pizza that contains spinach, green onions, tomatoes, cheese, pepper and other products that have been linked to foodborne illnesses does not change the public health risk, nor does adding beef to the vegetables in vegetable beef soup increase risk.  But these additions of meat do add cost by now requiring daily inspection of the product. 

The savings produced by moving these very low risk products to the FDA could be used to increase the inspection of animals and animal products, such as eggs and oysters, that are now FDA responsibility and have been linked to foodborne illnesses by daily FSIS inspection.

The very next thing I would use my wand for is to declare whole carcass, low dose, non-penetrating irradiation to be a processing aid, not a food additive.  That done, the industry can now embrace the concept, explore its applications, and over the next few years begin to significantly decrease the pathogen load on carcasses prior to the application of other processing aids down the line, greatly reducing our risks of falling ill from consuming meat.

And, since industry will now have this very important tool to help it produce a safer product, I am now going to declare all non-O157:H7 Shigatoxin producing E coli strains to be adulterants.

 

At the same time, I am going to take personal risk using the Wand as my protective shield and establish a tolerance level for E coli.  Before you declare me clinically insane, think about the effectiveness of the current “zero tolerance” policy.  It is, at this time at least, unobtainable and non-enforceable.  Develop a realistic tolerance level that is reachable with today’s interventions, and then enforce it.  Allow FSIS to bring action against those few plants that provide the greatest risk to the public with their product.

And speaking of plants that impose a risk, I am also waving my wand at FSIS and mandating that they do trace back to the source of contamination to the very best of their ability.  For example, in the FSIS testing program for 2010, 64 ground beef samples were positive for E coli O157:H7.  Of those positives, 29 were found at plants that used only outside source material and did no slaughter of their own.  And, these 29 plants used only one source in the tested lot.  And that same product from that source was most likely sold to other processors as well.  Yet FSIS maintains that so much ground beef is a blended product from multiple sources that trace back is next to impossible.  Magic Wand, fix this.  Find the source and take action.

We have other products available to assist us in making our products safer, but sometimes the bureaucracy of having three agencies (Animal and Plant Health Inspection Service, FDA and FSIS) with overlapping oversight of these products produces little movement in the approval process, as we saw with the E. coli vaccine.  So I will use the powers of the Wand to declare that Phage treatments are a processing aid, not a food additive, and can therefore be used on primals and trim without labeling restrictions.

Before my Magic Wand’s powers weaken, I want to accelerate the research on the efficacy of the E coli vaccines.  One way I will do this is to provide tax incentives for those companies willing to spend their own resources in this effort.  Heck, I think I will provide tax incentives for any research into more effective ways to produce a safer product.  And then I will wave the wand again, and make FSIS a more cooperative partner with plants looking for new ways to improve safety, and become less of a hindrance to them.

Now that my wand has effectively provided me with the information to declare the E. coli vaccine to be a very effective pre-harvest tool in reducing E coli in beef, I am going to declare the pathogen to be an environmental hazard worthy of the government’s attention to reduce its presence.

  

Produce is accountable for 34 percent of all E. coli O157:H7 foodborne illnesses, ground beef being responsible for 33 percent, according to Robert Tauxe of the Centers for Disease Control and Prevention.  One-third of E. coli illnesses are not even related to food, but come from our drinking water, recreational water, petting zoos and person-to-person contact.  We need to get it out of the environment to save lives. T hat means reducing it in cattle.  The vaccine will help us get there.

But why should the rancher, feeder or packer bear this expense?  Ultimately it will be the purchaser of beef that pays the price.  So, Magic Wand, make the government develop and pay for a mandatory vaccination program for beef that will save children’s lives, just like they do for most childhood vaccines available now.  The federal government took positive steps to reduce or eliminate Bovine tuberculosis and brucellosis, it should do it for E. coli O157:H7.

  

It would truly have to be magical, but, when weather permits, washing cattle in the feed lots or on the farms, before loading into trucks and hauling to the holding pens, would effectively reduce the pathogen loads in and around the slaughter facilities.

 

And the Magic Wand is going to try to find out what truly causes “event days” in beef slaughter facilities so preventive measures can be introduced and implemented by all facilities.  And this just might include changes in facility design to reduce pathogens being introduced by measures other than just the cattle.

I think the Magic Wand, if it has any energy left after taking on the payment method for the E. coli vaccination program, will probably do the same thing for Salmonella vaccines in our poultry flocks.

And then the Wand is going to help me convene a high-level conference on antibiotic use in food animals, and the participants will come willing to listen and to learn, and to stop the non-productive claims that are so often repeated.  There is a middle ground here that can be reached but, if it is not, Congress will come along and
create problems like it did with catfish inspection.

Speaking of Congress, the Magic Wand will give me the power to immediately rescind the actions of Congress that prohibit FSIS from moving forward with risk-based inspection.  This was a budget neutral process that would have increased inspection activities in plants with poor safety records and/or producing high risk products, and would have reduced inspection activities in plants with stellar safety records and plants producing extremely safe products.

The Wand holder feels this will be easier to accomplish now that Congress has mandated in the Food Safety Modernization Act that the FDA use risk as a key element in determining inspection levels and frequency.

While on the subject of high risk products, frozen ground beef patties are a special problem. When cooked in restaurants with validated and documented kill steps, frozen patties are not a problem.  But when cooked at tail gate parties, pool parties, camp grounds, etc, we have a problem.  I might lend the Magic Wand to someone else and let them decide whether to ban the sale of frozen GB patties at retail, or to require that the meat be irradiated with penetrating beams.

And lastly, while the Wand still has some energy left in it and powers to create change, I am going to try and make that final kill step in all homes and restaurants and institutions a reality. My plan will use the same energy and resources that the government used to educate us all about the switch to cable television  and the “dangers” of Y2K  to help the American public understand that raw meat and poultry should not be considered sterile.

 

As a result of this education effort, the majority of the American public will now know how to safely handle raw meats and poultry and, most importantly, how to measure the internal temperature for doneness.

 

Actually, this should probably have been the first action taken using the power of the Magic Wand.  It is by far the most important and will have most immediate effect on the safety of meat and poultry products. 

© Food Safety News
  • If I had a magic wand….
    I would require anyone wishing to get into the food production and food service industry to meet minimum education and experience requirements.

  • Larry and Karen Andrew

    We hope your magic wand produces the improvements you have identified. Ours would include a significant increase in criminal sanctions and prosecutions that we think would greatly influence management decisions on food safety issues.

  • Thank you, Dr. Raymond, for proposing, “Now that my wand has effectively provided me with the information to declare the E. coli vaccine to be a very effective pre-harvest tool in reducing E coli in beef, I am going to declare the pathogen to be an environmental hazard worthy of the government’s attention to reduce its presence…One-third of E. coli illnesses are not even related to food, but come from our drinking water, recreational water, petting zoos and person-to-person contact. We need to get it out of the environment to save lives. That means reducing it in cattle. The vaccine will help us get there.”
    You have described the situation clearly, “We need to get [E. coli] out of the environment to save lives.”
    I would broaden your goal to ALL serious pathogens causing foodborne illnesses which are not already ubiquitous in nature. Salmonella enteritidis (SE) appears to similarly being spread by industrial agriculture.
    In its “Brief in Support of United States’ Motion to Dismiss Plaintiff’s Amended Complaint” http://www.farmtoconsumer.org/litigation/ey100426–ds mtd memo in support.pdf, the FDA is already claiming the authority to address this type of public health threat. The FDA claims the Public Health Service Act (PHSA) grants it such authority. In this brief, the FDA claims the threat to public health posed by the interstate sale of raw milk is so great as to necessitate its prohibition while it makes no such claim about the clearly, demonstrably greater threat of the communication of the various E. coli. and SE by the interstate transport and sale of infected animals and eggs.
    As I have repeatedly pointed out in comments on Food Safety News, the probability of increased foodborne illness posed by the spreading of such pathogens through out nature is exponentially greater than anything the FSIS and FDA are presently focused upon. Furthermore, these hazards were not even brought up by the supporters of the FSMA much less directly addressed by the FSMA, itself. If the FSMA has changed the FDA from reactive in prevention oriented as all the FSMA supporters claim, what could be more preventive than stopping the spread of these pathogens into our natural world from our unnatural CAFOs?
    If these pathogens become ubiquitous in nature as seems quite possible, they will proved almost impossible to eradicate just as listeria already is.
    When will those who style themselves as “food safety advocates” address this known hazard? What an irony as so many of them advocate full food safety plans throughout the food system yet they don’t even do the hazard analysis of entire systems of food production needed to lead to major reductions in foodborne illness. They treat the symptoms caused by these food production systems rather that the food production systems’ diseases.
    Once again, I thank you, Dr. Raymond, for trying to point the advocates and regulators in a more appropriate direction.
    As always, I will happily discuss everything I have written with anyone who writes to me at healthyfoodcoalition@gmail.com.

  • Michael Bulger

    I agree that these pathogens need to be addressed at their source. A quick analysis of the food system shows that, between the 300 million American consumers and the over 2 million farms, the smallest critical control point in the system would be the approx. 420,000 food processing facilities.
    These facilities were the focus of the FSMA, and logically so, as deploying our limited resources to the smallest point in the hourglass should have the greatest impact in the immediate future.
    However, this is like treating a wounded person with a tourniquet. Necessary, but eventually we need to treat the wound itself (in this case the pathogens in places such as CAFOs). The tourniquet will help in the short-run, but as we all want to make real progress, we need to track the contamination we find at the facilities back to the livestock producers and take on the pathogens at their base.
    I don’t think we need a magic wand to do that.

  • Harry, when are you going to “pick up the wand?”

  • Doc Mudd

    Doc Raymond would encounter no difficulty getting Pfizer, Cargill and professional American livestock producers to use the new e. coli vaccine effectively, if it is warranted. These guys are pros who know their trade and get things done right and timely as a matter of routine business.
    http://www.foodsafetynews.com/2011/01/now-pfizer-owned-vaccine-for-o157-getting-big-push/
    Problem is, it isn’t just your much-maligned “CAFOs” who are housing livestock that naturally harbors e. coli. See, con artists who spread the “all badness springs from evil CAFOs” myth figure no one will ever call their bluff. Turns out, though, all animals naturally live with strains of e. coli in their gut as a natural part of their environments. Always have, always will. So…
    .
    .
    .
    Hey, Harry, you could vaccinate all of the wildlife and bison herds in North America with your ‘magic wand’, couldn’t you? See, they naturally harbor e. coli too, of course, and if you’re going to “eradicate” e. coli, as you so boldly profess, well, we can’t overlook any reservoirs of the bug, can we?
    http://www.foodsafetynews.com/2011/01/bison-ranchers-bullish-an-e-coli-question-remains/
    http://www.foodsafetynews.com/2011/01/bison-ranchers-bullish-an-e-coli-question-remains/
    .
    .
    .
    Hey Michael, you certainly could see to vaccinating all of the tres chic organic and grass-fed livestock to purge them of their natural relationship with e. coli, couldn’t you? Surely you will find reliable assistance among your small army of concerned armchair agrarians and your ferocious legion of heroic hobby farmers. They all talk a big game, can they walk it?
    http://www.foodsafetynews.com/2010/12/organic-ground-beef-recalled-due-to-e-coli/
    http://www.marlerblog.com/lawyer-oped/has-the-nail-been-driven-into-the-coffin-of-the-conventional-wisdom-that-grass-fed-beef-is-safer-tha/
    .
    .
    .
    What will I be doin’ while you geniuses are wranglin’ critters and jabbin’ away like woodpeckers? Oh, I’ll be sittin’ back sippin’ on a beer, poised to spring into action and nominate you two for a Nobel Prize just as soon as you succeed, ’cause “eradicating” e. coli would be somethin’ to see. It can’t be accomplished, of course, but why dash cold water on a couple of big dreamers who always have all the easy answers?
    Hey Harry – I really, really want to see you wrasslin’ them bison! When they don’t want to play they can really be sons-of-bitchs about it. But you knew all that, of course, bein’ an expert farmer and all. Could you please get some video of you in perfect command of those ol’ buffalo and post it on your ‘wealthyfoods’ website?

  • Thank you, Dr. Raymond, for proposing, “Now that my wand has effectively provided me with the information to declare the E. coli vaccine to be a very effective pre-harvest tool in reducing E coli in beef, I am going to declare the pathogen to be an environmental hazard worthy of the government’s attention to reduce its presence…One-third of E. coli illnesses are not even related to food, but come from our drinking water, recreational water, petting zoos and person-to-person contact. We need to get it out of the environment to save lives. That means reducing it in cattle. The vaccine will help us get there.”
    You have described the situation clearly, “We need to get [E. coli] out of the environment to save lives.”
    I would broaden your goal to ALL serious pathogens causing foodborne illnesses which are not already ubiquitous in nature. Salmonella enteritidis (SE) appears to similarly being spread by industrial agriculture.
    In its “Brief in Support of United States’ Motion to Dismiss Plaintiff’s Amended Complaint” http://www.farmtoconsumer.org/litigation/ey100426–ds mtd memo in support.pdf, the FDA is already claiming the authority to address this type of public health threat. The FDA claims the Public Health Service Act (PHSA) grants it such authority. In this brief, the FDA claims the threat to public health posed by the interstate sale of raw milk is so great as to necessitate its prohibition while it makes no such claim about the clearly, demonstrably greater threat of the communication of the various E. coli. and SE by the interstate transport and sale of infected animals and eggs.
    As I have repeatedly pointed out in comments on Food Safety News, the probability of increased foodborne illness posed by the spreading of such pathogens through out nature is exponentially greater than anything the FSIS and FDA are presently focused upon. Furthermore, these hazards were not even brought up by the supporters of the FSMA much less directly addressed by the FSMA, itself. If the FSMA has changed the FDA from reactive in prevention oriented as all the FSMA supporters claim, what could be more preventive than stopping the spread of these pathogens into our natural world from our unnatural CAFOs?
    If these pathogens become ubiquitous in nature as seems quite possible, they will proved almost impossible to eradicate just as listeria already is.
    When will those who style themselves as “food safety advocates” address this known hazard? What an irony as so many of them advocate full food safety plans throughout the food system yet they don’t even do the hazard analysis of entire systems of food production needed to lead to major reductions in foodborne illness. They treat the symptoms caused by these food production systems rather that the food production systems’ diseases.
    Once again, I thank you, Dr. Raymond, for trying to point the advocates and regulators in a more appropriate direction.
    As always, I will happily discuss everything I have written with anyone who writes to me at healthyfoodcoalition@gmail.com.

  • Doc Raymond

    John, I agree with your idea about minimal requirememnts about education. But of course Congress would say the small producers should be exempted.
    Larry and Karen, I also agree that criminal sanctions might help deter bad actors. One of my biggest disappointments as the Undersecretary for Food Safety at the USDA was the lack of aggessive action by the US Attorney’s office to precede with prosecution when FSIS handed them what we thought was clear evidence of criminal activity.
    Michael, CAFOs are not the problem. Big Ag has helped with improved animal husbandry to reduce or eliminate many pathogens and parasites from the US food supply that still exist in other parts of the world.

  • The dissembling of “Doc Mudd” continues.
    Dr. Raymond was clearly addressing human pathogenic E. coli. and “Doc Mudd” blows smoke by bringing up non-pathogenic E. coli. And, of course, he ignores the fact that there is no question that CAFOs provide an almost ideal environment for breeding these human pathogens. Our record of stamping out smallpox and dramatically reducing other diseases like plague and yellow fever demonstrate the impact thoughtful action can have.
    So, once again Food Safety News has allowed him to continue to function as a troll. I won’t comment again on his claptrap.
    Michael Bulger’s analysis leaves much to be desired.
    Of the 418,574 facilities registered with the FDA on 12-1-10 (http://www.fda.gov/Food/GuidanceComplianceRegulatoryInformation/RegistrationofFoodFacilities/ucm236512.htm), only 166,160 are in the US. Thus, only those are between the approximately 2 million farms and 300 million Americans consumers. However, the vast majority of the farms produce commodities or meats that are not subject to the FSMA or pack and sell direct; thus, no facility is between them and the consumer. Furthermore, Mr. Bulger mislabels all facilities with the technical term, “critical control point” when the vast majority of them do NO processing/manufacturing and, thus, have NO “critical control points” at which to exert control.
    Despite this fact, as a result of Sec. 103 Hazard Analysis & Risk-based Preventive Controls of the FSMA, the 161,681 warehouses/holding facilities and 41,559 packers/repackers will have to formulate and follow formal food safety plans despite the fact that I can find no record of a single outbreak that began at one of these facilities. And American consumers will pay higher prices for this waste of time and the local, healthy food movement will have a much harder time creating this needed infrastructure for the distribution of local food for local people.
    BTW, for those interesting in bison, the largest herd east of the Mississippi is at Carolina Bison headquartered right here in Buncombe County, NC. I participate in round ups whenever I can work them into my schedule. And we sell Carolina Bison at our market. I wonder how much up close and personal experience “Doc Mudd” has with bison.

  • Doc Mudd

    Harry’s unfettered optimism is most encouraging. In the same easy way he “stamped out smallpox” he will “eradicate” e. coli!
    Well, get on with it, old boy. Tally ho, tally ho!!
    I’m crackin’ open the first Pabst Blue Ribbon right now in breathless anticipation. (This won’t take too terribly long, will it Harry? I don’t want to get too drunk to fish…or ‘troll’, as you complain)

  • Michael Bulger

    Harry, you really are ridiculous.
    The food facilities are themselves the control points. I’m sorry if I am able to think outside the box and that bothers you. I tried to use an analogy that you might be able to understand. I guess I overestimated you.
    @Doc Raymond: CAFOs most certainly are not exempt from food safety problems. They will need to be addressed, just as any livestock operation will if we are to seriously confront these pathogens.
    Doc Mudd would rather sip a beer and spin the wheel. I, on the other hand, don’t think that is how progress is made.
    And just to remind us all:
    “Harry Hamil
    12/31/2010
    9:29AM
    For those who have read my comments since the inception of Food Safety News, I want you to know that I am returning to be a full-time grower, distributor and retailer of the local, healthy food. I expect that I will seldom have time to make comments on this venue.”
    Thank goodness he has saved time to attack me on FSN. What better way to prove himself?

  • The dissembling of “Doc Mudd” continues.
    Dr. Raymond was clearly addressing human pathogenic E. coli. and “Doc Mudd” blows smoke by bringing up non-pathogenic E. coli. And, of course, he ignores the fact that there is no question that CAFOs provide an almost ideal environment for breeding these human pathogens. Our record of stamping out smallpox and dramatically reducing other diseases like plague and yellow fever demonstrate the impact thoughtful action can have.
    So, once again Food Safety News has allowed him to continue to function as a troll. I won’t comment again on his claptrap.
    Michael Bulger’s analysis leaves much to be desired.
    Of the 418,574 facilities registered with the FDA on 12-1-10 (http://www.fda.gov/Food/GuidanceComplianceRegulatoryInformation/RegistrationofFoodFacilities/ucm236512.htm), only 166,160 are in the US. Thus, only those are between the approximately 2 million farms and 300 million Americans consumers. However, the vast majority of the farms produce commodities or meats that are not subject to the FSMA or pack and sell direct; thus, no facility is between them and the consumer. Furthermore, Mr. Bulger mislabels all facilities with the technical term, “critical control point” when the vast majority of them do NO processing/manufacturing and, thus, have NO “critical control points” at which to exert control.
    Despite this fact, as a result of Sec. 103 Hazard Analysis & Risk-based Preventive Controls of the FSMA, the 161,681 warehouses/holding facilities and 41,559 packers/repackers will have to formulate and follow formal food safety plans despite the fact that I can find no record of a single outbreak that began at one of these facilities. And American consumers will pay higher prices for this waste of time and the local, healthy food movement will have a much harder time creating this needed infrastructure for the distribution of local food for local people.
    BTW, for those interesting in bison, the largest herd east of the Mississippi is at Carolina Bison headquartered right here in Buncombe County, NC. I participate in round ups whenever I can work them into my schedule. And we sell Carolina Bison at our market. I wonder how much up close and personal experience “Doc Mudd” has with bison.

  • Inspector

    Dr. Raymond,
    I’d like to hear your thoughts on the research from Cornell University that shows that finishing cattle on grain (in CAFOs) increases the number of acid-resistant E. coli. Feeding cattle hay (what they are supossed to eat) reduces E. coli. Here’s the link:
    http://www.news.cornell.edu/releases/Sept98/acid.relief.hrs.html
    Also, the routine use of preventative antibiotics in CAFOs leads to more antibiotic resistance.
    Knowing this, why is the industy still allowed to feed cattle an unnatural grain diet which makes them sick and is laced with subtheraputic antibiotics in a confined, dusty, manure-filled feedlot?
    The answer is “efficiency” aka money. I wish the USDA would address that!
    We need to start addresing E. coli pre-harvest (root cause) and use interventions that don’t create more resistance. One technology that intrigues me is HPP (High Pressure Processing).

  • doc raymond

    Inspector, what do I think about the Cornell University research? I think it is very old. Many studies since their 1998 report have added valuable information and scientific dats regarding how the different feeding practices contributes to the risk of an E coli O157:H7 foodborne illness to humans.
    For instance, most of the recent research does indicate an increased incidence of E coli O157:H7 colonization of the distal colon/rectum and shedding of the same in cattle fed high quantitities of distilled grains, a by-product of the biofuels industry. But other studies have shown no difference in colonization rates when comparing grass fed cattle vs. corn fed cattle in feed lots. Other studies have shown E coli O157:H7 to be present in newborn calves, whose mothers, of course, were all grass fed. The bug is a natural inhabitant of the intestinal tract of cattle and does not cause illness in cattle. It is not a factor in antibiotic use or antibiotic resistance in bacteria. My Grand Dad put his cattle into his corn fields after harvest to benefit from the spilled corn, as most farmers still do today. I do not think we can say feeding corn to cattle is unnatural or endangers their health. I agree with you that preharvest is an area we need to look at very hard—issues like vaccination for E coli O157 could help reduce the incidence of the bug not only in cattle and our beef, but in the environment and the contamination of produce, water, etc. At the same time, we need to recognize that modern ag practices and animal husbandry have allowed us to keep beef prices reasonably low and to help feed the world. Grass fed only would not do that. pasture space is limited and declining. People do deserve a choice. Me, I like the taste and texture of corn fed beef. Thanks for your comments and questions. And for being a reader of FSN