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Food Safety News

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Publisher’s Platform: Are Cuts Always a Good Idea?

I get a lot of emails and comments, most saying things that I tend not to print.  However, this email is one of the more disturbing ones I have received lately:

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There is a program run by USDA called the microbiological data program (MDP).

lettucehydroponic-featured.jpg

This program collects fresh produce samples from distribution centers and terminal markets from key states across the U.S. and test them for pathogens (Salmonella and Shiga toxin- carrying E. coli). The produce industry hates this program as it has found pathogens in domestic and imported samples and FDA has responded to the information and recalled products. The produce industry via the USDA Fruit and Vegetable Advisory Committee recommended to USDA and congress that the program be terminated. Congress, yielding to industry pressure is going along with this (see pg 20-21).

MDP cost the taxpayers $4.5 million dollars a year to operate. For the past 3 years, they have been testing 15,000 samples a year (both domestic and imports, organic and conventional, pre-washed and unwashed). In comparison, FDA, which has regulatory responsibility and gets substantial funds to perform food safety activities, has only conducted domestic surveys in 1999, 2001 and 2005 testing only about 1,000 samples of multiple commodities (so a few samples of each commodity). FDA primarily tests only at the ports of entry and then less than 1% of the food coming across the border.

With the current outbreak in Europe with a pathogenic E. coli, our elected Congressional leaders want to shut down this program? This program actually test for STECs (Shiga toxin E. coli).

The idea of MDP is surveillance; HACCP alone without testing to verify it is working is worthless.

This is a program that works, actually serves a purpose and is efficiently run ($4.5 million). FDA heavily uses the MDP data.

Any help would be most welcome. The produce industry is very powerful. We the American public need this program.

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We have not had a major leafy green outbreak since the spinach and Taco Bell outbreaks in 2006.  Does not that argue for keeping a testing program in place?  Sure, there likely have been recalls or product withdraws, but isn’t getting tainted product out of the market a good thing?

It appears that the Republicans continue to accept the belief that the free market will solve all ills, despite the 48,000,000 reasons yearly that it is not the case. As Lyndsey Layton reported:

Rep. Jack Kingston (R-Ga.), chairman of the House subcommittee that wrote the agriculture appropriations bill, said the cuts to food safety were justified because the nation’s food supply was “99.99 percent safe.”


“Do we believe that McDonald’s and Kentucky Fried Chicken and Safeway and Kraft Food and any brand name that you think of, that these people aren’t concerned about food safety?” Kingston said on the House floor. “The food supply in America is very safe because the private sector self-polices, because they have the highest motivation. They don’t want to be sued, they don’t want to go broke. They want their customers to be healthy and happy.”

I appreciate that Rep Kingston likes this trial lawyer so much. However, the last line of defense should not be civil litigation. It is a blunt instrument for change.

© Food Safety News
  • http://www.handwashingforlife.com/ jimmann

    The risk is never zero. Chasing zero with government controls is an even more blunt instrument than civil litigation.
    What is a good level of risk to accept? If 99.99 is not a safe level what is?

  • jmunsell

    Indeed, microbial testing is required to validate the efficacy of individual HACCP Plans. WHERE and WHAT is tested is the crux of the matter. Let’s look at ground beef first. If ground beef at a retail meat market tests positive, the hot meat can be kept off the market. But beyond that, how can future recurrences be prevented? How do we determine the SOURCE of the contaminated ground beef? In all likelihood, the source of the E.coli in the burger was the source originating slaughter plant which produced trimmings or intact cuts which harbored the invisible pathogen.
    Testing at downstream further processing entities has limited FUTURE value, since such testing does not provide solutions to help the downstream entities (retail meat markets, restaurants, further processing meat plants) to prevent their future purchase of previously-contaminated meat from their source slaughter providers. Testing of meat would have the most benefit if such testing were done at the SOURCE, which is the slaughter plant. Both USDA and the source slaughter plants should be testing carcasses, boneless trim, intact boxed beef cuts, and ground beef at the source slaughter plant. As positives occur, subsequent testing should be designed to identify the specific processes or locations at the slaughter plant where enteric bacteria are accidentally being transferred onto beef carcasses on the kill floor. Perhaps the contamination is occurring during hide removal, during evisceration, during steam pasteurization, etc. If we truly want test results to benefit public health, all testing should be designed not only to detect pathogens, but also to reveal exactly WHERE and HOW the contaminants are being deposited onto carcasses. This is called “Process Control”, whereby each step of the slaughter process is subjected to microbial testing, in order to determine which step(s) have failures which require corrective actions, and perhaps redesigned slaughter protocol. Test results downstream at a Safeway store cannot provide any evidence which would reveal HOW & WHERE the pathogen entered the food chain, circumventing meaningful corrective actions to prevent future recurrences.
    Interestingly, USDA/FSIS has previously stated that it prefers to perform microbial testing “As close to the consumer as possible”. At first blush, this sounds good, as in protecting the consumer. However, what the agency is not admitting is that such testing is being performed as far away from the SOURCE as possible. Essentially, this insulates the source slaughter plant from accountability, while assessing all liability to the downstream entity which unwittingly purchased meat which is already laced with invisible pathogens. Pretty nifty, huh?
    The same should be accomplished in the produce industry, about which I know nothing. Would testing produce at the farm, in the field, be efficacious? Don’t know. Would testing water in a produce processing facility be more worthwhile, in the event fecal material is being deposited into the water, thus cross-contaminating all subsequent produce placed into the water? If so, all we would know is that the water is contaminated, but still don’t know WHERE the contaminant originated, which should be our highest focus.
    Bottom line: we must determine the true origin of fecal contamination, and focus enforcement and corrective actions at the SOURCE, if we want to prevent future contaminations and sicknesses downstream.
    What can a WalMart produce department do to prevent their future purchase and sale of pathogen-laced produce? No supplier can provide a 100% guarantee that incoming produce is pathogen free, unless the food has been fully cooked or irradiated. My wife and I insist on purchasing raw lettuce, tomatoes, spinach, ground beef and roasts, as do most consumers. There are many products which consumers require to NOT be fully cooked, which leaves only irradiation as a kill step. All these blasted domestic and international recalls and outbreaks point out the need for us to reconsider the usefulness of irradiation, some of which (such as low dose irradiation of beef carcasses) do not require radioactive isotopes. Admittedly, Good Manufacturing Practices must also be readdressed, such as applying manure to produce fields, or to ensure that irrigation water has not been subjected to feedlot runoff upstream somewhere. Again, going upstream to the SOURCE is tantamount.
    Yes, microbial testing is necessary. The value derived from such testing is maximized via testing as close to the source as possible, rather than as close to the consumer as possible.
    John Munsell

  • Ann Quinn, consumer

    The last time that I believed the American food industry
    or the worldwide global food industry, for that matter,
    self-polices its commercial food products, I lost my
    three pets between 2007 and 2011 and spent almost $20,000
    on treatment as a result of contaminated commercial pet
    foods.
    God forbid that it should ever be American consumers.
    We need better food safety in this country no matter
    what it costs.

  • http://www.handwashingforlife.com/ Jim Mann

    The risk is never zero. Chasing zero with government controls is an even more blunt instrument than civil litigation.
    What is a good level of risk to accept? If 99.99 is not a safe level what is?

  • John Munsell

    Indeed, microbial testing is required to validate the efficacy of individual HACCP Plans. WHERE and WHAT is tested is the crux of the matter. Let’s look at ground beef first. If ground beef at a retail meat market tests positive, the hot meat can be kept off the market. But beyond that, how can future recurrences be prevented? How do we determine the SOURCE of the contaminated ground beef? In all likelihood, the source of the E.coli in the burger was the source originating slaughter plant which produced trimmings or intact cuts which harbored the invisible pathogen.
    Testing at downstream further processing entities has limited FUTURE value, since such testing does not provide solutions to help the downstream entities (retail meat markets, restaurants, further processing meat plants) to prevent their future purchase of previously-contaminated meat from their source slaughter providers. Testing of meat would have the most benefit if such testing were done at the SOURCE, which is the slaughter plant. Both USDA and the source slaughter plants should be testing carcasses, boneless trim, intact boxed beef cuts, and ground beef at the source slaughter plant. As positives occur, subsequent testing should be designed to identify the specific processes or locations at the slaughter plant where enteric bacteria are accidentally being transferred onto beef carcasses on the kill floor. Perhaps the contamination is occurring during hide removal, during evisceration, during steam pasteurization, etc. If we truly want test results to benefit public health, all testing should be designed not only to detect pathogens, but also to reveal exactly WHERE and HOW the contaminants are being deposited onto carcasses. This is called “Process Control”, whereby each step of the slaughter process is subjected to microbial testing, in order to determine which step(s) have failures which require corrective actions, and perhaps redesigned slaughter protocol. Test results downstream at a Safeway store cannot provide any evidence which would reveal HOW & WHERE the pathogen entered the food chain, circumventing meaningful corrective actions to prevent future recurrences.
    Interestingly, USDA/FSIS has previously stated that it prefers to perform microbial testing “As close to the consumer as possible”. At first blush, this sounds good, as in protecting the consumer. However, what the agency is not admitting is that such testing is being performed as far away from the SOURCE as possible. Essentially, this insulates the source slaughter plant from accountability, while assessing all liability to the downstream entity which unwittingly purchased meat which is already laced with invisible pathogens. Pretty nifty, huh?
    The same should be accomplished in the produce industry, about which I know nothing. Would testing produce at the farm, in the field, be efficacious? Don’t know. Would testing water in a produce processing facility be more worthwhile, in the event fecal material is being deposited into the water, thus cross-contaminating all subsequent produce placed into the water? If so, all we would know is that the water is contaminated, but still don’t know WHERE the contaminant originated, which should be our highest focus.
    Bottom line: we must determine the true origin of fecal contamination, and focus enforcement and corrective actions at the SOURCE, if we want to prevent future contaminations and sicknesses downstream.
    What can a WalMart produce department do to prevent their future purchase and sale of pathogen-laced produce? No supplier can provide a 100% guarantee that incoming produce is pathogen free, unless the food has been fully cooked or irradiated. My wife and I insist on purchasing raw lettuce, tomatoes, spinach, ground beef and roasts, as do most consumers. There are many products which consumers require to NOT be fully cooked, which leaves only irradiation as a kill step. All these blasted domestic and international recalls and outbreaks point out the need for us to reconsider the usefulness of irradiation, some of which (such as low dose irradiation of beef carcasses) do not require radioactive isotopes. Admittedly, Good Manufacturing Practices must also be readdressed, such as applying manure to produce fields, or to ensure that irrigation water has not been subjected to feedlot runoff upstream somewhere. Again, going upstream to the SOURCE is tantamount.
    Yes, microbial testing is necessary. The value derived from such testing is maximized via testing as close to the source as possible, rather than as close to the consumer as possible.
    John Munsell

  • http://www.marlerblog.com bill marler

    Mr. Mann:
    “What is a good level of risk to accept? If 99.99 is not a safe level what is?”
    If you believe that I have some dry land to sell you in Seattle.

  • http://www.pathtracer.net Richard Ross

    Since one can’t test everything for pathogens, the opportunity for a pathogen in the food supply still exists. What is safe? Who is John Galt?

  • Ann Quinn, consumer

    Who among your family members is acceptable collateral
    damage? Your grandparents? Your parents? Your spouse?
    Your children? Yourself?
    My answer is none. Ask Linda Rivera’s family; I’m sure
    they’d say the same thing. If you’ve ever watched anything suffer from chronic kidney disease, it’s not a pretty sight. Along with kidney failure goes all kinds of related complications not one human being would volunteer for.
    Kidney disease is unbelievably treatment intensive and
    painful,and horrendously costly for each and every victim.
    And so much of it could be avoided with better food police
    and regulation that’s it’s really tragic that Congress is
    going to cut FDA and others’ food safety budgets in the
    name of a false economy only to be paid for by Medicare
    and Medicaid.

  • dangermaus

    Ann,
    Get off your horse. You could say that about anything, as everything involves some degree of risk. It’s not for you or anyone else to decide what kinds of risks others should be allowed to take in their choices of what to eat. If, for example, someone really wants to base their food choices on low-carbon, or local sourcing, or if they only want to eat things that are blue, that’s entirely their business.
    Of course everybody wants people growing and preparing foods to use good practices that help minimize the chance that bad bugs will get into it – you’d have to be a cartoon villain not to. But statements like “No matter what the cost” is just plain hysterical. Any rational person should see that. You sound as if you think it’s possible to eliminate the risk of food-borne illness – and it isn’t. There’d still be risk if everyone had their own irradiation machine on their kitchen tables.
    It drives me nuts every time I hear the “paid for by Medicare and Medicaid” argument advanced as an excuse to limit peoples’ freedom. We do not live in a communist country and I’d (and many others would) rather shut those programs down than have them be used as an excuse to regulate the minutia of peoples’ day-to-day lives.