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Wrestling With the Science of STEC

When it comes to our nation’s Shiga toxin-producing Escherichia coli (STEC) policy, some people like to wrestle in the mud.  I like to wrestle with the science.  And the science does not support the need for a new USDA policy, now set to go into effect in June.

  

At AMI, we regularly review microbiological testing trends, public health data and peer reviewed research to guide our work.  The data do not indicate that non-O157 STEC in beef products pose an urgent or unique public health threat.

USDA officials argue in favor of the policy, saying that the incidence rate of estimated cases of non-O157 STEC illnesses exceeded the incidence of O157:H7 cases for the first time, but this statistic misses an extremely significant point that most of those illnesses were actually sourced from foods other than beef.  According to available records, there was one E. coli O26 foodborne outbreak in 2010 that may have been related to ground beef.  Three illnesses were associated with that outbreak. There have been no other outbreaks from non-O157 STEC in beef among the more than 14,000 total foodborne outbreaks that have been documented in the U.S. over the past decade. 

 

We must remain valiant and constantly be open to new ideas, but if I ever doubt the foundation of AMI’s position, I simply look at the available public health data and I am again firm in my conviction.  I can’t find a scientific way to rationalize the path USDA is taking.

Perhaps that’s because research has shown that the interventions and process control systems that have so effectively reduced E. coli O157:H7 also work against the six other strains now in the spotlight.

If for whatever reason you’re skeptical of my words, consider these from some leading experts, including those who reviewed USDA’s Draft Risk Profile:

“We note that the illnesses associated with these strains have not primarily been due to contamination on beef.”  -FSIS Federal Register Final Determination

[There is no] “Evidence that declaring six serotypes of non-O157 STEC adulterants would have any public health benefit.  As it is, the evidence suggests that contamination with these serotypes is prevented or eliminated by exactly the same interventions that are currently in place to prevent or eliminate O157 STEC contamination.  In the absence of additional interventions that would specifically affect non-O157 STEC, declaring them adulterants is not likely to have any public health benefit.” -Peer Reviewer 1, FSIS Draft Risk Profile:

 

“We reviewed the estimates of foodborne illness, major pathogens and specified sources, papers. For the volume of data, severity of illness, our ability to measure change, and we concluded that the non-O157 E. coli, at this point in time, was not on par with the other pathogens as far as understanding and implementing interventions to reduce them.”    –Dr. Mark Hoekstra, CDC, CDC/FSIS/FDA Foodborne Illness Source Attribution Public Meeting, January 31, 2012.

Given these legitimate questions from our government agencies about the public health risk posed by these STEC in ground beef and the potential benefits of the policy, how is proceeding with it justified? 

  

The good news is that USDA recently took a major step to better understand these STEC– an action AMI has been arguing for years is needed. The five year, $25 million grant USDA awarded to the University of Nebraska-Lincoln last month to study STEC in beef will provide some of the needed research regarding analyzing the risks of STEC in the beef supply and developing validated test methods.  It’s the kind of work that should have been the first step, however.  Science should be the engine that drives the train — not the caboose.

Our goal is to ensure that every eating experience involving meat products is a safe one.  To achieve that, we must confront the scientific facts, and when we do that, they tell us this policy is simply without a sound foundation.  And that’s a view that USDA’s own experts and risk reviewers share because like me, they have truly wrestled with the science.

—————————

James H. Hodges is American Meat Institute Executive Vice President.

 

© Food Safety News
  • dcohen

    James Hodges analysis appears to be contradicted by a 2009-2010 review conducted by the the Food Research Institute, University of Wisconsin, Madison, funded in part by the American Meat Institute Foundation**.
    For example, in the review the authors find that cattle are the primary reservoir of non-O157:H7 STEC, that where country surveys have been done up to 40% of (various) meat samples were contaminated with non-O157:H7 STEC , and detection of non-O157:H7 cases and outbreaks are under-reported in the U.S. because of lack of routine public health testing.
    The relative larger proportion of person to person contact infection or “unknown” causation is also thought by the CDC to be due to the same analytic and reporting poverty:
    “These differences are likely due, in part, to the better analytical methods available for E. coli O157:H7. E coli O157:H7 is also more virulent than some non-O157:H7 STEC strains and thus outbreaks are recognized and investigated more rapidly and thoroughly.”
    The downside of testing is hard to see from Mr Hodges’ own argument. There appear to be no additional process interventions needed than already in place for O157:H7. Consumer confidence would be damaged again if there was a serious outbreak after a refusal to test for known emerging pathogens. The meat industry could voluntarily adapt a shiga toxin and/or stx genes testing regime that would cover the entire class and include the “big 6” non-O157:H7 as a consequence.
    A large number of commercial tests are available, and a testing regime with great statistical power could be implemented with low type I error rates (false positives) which would appear to be the main economic burden of adding testing if there were, in fact, less reason for outbreak concern.
    Meat is of course, only one product in the animal production cycle. On a wet mass basis it is almost a by-product of manure production. Manure, bones, hides, offal and brains and nervous tissue all find different markets. Meat production can be a critical control point for detecting emergent pathogen flow into the environment from animal production, as well as a control point for preventing pathogen flow into the food supply.
    Most people, the consumers, are resistant to being the testing regime for known, serious, emerging pathogens.
    Any intervention can have unintended consequences, and it would be useful to have more information from the industry on the basis for their opposition to non-O157:H7 testing.
    Dan Cohen
    Davis, CA
    ** White Paper on Non-O157:H7 Shiga Toxin-Producing E. coli
    from Meat and Non-Meat Sources. Kaspar, Dolye and Archer. FRI Food Safety Reviews 2010.

  • Richard

    Mr. Hodges, as a beef consumer I appreciate your views.
    Please note that ‘absence of evidence’ of STECs in beef is not ‘evidence of absence’.
    When AMI and the major slaughter plants embrace and enable traceback to the source, that additional data will inform the science of the prevalence of STECs in beef, including primal cuts and ground product.
    This from Feb. 7 FSN: “Does High-Risk Meat Get USDA Endorsement?”
    “USDA collects routine samples of ground beef for laboratory analysis for E. coli O157:H7, referred to as “verification sampling.” From Jan. 1, 2009 to Nov. 30, 2010, the agency’s routine verification sampling revealed 64 samples that were positive for E. coli O157:H7. Of these 64, 29 were collected at plants which purchased all their meat from but one slaughter provider. In all 29 cases, USDA refused to do a traceback to the one well-identified source. The agency deliberately refused to go to the source plant and require corrective actions to prevent recurrences. USDA adroitly avoided any enforcement actions at the source plant, in spite of these 29 golden opportunities to protect public health.
    Eventually, USDA mismanagement of public health issues caught up to them. On Aug. 3, 2011, USDA Secretary Tom Vilsack gave a speech in Milwaukee, in which he addressed this issue. He stated:
    “In 90 days, I expect the agency to announce the first step in transforming our traceback policy…”
    The FIRST STEP? You mean to say that after several decades of being in the meat inspection business, that USDA finally decided to embrace traceback protocol in 2011? Yes. Well, what happened at the end of 90 days? No official USDA press releases. But on Dec. 29, 2011, a full 148 days later, USDA sent its traceback suggestions to OMB for approval.
    Part of the USDA submission was requesting OMB permission to conduct tracebacks when verification sampling revealed the presence of E. coli O157:H7. This awkward revelation shows that USDA perceives it doesn’t have the authority to do tracebacks to the source, even when the source has already been clearly identified to be one individual slaughter plant! Yet USDA claims to act with an “abundance of caution” when protecting consumers from foodborne outbreaks.”

  • I understand and support the desire to expand the definition of adulterants beyond O157. It should be done if it can be implemented effectively. However, it seems that the FSIS approach for detection is flawed. Screening for virulence leads to a high level of false positives because the genes from multiple organisms in the test sample can combine to yield a positive result for virulence…..even though the virulence didn’t come from just one organism. The secondary screen for O types will not rectify this problem.
    Adding to this confusion is the fact that the German E. coli is eae negative…..so, a positive sample for the German E. coli (very deadly) would yield a negative on the FSIS screen. The 90 day delay isn’t going to solve this problem.
    The U of Nebraska effort is going to also look into testing/detection technologies. This is needed before we go forward utilizing methods that will certainly lead to disruption.

  • doc raymond

    Jim, I will wrestle in the mud any time you like, and I suggest you have your writers do a little more proof reading next time as you contradict yourself in this brief review of the science surrounding non-O157 STECS.
    For example, yuo state that the research has shown that the interventions or prevention steps that have reduced E coli O157 are just as effective against the other 6 but do not provide a scientific source. Then you turn around and cite Hoekstra as saying that the “understanding and implementing 0f interventions to reduce them” (the non-O157s) was not on par with the knowledge about interventions to reduce other pathogens.
    You cite “Peer Reviewer”, whoever that is, as saying “contamination with these serotypes is prevented or eliminated by exactly” the same interventions as used in O157. Last I knew, we did not, as of yet, have interventions available to us that prevent or eliminate E coli of any strain. Bad expert to quote, in my humble opinion.
    And lastly, for the readers, Jim does not tell us that less that 10% of the estimated 112,000 food borne illnesses from non-O157 STECs ever are linked to a source. That means, quite frankly, that over 90,000 illnesses per year may come from beef. Last I checked, E coli does not originate in water or produce. The science has shown us that a scary percentage of ground beef is adulterated with these pathogens, and they are entering our homes and kitchens via this route. Mr. Hodges also failed to tell us this well known fact in his review of the science he likes to wrestle with.

  • Daniel Cohen

    James Hodges analysis appears to be contradicted by a 2009-2010 review conducted by the the Food Research Institute, University of Wisconsin, Madison, funded in part by the American Meat Institute Foundation**.
    For example, in the review the authors find that cattle are the primary reservoir of non-O157:H7 STEC, that where country surveys have been done up to 40% of (various) meat samples were contaminated with non-O157:H7 STEC , and detection of non-O157:H7 cases and outbreaks are under-reported in the U.S. because of lack of routine public health testing.
    The relative larger proportion of person to person contact infection or “unknown” causation is also thought by the CDC to be due to the same analytic and reporting poverty:
    “These differences are likely due, in part, to the better analytical methods available for E. coli O157:H7. E coli O157:H7 is also more virulent than some non-O157:H7 STEC strains and thus outbreaks are recognized and investigated more rapidly and thoroughly.”
    The downside of testing is hard to see from Mr Hodges’ own argument. There appear to be no additional process interventions needed than already in place for O157:H7. Consumer confidence would be damaged again if there was a serious outbreak after a refusal to test for known emerging pathogens. The meat industry could voluntarily adapt a shiga toxin and/or stx genes testing regime that would cover the entire class and include the “big 6” non-O157:H7 as a consequence.
    A large number of commercial tests are available, and a testing regime with great statistical power could be implemented with low type I error rates (false positives) which would appear to be the main economic burden of adding testing if there were, in fact, less reason for outbreak concern.
    Meat is of course, only one product in the animal production cycle. On a wet mass basis it is almost a by-product of manure production. Manure, bones, hides, offal and brains and nervous tissue all find different markets. Meat production can be a critical control point for detecting emergent pathogen flow into the environment from animal production, as well as a control point for preventing pathogen flow into the food supply.
    Most people, the consumers, are resistant to being the testing regime for known, serious, emerging pathogens.
    Any intervention can have unintended consequences, and it would be useful to have more information from the industry on the basis for their opposition to non-O157:H7 testing.
    Dan Cohen
    Davis, CA
    ** White Paper on Non-O157:H7 Shiga Toxin-Producing E. coli
    from Meat and Non-Meat Sources. Kaspar, Dolye and Archer. FRI Food Safety Reviews 2010.

  • Mr. Hodges, I am particularly intrigued with 3 of your quotes about “science”:
    “I like to wriestle with the science”
    “I can’t find a scientific way to rationalize the path USDA is taking”
    “We must confront the scientific facts”
    At a FSIS-sponsored Traceback Hearing in DC on March 10, 2010, AMI’s VP Scott Goltry stated “AMI is unaware if a change to the trace back follow up sample procedure would have a significant improvement to public health”. Mr. Hodges, AMI’s definition of “science” opposes trace backs to the source, as “Richard” states above. I can perceive how AMI might want to insulate its slaughter plant members from liability for pathogens unwittingly deposited onto carcasses on their kill floors, which would be revealed by Tracebacks to the Source, but please don’t hide behind the skirt of “SCIENCE”.
    At the same public hearing, Mr. Goltry’s published remarks included this: “Regarding verification sampling, AMI would encourage the agency to review GROUND BEEF PRODUCTION PRACTICES [certainly not kill floor production practices] and sample ground beef products that are routinely produced by the PROCESSING FACILITY [certainly not the kill floor facility]. Excuse me for stating the obvious Mr. Hodges, but is it possible that AMI’s definition of “Science” focuses on FSIS scrutiny of operations at downstream, further processing operations, but NOT at the source slaughter establishments? Which is precisely why Mr. Goltry suggests, on AMI’s behalf, that trace backs to the source will not improve public health. Such pseudo-science effectively insulates AMI’s slaughter members from accountability. Whew! I thought that “SCIENCE” was a commendable pursuit.
    Perhaps the biggest pseudo-scientific claim embraced by both AMI and FSIS is that USDA-style HACCP is science-based. Raw meat & poultry does not enjoy a true CCP, because raw meat & poultry lack interventions which can Prevent, Eliminate or Reduce pathogens to a non-detectable level. Fully cooked, RTE meats DO have legitimate CCP’s. Well, since raw meat & poultry have only make-believe CCP’s, is it possible that AMI is opposed to testing for the new Big 6 STEC’s because such tests will prove that slaughter plants regularly experience ongoing multiple HACCP failures? Mr. Hodges, you can’t have it both ways: if we claim that safe raw meat is consistently produced via a plethora of validated interventions, we should proactively embrace testing which would prove that our raw meat is indeed consistently safe. Am I right in wondering if AMI is opposed to agency testing at source slaughter plants, and is ardently opposed to traceback to the source [slaughter plants]?
    Ain’t “science” wonderful!
    John Munsell

  • Tonight, I commenced reading Marion Nestle’s book “Safe Food: The Politics of Food Safety”. Early in her book, three of her statements dovetail perfectly with Jim Hodge’s comments on “science”:
    Page 16: “This book explains how food companies use science as a political tool to oppose requirements to keep harmful microbes out of food…..”
    Page 22: “In this book, we will see how the failure of food companies, scientists, and government agencies to recognize the need to address values as well as science in matters of food safety leads to widespread distrust of the food industry and its regulators”. Hmmmm..sound familiar?
    Page 30: “We will see how food producers repeatedly deny responsibility for foodborne illness, invoke science to promote self-interest and divert public attention from harm caused by their products, and express outright hostility to federal oversight”.
    I’ve heard this before. Akin to a person who says “God told me to tell you…..”. Since we can’t take on God, we’re supposed to acquiesce. Likewise, we are told “Science dictates that we embrace this policy” No one is going to oppose science, so such a remark is designed to prematurely terminate a conversation. End of discussion.
    Whenever anyone in our industry or FSIS states that their policies are science-based, I see more red flags than Khrushchev ever did. Authors of such statements have tired of defending their policies, so attempt to stifle all opposition by sanctimoniously hiding behind their pantheistic definition of “Science”, an ephemeral definition at best.
    John Munsell

  • Mr. Hodges, I am particularly intrigued with 3 of your quotes about “science”:
    “I like to wriestle with the science”
    “I can’t find a scientific way to rationalize the path USDA is taking”
    “We must confront the scientific facts”
    At a FSIS-sponsored Traceback Hearing in DC on March 10, 2010, AMI’s VP Scott Goltry stated “AMI is unaware if a change to the trace back follow up sample procedure would have a significant improvement to public health”. Mr. Hodges, AMI’s definition of “science” opposes trace backs to the source, as “Richard” states above. I can perceive how AMI might want to insulate its slaughter plant members from liability for pathogens unwittingly deposited onto carcasses on their kill floors, which would be revealed by Tracebacks to the Source, but please don’t hide behind the skirt of “SCIENCE”.
    At the same public hearing, Mr. Goltry’s published remarks included this: “Regarding verification sampling, AMI would encourage the agency to review GROUND BEEF PRODUCTION PRACTICES [certainly not kill floor production practices] and sample ground beef products that are routinely produced by the PROCESSING FACILITY [certainly not the kill floor facility]. Excuse me for stating the obvious Mr. Hodges, but is it possible that AMI’s definition of “Science” focuses on FSIS scrutiny of operations at downstream, further processing operations, but NOT at the source slaughter establishments? Which is precisely why Mr. Goltry suggests, on AMI’s behalf, that trace backs to the source will not improve public health. Such pseudo-science effectively insulates AMI’s slaughter members from accountability. Whew! I thought that “SCIENCE” was a commendable pursuit.
    Perhaps the biggest pseudo-scientific claim embraced by both AMI and FSIS is that USDA-style HACCP is science-based. Raw meat & poultry does not enjoy a true CCP, because raw meat & poultry lack interventions which can Prevent, Eliminate or Reduce pathogens to a non-detectable level. Fully cooked, RTE meats DO have legitimate CCP’s. Well, since raw meat & poultry have only make-believe CCP’s, is it possible that AMI is opposed to testing for the new Big 6 STEC’s because such tests will prove that slaughter plants regularly experience ongoing multiple HACCP failures? Mr. Hodges, you can’t have it both ways: if we claim that safe raw meat is consistently produced via a plethora of validated interventions, we should proactively embrace testing which would prove that our raw meat is indeed consistently safe. Am I right in wondering if AMI is opposed to agency testing at source slaughter plants, and is ardently opposed to traceback to the source [slaughter plants]?
    Ain’t “science” wonderful!
    John Munsell

  • Tonight, I commenced reading Marion Nestle’s book “Safe Food: The Politics of Food Safety”. Early in her book, three of her statements dovetail perfectly with Jim Hodge’s comments on “science”:
    Page 16: “This book explains how food companies use science as a political tool to oppose requirements to keep harmful microbes out of food…..”
    Page 22: “In this book, we will see how the failure of food companies, scientists, and government agencies to recognize the need to address values as well as science in matters of food safety leads to widespread distrust of the food industry and its regulators”. Hmmmm..sound familiar?
    Page 30: “We will see how food producers repeatedly deny responsibility for foodborne illness, invoke science to promote self-interest and divert public attention from harm caused by their products, and express outright hostility to federal oversight”.
    I’ve heard this before. Akin to a person who says “God told me to tell you…..”. Since we can’t take on God, we’re supposed to acquiesce. Likewise, we are told “Science dictates that we embrace this policy” No one is going to oppose science, so such a remark is designed to prematurely terminate a conversation. End of discussion.
    Whenever anyone in our industry or FSIS states that their policies are science-based, I see more red flags than Khrushchev ever did. Authors of such statements have tired of defending their policies, so attempt to stifle all opposition by sanctimoniously hiding behind their pantheistic definition of “Science”, an ephemeral definition at best.
    John Munsell