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A Turning Point for E. Coli Testing?

We just might be witnessing a watershed change in USDA attitudes regarding testing for E. coli O157:H7, corrective actions subsequent to adverse lab test results, and tracebacks to the true source of contamination.  

Due diligence must be addressed these next 12 months to monitor USDA/FSIS’ willingness to implement meaningful reforms as suggested by the Office of the Inspector General (OIG).  Public revelation by OIG of faulty FSIS meat inspection policies should provide the required incentive to FSIS to not only author policies that better promote public health, but to also be more transparent.

The following comments will serve as my brief response to OIG’s audit report, and to FSIS’ response to OIG’s recommendations.  

In the middle of page one, OIG states “….regardless of how stringently the industry tests for E.coli, there is always an inherent risk of its presence in slaughter plants” (emphasis added).  

beeftrimtests-iphone.jpg

In this Audit Report, OIG makes references to the fact that E. coli contamination emanates from hides and viscera.  OIG is thus refreshingly candid, acknowledging that E.coli originates on kill floors, not at downstream entities that do not have manure-covered hides or intestines on their premises.  If FSIS had made this common-sense admission years ago, and had focused its search for E. coli at the source, rather than the destination, the number of outbreaks would have been greatly diminished compared to what we continue to currently experience. 

 

On page two, the Audit Report states “We also found that FSIS needs to consider shifting more of its testing resources to sampling trim, instead of [sampling] ground beef, for E.coli.”  This is not ground-breaking news to FSIS.  On Dec. 5, 2006, an industry meeting was conducted in Denver regarding control of E. coli O157:H7 in slaughter operations.  At the meeting, Dr. Daniel Engeljohn (FSIS official) stated that the agency would commence testing trim in 2007 because the incidence of E. coli is three times greater in trim than in ground beef.

FSIS has known this fact for over five years now. 

 

OIG also stated “A recent study stated that trim testing has a higher probability of finding E. coli O157:H7 than ground beef testing.”  OIG further stated that FSIS should “… begin testing more trim so that it can (1) maximize its [testing] results, (2) better promote public health, and (3) trace contamination problems to the source.”  This is but yet another disciplinary rejoinder to FSIS that if it truly desires to promote public health, it must write policies enabling tracebacks to the SOURCE of contamination.  

Folks outside the industry do not fully comprehend why testing trim, rather than ground beef (as OIG suggests), would benefit public health, requiring an explanation.  The report states on page 14 that one reason FSIS has sampled more ground beef (than trim) is “….agency officials are responding to the public’s expectation that it will test ground beef, as the final product, for E. coli O157:H7.” 

The report also says that FSIS officials have stated “….they want to achieve an optimal balance between sampling costs and protecting public health.”  This FSIS statement flies in the face of OIG’s previously mentioned conclusion that testing trim promotes public health.  

In a legal brief a few years back, Dr. Engeljohn stated that the agency prefers to test meat as close to the consumer as possible. 

This statement has great PR benefits to the agency, which is thus portrayed as the quintessential, aggressive 24/7 protector of all consumers.  What FSIS slyly avoids revealing is the fact that such testing is conducted as far away from the source slaughter plant as possible.  

Testing ground beef downstream, rather than trim at the source slaughter plant, insulates source slaughter plants from pathogen accountability.  It also minimizes the threat of potential legal actions against FSIS from source slaughter plants impacted by exposure of the true origin of contamination.  While testing ground beef has some advantage to public health, the primary beneficiary of testing ground beef downstream is the source slaughter plant upstream.

So, how did FSIS respond to this OIG suggestion?  On page 16, the “Agency Response” is “If necessary changes are identified, FSIS will develop proposed changes…..”  Clearly, FSIS will not acknowledge the necessity of changing testing to primarily focus on trim.  Furthermore, FSIS has established a deadline of April, 2013 to reveal changes.  Not only is FSIS disputing OIG’s suggestion to primarily focus testing on trim, but has given itself almost a full year to devise a stratagem to circumvent OIG’s common-sense recommendation.

Page 20 of the OIG Report includes two scenarios of which I was unaware, and should cause heads to roll at the agency. The two scenarios are:

“Additionally, while we were visiting the plants, we noted that plant managers sometimes exploit ambiguities in FSIS’ sampling policies or procedures so that they can avoid receiving noncompliance records if FSIS inspectors find a positive E. coli O157:H7 test result.  

For example, FSIS allows plants to avoid a noncompliance if they have a written policy in place to send bins [of tested trim] to cooking that FSIS samples from and finds E. coli.  One plant quality assurance manager told OIG that the plant had implemented a policy to send every bin to cooking that FSIS samples, so that it could never receive a noncompliance due to FSIS’ testing results.   

OIG maintains that FSIS should eliminate this policy ambiguity because noncompliance records trigger more serious enforcement actions and require corrective action that would improve how the plant controls E. coli.”  

The primary problem here is that while OIG perceives the need for corrective actions when a plant experiences recurring E. coli positives, FSIS sees no need for corrective actions.

As if the first scenario isn’t embarrassing enough, OIG reveals this second scenario on page 20: ”A second policy ambiguity involves FSIS allowing plants to avoid noncompliance if an FSIS test and a plant test both result in a positive on a single sample.”

This logic is stupefying:  although trimmings tested by both FSIS and the plant both come back positive, removing all doubt of lab accuracy, FSIS implements no enforcement actions at the clearly noncompliant source slaughter plant.  

When company-conducted testing reveals the presence of E. coli, the impacted lot is diverted to a cooking plant, same as is done when E. coli is detected in FSIS-conducted testing.  Such diversions conveniently circumvent the need for corrective actions to prevent recurrences, a foundational requirement of true HACCP.  As such, the source slaughter plants and FSIS jointly place sole emphasis on prevention of SHIPMENT into commerce of contaminated meat, blithely ignoring ongoing PRODUCTION problems that are sanitary dressing failures on the kill floor.

When contaminated meat is detected, and diverted, FSIS congratulates the slaughter plant exclaiming “Your HACCP Plan is working!”  No NRs, and no corrective actions, although recurring lab positives prove ongoing sanitary dressing failures.

Pretty nifty, eh?

These policies are unconscionable, imperil public health and adroitly avoid the need for corrective actions to prevent recurrences.  Perhaps OIG is
only now realizing how FSIS has covertly abrogated its responsibility to protect consumers from foodborne outbreaks.  FSIS and the slaughter plants are equal accomplices in such sinister, scurrilous policies … which have not been transparent.

Bottom line:  all adverse lab reports deserve individual NRs.  FSIS refusal to issue NRs at source slaughter plants in spite of recurring lab positives imperils public health.  Corrective actions to prevent recurrences cannot be accomplished by diversion to cooking.  Meaningful corrective actions can only be accomplished on the kill floor, not by a sleight of hand, i.e., diversion.  FSIS disagrees.

On page 25, OIG’s Recommendation 7 to FSIS states in part “Improve communication by issuing guidance to industry to assist plants in selecting laboratories based on the capabilities of the testing laboratories.”  The agency’s response included a link to policy guidance announced on March 8, 2012.  Utilizing this guidance, I proposed an idea to the USDA’s Front Line Supervisor in Montana in April, which if approved would clarify FSIS expectations of small plants’ procedures to contract with outside labs.  

The Front Line Supervisor forwarded my suggestions to askFSIS on April 17.  As of Saturday, May 19, askFSIS had not yet provided an answer to Montana’s Front Line Supervisor.  When askFSIS was implemented, many plant owners and I sent questions to askFSIS.  Some received quick responses.  Unfortunately, most responses were delayed, were confusing, and some answers delicately skirted the issue.  

As a result, most plant owners with whom I visit no longer use askFSIS, for obvious reasons.  When the agency cannot even respond to a Front Line Supervisor within a month, we start to grasp how FSIS uses askFSIS as a PR front, but is frequently useless.  The agency’s refusal to provide meaningful answers, in an expedited fashion, also shows the agency’s bias against small plants.

I respectfully suggest that OIG should investigate askFSIS, which if it is the agency’s primary outreach to small plants, should be jettisoned and replaced by a group that will be held accountable.  

In conclusion, a popular industry mantra about eight years ago was that “We can’t test our way to safe food.”  I agree.  Testing alone doesn’t produce safe food.

Instead, consistently efficacious sanitary kill floor dressing procedures produce safe food. 

Testing can produce SAFER food, but only if adverse lab results lead to meaningful corrective actions to prevent recurrences.  Contents of this OIG report reveal that FSIS intentionally avoids issuing NRs subsequent to recurring lab positives for E. coli O157:H7.  

How frequently can a slaughter plant experience lab positives?  Page 36 of the OIG report refers to a plant which experiences 7, 15, 48 or more positives in one day.  The recent FSIS Traceback suggestions reveal that depending on a slaughter plant’s size and number of samples it takes daily, the plant could experience 5 – 8 percent or more positives before the agency will commence even considering whether these high numbers of positives might constitute a “High Event Period.”  Such thinking reveals the hypocrisy of the agency’s alleged “Zero Tolerance” standard towards E. coli O157:H7.  

Therefore, FSIS has knowingly enacted policies (some ambiguous and non-transparent) insulating slaughter plants from implementing corrective actions after E. coli O157:H7 is detected in their meat.  The same policies have effectively thwarted traceback attempts, with full FSIS endorsement.

Rather than giving FSIS almost a year to correct these inane practices, the agency should be forced to testify before the appropriate entity no later than June 15 to explain if OIG’s allegations are correct, and implement initial changes within two months.

  

John W. Munsell is manager of the Foundation for Accountability in Regulatory Enforcement (FARE) in Miles City, MT

© Food Safety News
  • Ted

    Proper credit is due FSIS: one absolutely must acknowledge the “public’s expectation that it will test ground beef, as the final product, for E. coli O157:H7″. Fine to test upstream, wonderful to root out dangerous operators at “the source” (but not all the way back to the farm of origin, though — that’s getting a little too close to home for R-CALF members, isn’t John?).
    John, your hidden political agenda is exposed here. It is clear you want to shift blame for contaminated ground beef up the supply chain and make “heads roll” at the corporate and agency levels. You are clearly not interested in food safety except to wield it as a bludgeon. As a consumer, I don’t care how it is accomplished but I expect ground beef I purchase from any legitimate outlet, however large or small, to be monitored for safety as near to my plate as possible. If FSIS can trace bad beef back through the supply chain all the way to the farm of origin, so much the better. And, yes, let heads roll all along the pathway, including the clueless little boob who ground up a bunch of bought-in trim and sold it to me to feed my kids.

  • Jon

    “Ted”– as food safety farmer bludgeoner in chief what part of SOURCE do you not understand??
    “In this Audit Report, OIG makes references to the fact that E. coli contamination emanates from hides and viscera. OIG is thus refreshingly candid, acknowledging that E.coli originates on kill floors, not at downstream entities that do not have manure-covered hides or intestines on their premises. If FSIS had made this common-sense admission years ago, and had focused its search for E. coli at the source, rather than the destination, the number of outbreaks would have been greatly diminished compared to what we continue to currently experience. ”
    That is: that meat on the hoof out grazing out in the farmers’ pasture is not contaminated. Once it’s penned up and finished on distillers grains, knee deep in toxic E coli in the factory farm feedlot — cheek by jowl with thousands more — is where the troubles begin.
    That contamination is brought into the packer facility on four feet (ambulatory, or less so) and then the E coli readily hits the fan… and finally gets ground up into your burger…

  • Ted
  • http://www.foodsafetyanalysis.com M. “Mike” Mychajlonka, Ph. D.

    John, I completely agree with your comments, observations and conclusions. “Inane” might well be the best descriptor of the current situation. Any improvement is welcome. Yet, we still seem to have elephants roaming around the living room. Prudence suggests that they be recognized:
    • It is well past time that meat was routinely pasteurized. Yes, those not familiar with developments seem to automatically, and erroneously conclude that only liquids may be Pasteurized and that the only Pasteurization modality is heat or irradiation. Yes, consumers are not likely to ever buy foods that have been irradiated. The radiodura label scares them because that label was designed to be scary. Yes, work remains to be done. Nevertheless, alternatives exist. For examples, consider that: (i), a patented process exists for the Pasteurization of whole eggs (thereby largely eliminating any threat from Salmonella) and (ii), a method has been found to treat commercially produced whole wheat bread (in its final packaging) so that its shelf life may be measured in months and not days (www.foodsafetyanalysis.com)
    • We are worry about STEC because it carries Shiga toxin. Published reports have already shown that the Shiga toxin is more heat resistant than the microorganisms that carry it. The field example here is of a batch of milk that was successfully Pasteurized and yet caused consumers to fall ill because that milk still contained active Shiga toxin. The industry needs to measure Shiga toxin directly and not just its carrier. The CDC has published such a method involving the use of an instrument (MALDI TOF MS/MS) that is pricey and nowhere near as easy to use as the “Tricorder” of Star Trek fame. On the other hand, such testing can be rapid and should adapt well to automation.
    • The basis of the mantra that “We can’t test our way to safe food” was the large number of samples that had to be tested to “prove” absence of various contaminants within reasonable statistical bounds. Consumers currently have virtually no say in the debate on food safety. Yes, consumers have the power of the purse, but they are not given the information of how to use it, until an outbreak occurs, at which point regulatory agencies have sometimes withheld information from consumers for fear that they would indeed exercise their power of purse. Furthermore, in a report published in July of last year, FDA has projected that the growth of food imports into the U.S. may mean that many current domestic food producers may find themselves unable to compete and so will be pushed out of the U.S. market by foreign competitors (which FDA admits are harder to regulate). It is in the interests of both consumers and food producers to collaborate and make common cause for the sake of food safety. Why should food, proven by transparent testing results, to be safer NOT enjoy a pricing advantage? One company (www.foodsafetyanalysis.com) already offers a “shared cost” model to consumers for testing levels of arsenic, lead and mercury in foods that sometimes have high levels of these contaminants. The price to the individual consumer is affordable (five bucks). The trade-off is that a number of consumers must request the same test before it may be run and the results shared by all participants (who also shared the costs). Why should manufacturers of apple juice, honey and other products not participate in this program? They could buy “shares” of this testing as well and advertise the fact to their customers. Such numbers could be quite useful data for the annual HACCP review. The accountant poring over the books of any such company can take solace that such expenditures can be allocated to two different cost centers (advertising and regulatory affairs). At the same time, she knows that the company’s customers helped foot a portion of the total bill. Everybody wins. Such testing schemes need not be limited to heavy metals.

  • http://www.johnmunsell.com jmunsell

    Hi Ted. Let’s talk about the live animals first. As OIG admits in its report, E.coli emanate from manure and viscera (intestines), which arrive at slaughter plants in and on live animals. The industry is investing time and money in what are called “Pre Harvent Interventions”, i.e., how can feedlots reduce the incidence of E.coli in and on animals arriving at slaughter plants. Thus far, vaccines and bacteriophages (viruses which kill bacteria like E.coli) have the most promise, but are still in research and development. So, our ability to kill E.coli in live animals is limited at this point. Maybe in future years we’ll have success stories to share. Just like polio, which took years to control.
    Establishments which grind burger, but don’t slaughter, do not have manure-covered hides or intestines on their premises. (These establishments include your local retail meat markets like Safeway & Costco, and some restaurants). So, if their burger contains E.coli, in all likelihood, they unwittingly purchased meat from their source slaughter suppliers which was already laced with invisible pathogens.
    When I sent samples of my burger to outside labs for E.coli analysis, the total cost to me per sample was $70, including FedX next-day fees. Do we expect our local meat markets to send a sample of EVERY batch of burger to outside labs? And of course, to test & hold, which means they must quarantine and hold the burger pending receipt of lab reports? Want your local meat market to quarantine their burger for 3 or 4 days waiting for a lab report? Their placards would be changed to “Ground Fresh Daily – 4 days ago”.
    Not only do I advocate for safe food, but I also advocate for legitimate rights of meat plants and livestock producers. You referred to R-Calf. Did you know that R-Calf endorsed my “Traceback Bill”, which if enacted would require USDA to trace back to the slaughter plant SOURCE of E.coli? Did you also know that the Montana Stockgrowers endorsed my bill? And the Montana Cattlemen Association? And the United States Cattlemen Assoc? Regardless of their affiliations, cattlemen realize that consumer confidence is adversely impacted by outbreaks and recalls. To improve food safety, cattlemen (and now USDA’s Office of Inspector General), realize that E.coli must be detected at the SOURCE, and then Force the Source to clean up its act, rather than force the destination to somehow clean up someone else’s unsafe meat.
    The OIG report included this statement about USDA’s testing for E.coli: “At present, if the contamination level [of E.coli] is very low, FSIS is more likely to miss contamination than to detect it”. In the last ten years, the incidence of E.coli in agency-conducted testing has been 3/10 of 1%. Because of its low incidence, testing does NOT always detect the pathogen’s presence, and OIG admits it. Now that the agency has publicly admitted the limitations of testing, USDA has been touting the need for Prevention at the Souce Slaughter Plants!
    R-Calf asked if I would chair their HACCP committee, which I gladly do. If any other livestock organizations requested the same of me, I would gladly do so. Ted, please realize that Traceback to the Source is not unique to R-Calf, but broadly shared by cattlemen, as well as by consumers. Who in their right mind would oppose tracebacks to the SOURCE of contamination? Answer: only USDA, evidenced by their historical misbehavior. But, top agency meat inspection officials are now embracing traceback, and we are witnessing a watershed change at USDA which will benefit all. I whole-heartedly endorse the top FSIS officials and their bold new positions.
    Likewise, USDA’s Undersecretary for Food Safety Dr. Elisabeth Hagen was also quoted in the OIG report stating that as the agency commences testing for the new Big Six non-O157:H7 STEC’s, the agency will test trim, NOT ground beef! Why? Dr. Hagen says FSIS will get more “bang for its buck” by testing trim because E.coli is MUCH more likely to be detected in the trim, rather in ground beef. When trimmings are ground, the small amount of resident E.coli bacteria are diluted, spread around, and more difficult to detect.
    Hope this clarifies the issue, and thanks for your interest. Please cross examine me all you want: we must all become more transparent when it comes to our willingness to detect the source of E.coli, and then to control it at the source.
    John Munsell

  • Ted

    “Want your local meat market to quarantine their burger for 3 or 4 days waiting for a lab report?”
    Yes, absolutely yes. I want it tested and I don’t want to hear about positive tests 3 days after my kids have eaten it — by then probably even I know there was a problem with the burger, what with kids vomiting and spraying diarrhea who wouldn’t notice? Prevention is what I want.
    “Did you know that R-Calf endorsed my “Traceback Bill”, which if enacted would require USDA to trace back to the slaughter plant SOURCE of E.coli?”
    Yeah, I’m not surprised because R-CALF’s agenda is your agenda, which is to blame large slaughter plants but STOP SHORT of tracing back to the farm of origin. That would require a meaningful system like NAIS, which R-CALF steadfastly opposes. They don’t want to be held responsible for quality problems with their animal products — they want to cash the checks, remain anonymous and pass any blame onto corporations. We get it, John.

  • Jon

    “Ted” — if you look a little more closely — past your jerking knee — you’ll see that I was absolutely describing the conventional meat system — not grass fed as you so lovingly depict it (NOT).
    Actually most conventional beef is initially raised on grass (excepting old and spent dairy cows) but FINISHED in factory feed lots, knee deep in toxic E coli, etc….
    .

  • http://www.johnmunsell.com John Munsell

    Hi Ted. Let’s talk about the live animals first. As OIG admits in its report, E.coli emanate from manure and viscera (intestines), which arrive at slaughter plants in and on live animals. The industry is investing time and money in what are called “Pre Harvent Interventions”, i.e., how can feedlots reduce the incidence of E.coli in and on animals arriving at slaughter plants. Thus far, vaccines and bacteriophages (viruses which kill bacteria like E.coli) have the most promise, but are still in research and development. So, our ability to kill E.coli in live animals is limited at this point. Maybe in future years we’ll have success stories to share. Just like polio, which took years to control.
    Establishments which grind burger, but don’t slaughter, do not have manure-covered hides or intestines on their premises. (These establishments include your local retail meat markets like Safeway & Costco, and some restaurants). So, if their burger contains E.coli, in all likelihood, they unwittingly purchased meat from their source slaughter suppliers which was already laced with invisible pathogens.
    When I sent samples of my burger to outside labs for E.coli analysis, the total cost to me per sample was $70, including FedX next-day fees. Do we expect our local meat markets to send a sample of EVERY batch of burger to outside labs? And of course, to test & hold, which means they must quarantine and hold the burger pending receipt of lab reports? Want your local meat market to quarantine their burger for 3 or 4 days waiting for a lab report? Their placards would be changed to “Ground Fresh Daily – 4 days ago”.
    Not only do I advocate for safe food, but I also advocate for legitimate rights of meat plants and livestock producers. You referred to R-Calf. Did you know that R-Calf endorsed my “Traceback Bill”, which if enacted would require USDA to trace back to the slaughter plant SOURCE of E.coli? Did you also know that the Montana Stockgrowers endorsed my bill? And the Montana Cattlemen Association? And the United States Cattlemen Assoc? Regardless of their affiliations, cattlemen realize that consumer confidence is adversely impacted by outbreaks and recalls. To improve food safety, cattlemen (and now USDA’s Office of Inspector General), realize that E.coli must be detected at the SOURCE, and then Force the Source to clean up its act, rather than force the destination to somehow clean up someone else’s unsafe meat.
    The OIG report included this statement about USDA’s testing for E.coli: “At present, if the contamination level [of E.coli] is very low, FSIS is more likely to miss contamination than to detect it”. In the last ten years, the incidence of E.coli in agency-conducted testing has been 3/10 of 1%. Because of its low incidence, testing does NOT always detect the pathogen’s presence, and OIG admits it. Now that the agency has publicly admitted the limitations of testing, USDA has been touting the need for Prevention at the Souce Slaughter Plants!
    R-Calf asked if I would chair their HACCP committee, which I gladly do. If any other livestock organizations requested the same of me, I would gladly do so. Ted, please realize that Traceback to the Source is not unique to R-Calf, but broadly shared by cattlemen, as well as by consumers. Who in their right mind would oppose tracebacks to the SOURCE of contamination? Answer: only USDA, evidenced by their historical misbehavior. But, top agency meat inspection officials are now embracing traceback, and we are witnessing a watershed change at USDA which will benefit all. I whole-heartedly endorse the top FSIS officials and their bold new positions.
    Likewise, USDA’s Undersecretary for Food Safety Dr. Elisabeth Hagen was also quoted in the OIG report stating that as the agency commences testing for the new Big Six non-O157:H7 STEC’s, the agency will test trim, NOT ground beef! Why? Dr. Hagen says FSIS will get more “bang for its buck” by testing trim because E.coli is MUCH more likely to be detected in the trim, rather in ground beef. When trimmings are ground, the small amount of resident E.coli bacteria are diluted, spread around, and more difficult to detect.
    Hope this clarifies the issue, and thanks for your interest. Please cross examine me all you want: we must all become more transparent when it comes to our willingness to detect the source of E.coli, and then to control it at the source.
    John Munsell

  • http://www.johnmunsell.com jmunsell

    Ted: Regarding your desire that local meat markets test burger, and quarantine it pending lab reports. USDA’s OIG stated that because of the low prevalence of E.coli in trim, that agency testing will more likely NOT detect its presence than detect it. When that trim gets ground into burger, detection of the pathogen will be even LESS LIKELY because the bug will have been diluted via mixing in the grinding process.
    Sad, but even if your local meat market tests every batch of burger, over 50% of “hot” lots will not be detected, and folks will continue to get sick.
    So, testing is NOT the panacea, and has severe limitations. Because of testing’s inability to produce consistently safe food, NASA and the Army contracted with Pillsbury in 1959 to develop a food production system which could produce safe food, and HACCP was born. Under HACCP, every stage of the kill floor production process should be tested, and individually validated to ensure food safety. True HACCP requires testing the process, while USDA-style HACCP prefers to test the final product, with all its limitations.
    Finally, the OIG report included this statement “….regardless of how stringently the industry tests for E.coli, there is always an inherent risk of its presence in slaughter plants”. So, (1) OIG doesn’t speak of an inherent risk at your local meat market, but at the SOURCE, which is the slaughter plant. (2) Frankly, all raw meat & poultry carries an inherent risk. (3) We consumers need to be vigilant, and do all we can to prevent cross-contamination in our kitchens, and to properly handle and cook meat. (4) Because of this inherent risk, the only remaining option is for retailers to either fully cook or irradiate ground beef, thereby killing all bacteria. But, consumers prefer to purchase raw steaks, ground beef, roasts etc at the local meat market.
    John Munsell

  • http://www.johnmunsell.com John Munsell

    Ted: Regarding your desire that local meat markets test burger, and quarantine it pending lab reports. USDA’s OIG stated that because of the low prevalence of E.coli in trim, that agency testing will more likely NOT detect its presence than detect it. When that trim gets ground into burger, detection of the pathogen will be even LESS LIKELY because the bug will have been diluted via mixing in the grinding process.
    Sad, but even if your local meat market tests every batch of burger, over 50% of “hot” lots will not be detected, and folks will continue to get sick.
    So, testing is NOT the panacea, and has severe limitations. Because of testing’s inability to produce consistently safe food, NASA and the Army contracted with Pillsbury in 1959 to develop a food production system which could produce safe food, and HACCP was born. Under HACCP, every stage of the kill floor production process should be tested, and individually validated to ensure food safety. True HACCP requires testing the process, while USDA-style HACCP prefers to test the final product, with all its limitations.
    Finally, the OIG report included this statement “….regardless of how stringently the industry tests for E.coli, there is always an inherent risk of its presence in slaughter plants”. So, (1) OIG doesn’t speak of an inherent risk at your local meat market, but at the SOURCE, which is the slaughter plant. (2) Frankly, all raw meat & poultry carries an inherent risk. (3) We consumers need to be vigilant, and do all we can to prevent cross-contamination in our kitchens, and to properly handle and cook meat. (4) Because of this inherent risk, the only remaining option is for retailers to either fully cook or irradiate ground beef, thereby killing all bacteria. But, consumers prefer to purchase raw steaks, ground beef, roasts etc at the local meat market.
    John Munsell

  • Minkpuppy

    Here’s the point of this article as I see it:
    Grinding plants purchase trimmings that have been “USDA Passed and Inspected” and in most cases tested by the producing plant which provides a Certificate of Analysis that the trimmings tested negative for E. coli 0157:H7. They have a reasonable expectation at that point that their ground beef is also going to be free of the pathogens.
    There’s just one problem. That Certificate of Analysis ain’t worth the paper it’s printed on and certain FSIS inspectors and officials will admit it freely (as long as it stays off the record–can’t contradict the big bosses!). The current N60 trim sampling method is highly inadequate when it comes to catching positive samples but it’s all we’ve got right now.
    Ground beef sampling is a good FINAL step in the process to prevent it from hitting the food supply but the blame should not be dumped totally on the grinder. He or she is at the mercy of the trim supply. The grinders can practice all kinds of things to minimize cross contamination but the bottom line is this: If their product tests positive, it’s 100% because some or all of the source material was contaminated! Certificate of Analysis be damned. The grinder has absolutely no guarantees that the source trimmings are safe even if they were tested. Because the test “misses” positives so much of the time, even if your grocer did hold his ground beef for the test results, it’s still no guarantee that you won’t get sick. Heck, might even be more likely since now it’s had more time to grow.
    Ground beef sampling should be used by FSIS to determine where the problems are occurring upstream at the slaughter plants and deal with it there as well. It’s not being used that way. It’s being used by some District Managers as a tool to unfairly punish small plants that are busting their butts trying to do everything right. They resent “wasting” inspection resources on small plants when the big plants are short-handed. It’s shameful and I hope this District rearrangement gets rid of those with that attitude.
    Sure, we can trace back to the farm of origin but at this point it isn’t going to mean much because there isn’t much that can be done to stop or reduce shedding in the live animals. The probiotics and vaccines are still in the research phase but they seem to be the best bet. Feeding concentrated citrus peels has also shown some promise as an anti-E. coli feed additive–very attractive option in Texas, California and Florida where there’s lots of leftover peels from the juice industry. What little else I’ve found on changing husbandry practices is inconclusive (didn’t seem to make a difference one way or another). Diet doesn’t seem to mean much either except with possibly distiller’s grains but that research seems to have a lot of conflicts also.
    HACCP doesn’t really apply well on the farm–it can be used to verify that feed sources are protected from contamination and that vaccines are used but that’s about it as I see it. There’s too many variables to set up solid critical control points which is what HACCP relies on to work.
    FSIS should never have tried to apply HACCP to slaughter plants for that very reason. It’s great for processing plants, where there’s a cooking temperature that kills bacteria and chilling processes that are designed to stop pathogen growth. Not so much on the kill floor where contamination can occur throughout the carcass dressing procedure and there’s no one place where they can put a control to stop it.
    Until something effective is found for the live animal, the big plants need to SLOW DOWN the lines to give the employees adequate time to perform the procedures correctly. The animals need to be cleaner coming in to the plant. The slaughter plants need to be held accountable.

  • http://www.johnmunsell.com jmunsell

    Mink Puppy states above “The grinder has absolutely no guarantees that the source trimmings are safe even if they were tested”. USDA is FULLY COGNIZANT of this dilemma. To show the agency’s complicity in this dilemma, FSIS stated the following in FSIS Notice 05-09: “An establishment that receives, grinds, or otherwise processes raw beef products cannot conclude that E.coli O157:H7 is not reasonably likely to occur in its production process because the product it receives bears the mark of inspection”. End quote.
    Subsequently, the agency issued a training brochure entitled “Prerequisite Programs for E.coli O157:H7″, in which it revealed “Grinders with prerequisite programs should not rely on the mark of inspection to accept incoming product”.
    Whew! When the agency publishes documents for public viewing in which USDA acknowledges that its official Mark of Inspection is valueless, well, the consuming public should rise in opposition to the agency’s deregulation of the source slaughter plants.
    When agency investigators visit a plant which has experienced E.coli problems, agency inspectors who witness such investigations subsequently relate identical stories, which is that USDA investigators dedicated 95% – 98% of their time poring over written paperwork, instead of scrutinizing production lines! Investigators always issue reports which claim that alleged failures in a company’s written HACCP Plan, Purchasing Specifications, SSOP’s etc were inadequate, and must be rewritten. Cogitate on that for awhile! FSIS claims that grinding plants experienced E.coli-contaminated meat because of alleged failures in their WRITTEN plans! Hogwash! Balderdash! Poppycock! E.coli-contaminated meat comes out of grinders because the trimmings that went into the grinder were previously laced with invisible pathogens. E.coli bacteria didn’t magically appear because of alleged paperwork errors! FSIS ardently disagrees.
    American consumers must steel themselves against a future in which pathogen-laden meat floods the marketplace, because USDA prefers to audit paperwork, instead of inspecting meat. The primary culprit here is not unsanitary conditions at grinders, but a lazy USDA which unashamedly admits that its Mark of Inspection is but fluff. When the mark of inspection has credibility at the large slaughter plants, only then will consumers rightly perceive that meat in commerce is safer.
    John Munsell

  • http://www.foodsafetyanalysis.com M. “Mike” Mychajlonka, Ph. D.

    John, although I agree with much of what you say and especially your comments about the necessity of tracing contamination back to its source, I cannot agree with everything that you say. The efficiency with which testing is able to identify a problem has a great deal to do with both the analytical sensitivity of the testing used and with the number of samples tested. If you do not specify both of these two parameters, you have no basis for commenting that “. . . testing is NOT the panacea, and has severe limitations.”
    In the case of STEC, what makes people sick is the Shiga toxin, not necessarily the strain of Escherichia coli carrying the Shiga toxin. Shiga toxin is deadly to people but much less so to bovines. In fact, there is good reason to believe that Shiga toxin may actually protect bovines from bovine leukemia under the highly stressed “finishing” conditions under which they spend the last days of their lives. So, if you wish to go back to the source, consider that the true source may not be the killing floor itself, but rather the finishing pens outside of it and perhaps even the farms supplying the cattle or the sparrows and rats also living on that farm. That is why I suggested in my previous post that testing methods actually test for the problem (Shiga toxin), not just the messenger (STEC). One study (Renter et al. Can J Vet Res. 2004 April; 68(2): 150–153) found the prevalence of Shiga toxin in 92% of feedlots of which only 8% were E. coli O157/H7.
    Lastly, even if one were to adopt the idea that shooting (i.e., Pasteurizing) the messenger (STEC) is a worthy goal, it is wrong of you to suggest that our only choices are to pre-cook our meat or to irradiate it. As I have said in a previous post to this thread, there are now various methods with which Pasteurization may be accomplished that do not involved either cooking the meat or irradiating it. But then, analysis for the actual problem (i.e., Shiga toxin) becomes even more important. For example, irradiation kills by causing the formation of unnatural bonds within an organism’s DNA, which prevent the replication of that DNA. A STEC cell no longer able to divide is considered “dead” to analysis by microbiological methods, but that does not mean that it is unable to metabolize for a while. When it does finally die, it will release its contents (including Shiga toxin) to its environment.
    This problem is a technical one but the press it gets seems to be mostly political. The situation is reminiscent of the old story of the drunk who stumbles and falls on a dark sidewalk as he is leaving the bar. He picks himself up, notices that he has lost his car keys so he walks over to a streetlamp where his cafr is parked and starts examining the gutter. A passerby notices this and asks what he is doing. The drunk replies that he is looking for his car keys. The passerby asks if he is not much more likely to find this keys by checking the sidewalk where he stumbled only to have the drunk reply that it is too dark over there but here by the streetlight, he can see what he is doing.
    When are we all going to shine a light on the actual problem and stop stumbling around in the dark?

  • http://www.johnmunsell.com jmunsell

    Dr. Mike: Gotta admit, I don’t fully comprehend what your conclusions are, but I’m greatly interested. Are you suggesting we should perform different kinds of testing (for shiga toxin, rather than specific serotypes of E.coli), or sensitivity or the number of samples collected? Perhaps FoodSafetyNews would consider you authoring an article with specific conclusions, written so that a non-PhD can readily understand the reasons for and implications of your suggestions.
    One reason I make references to the inadequacies of testing is that testing’s inability to consistently produce safe food was the primary reason NASA and the Army contracted with Pillsbury in 1959, which resulted in Pillsbury’s development of the HACCP ideal. NASA required safe food for astronauts, but could not find any existing food production system in existence in 1959 capable of consistently producing safe food.
    A speaker at a Meat Safety Conference in Chicago stated that N-60 testing was statistically irrelevant, because of the low incidence of E.coli O157:H7. But USDA has always accepted N-60. Is this what you’re referring to when mentioning the number of samples collected?
    Anyway, could you provide a list of your conclusions, where we and USDA should go from here?
    John Munsell

  • http://www.johnmunsell.com John Munsell

    Mink Puppy states above “The grinder has absolutely no guarantees that the source trimmings are safe even if they were tested”. USDA is FULLY COGNIZANT of this dilemma. To show the agency’s complicity in this dilemma, FSIS stated the following in FSIS Notice 05-09: “An establishment that receives, grinds, or otherwise processes raw beef products cannot conclude that E.coli O157:H7 is not reasonably likely to occur in its production process because the product it receives bears the mark of inspection”. End quote.
    Subsequently, the agency issued a training brochure entitled “Prerequisite Programs for E.coli O157:H7″, in which it revealed “Grinders with prerequisite programs should not rely on the mark of inspection to accept incoming product”.
    Whew! When the agency publishes documents for public viewing in which USDA acknowledges that its official Mark of Inspection is valueless, well, the consuming public should rise in opposition to the agency’s deregulation of the source slaughter plants.
    When agency investigators visit a plant which has experienced E.coli problems, agency inspectors who witness such investigations subsequently relate identical stories, which is that USDA investigators dedicated 95% – 98% of their time poring over written paperwork, instead of scrutinizing production lines! Investigators always issue reports which claim that alleged failures in a company’s written HACCP Plan, Purchasing Specifications, SSOP’s etc were inadequate, and must be rewritten. Cogitate on that for awhile! FSIS claims that grinding plants experienced E.coli-contaminated meat because of alleged failures in their WRITTEN plans! Hogwash! Balderdash! Poppycock! E.coli-contaminated meat comes out of grinders because the trimmings that went into the grinder were previously laced with invisible pathogens. E.coli bacteria didn’t magically appear because of alleged paperwork errors! FSIS ardently disagrees.
    American consumers must steel themselves against a future in which pathogen-laden meat floods the marketplace, because USDA prefers to audit paperwork, instead of inspecting meat. The primary culprit here is not unsanitary conditions at grinders, but a lazy USDA which unashamedly admits that its Mark of Inspection is but fluff. When the mark of inspection has credibility at the large slaughter plants, only then will consumers rightly perceive that meat in commerce is safer.
    John Munsell

  • http://www.johnmunsell.com John Munsell

    Dr. Mike: Gotta admit, I don’t fully comprehend what your conclusions are, but I’m greatly interested. Are you suggesting we should perform different kinds of testing (for shiga toxin, rather than specific serotypes of E.coli), or sensitivity or the number of samples collected? Perhaps FoodSafetyNews would consider you authoring an article with specific conclusions, written so that a non-PhD can readily understand the reasons for and implications of your suggestions.
    One reason I make references to the inadequacies of testing is that testing’s inability to consistently produce safe food was the primary reason NASA and the Army contracted with Pillsbury in 1959, which resulted in Pillsbury’s development of the HACCP ideal. NASA required safe food for astronauts, but could not find any existing food production system in existence in 1959 capable of consistently producing safe food.
    A speaker at a Meat Safety Conference in Chicago stated that N-60 testing was statistically irrelevant, because of the low incidence of E.coli O157:H7. But USDA has always accepted N-60. Is this what you’re referring to when mentioning the number of samples collected?
    Anyway, could you provide a list of your conclusions, where we and USDA should go from here?
    John Munsell

  • http://www.foodsafetyanalysis.com M. “Mike” Mychajlonka, Ph. D.

    John, sorry for the delay in responding, but I was out grilling hamburgers this holiday weekend. Yes, I should know better, but they taste so good even though I no longer prepare them on the rare side.
    Yes, I think it would be a good idea to quantify the problem (Shiga toxin) rather than the carrier (STEC). Yes, attention must be paid to those horrible statistics, which relate the number of samples that need to be taken to quantify a low probability event within a given set of confidence limits. Yes, I agree with the speaker you heard at a Meat Safety Conference regarding N-60 testing. If the decision is to quantify one or more Shiga-toxin containing of STEC that are present in low numbers, then I should think a most probable number method should be used, which any system that allows samples to be consolidated prior to testing, is not. If taking samples is a problem for inspectors, then an automated sampling device should be constructed and provided to inspectors.
    As for writing an opinion piece for Food Safety News, I would be happy to, if asked. It may take me a little while to construct a piece that lays out, for the layman, a molecular biology-based test for Shiga toxin as quantified by a high-end mass spectrometer and then finish up with an overview of sampling theory and still entertain hopes of having a conscious audience when I am done. Still, I am willing to make the effort if it means being able to eat my hamburgers medium rare again.
    In terms of my presenting a list of conclusions, above and beyond the foregoing, I would rather not. I have been a teacher for enough years to know that if folks don’t know the context of where a conclusion is coming from, they won’t believe it anyway.
    It would be better, I think, to write the article and let that be the preface for conclusions. I would like to retain the copyright to any such article, so I may use it on my own website, and elsewhere. I am a consultant, after all.