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Letter From The Editor: Test Run for New FSIS Traceback Policy


Troy and Sterling Heights are a pair of hardscrabble Michigan towns both about 20 miles north of Detroit now dealing with a Salmonella Typhimurium outbreak.

Each has a retail meat market that since Thursday first recalled 500 and then the second 550 pounds of ground beef. Each meat market in turn sold ground beef to an un-named restaurant, also north of Detroit in Macomb County. At this point most of the illnesses involve folks who dined on an Arab dish at that restaurant where the ground beef is served raw.

Little businesses, small recalls, and local folks poisoned by not taking enough precautions with their ethnic or religious traditions. We should not expect to see much interest in this one, should we?  Or just maybe we should.

For one thing, within hours of the USDA’s Food Safety and Inspection Service (FSIS) announcement of the second small meat market recall, the federal Centers for Disease Control and Prevention (CDC) announced the expansion of the Salmonella Typhimurium outbreak to 16 illnesses in five states.

It does not seem likely that all the Salmonella Typhimurium illnesses in those four other states could have resulted from dining at the same north Detroit restaurant. More likely there is a common source out there, one that supplied both of those retail meat markets and others.

That was back in the  day when FSIS had little interest in knowing if a common source existed or doing anything about it.   And, you could double that if the common source was a big beef plant.  Think of it as FSIS circa 2002. Call it the bad old days.  If you don’t believe it, do a search on Food Safety News for “John Munsell.

John’s family owned a small meat plant in Miles City, MT that in 2002 had to recall 207 pounds of ground beef for E. coli O1157:H7 that was supplied by the massive slaughter plant at Greeley, CO. It’s a long story, but trust me that everybody including everybody involved at FSIS well knew the little plant in Miles City got its contaminated beef from the big plant in Greeley.  But, rather than go after the source back then, FSIS just shut down John’s business for four months.

FSIS in 2002 had no interest in knocking on doors at the always politically powerful  Greeley plant, and it’s “see no evil, hear no evil, speak no evil” approach would shortly directly contributed to a large E. coli outbreak a few months later for which the then ConAgra plant was rightly blamed.

ConAgra’s post outbreak recall was just a little larger than John’s, coming in at 19.1 million pounds of beef with some 40 sickened and 1 dead.  Even our publisher, Bill Marler, feels that listening to John would have saved lives.

Back then, it was FSIS policy  to make the John Munsell’s of the world feel like they were a character in their own Franz Kafka novel.  Tracing E. coli to its source was not in FSIS’s job description, especially if it led to a big beef plant owned by the likes of ConAgra.

JBS, USA owns the Greeley plant today. Dick and Charlie Monfort, owners of the Colorado Rockies, previously owned the Greeley plant before selling it to ConAgra in 1987. (Both Dick and Charlie continued in major management positions for ConAgra well into the 1990s.)

Almost 500 miles north of Greeley on the Yellowstone River, John decided he fight the bastards, be they in big government or big business. He sold his small meat plant and founded the Foundation for Accountability in Regulatory Enforcement (FARE).

And last year, he scored a victory when FSIS came out with a new policy to track E. coli contamination to the source whether or not illnesses are involved and the trace back investigation would begin immediately.

The new policy should make it a whole new ballgame for a newly empowered version of FSIS. Neither of the little meat markets in Michigan are likely the “common source” of an outbreak involving at least five states. So, we are about to find out if the new policy is real or, as they use to say, memorex.

Once the new FSIS identifies the common source for this Salmonella Typhimurium outbreak, John is sure to  have some additional questions. Like will FSIS audit that facility, conduct an HACCP reassessment, require corrective actions, and require stepped up Salmonella testing?

“And perhaps most importantly,” he asks, “will the establishment be required to recall source material from the same production dates on which it produced contaminated meat sold to these two Michigan retail store?”

Long story short, John sees two Michigan meat markets as  “small time, flies in the ointment” that are in the next few days and or maybe weeks going to make for a nationally important test because they will tell us all if FSIS really intends to “challenge the source.”

And I am sure for John if the actual source turns out to be a large plant owned by a JBS, Cargill, or Tyson’s,  it might bring a little smile to an old cowboy’s face.

Possibility helpful footnote:  John wrote a multi-part series in 2011 for Food Safety News, recalling the events that turned him into the activist who some today call the “Meatpacking Maverick.”  The first installment can be found here.

© Food Safety News
  • johnmunsell

    I must interject that this entire scenario has nothing to do with me.  Rather, it exists to reveal that FSIS has almost exclusively targetted small, downstream further processing plants with all food safety liability when pathogens are discovered out in commerce.  As such, the agency knowingly allows pathogen-laced meat to be shipped into commerce from the largest slaughter plants.  Subsequently, the agency spares no expense in detecting the pathogens DOWNSTREAM, and eggregiously targets the victimized downstream plants for aggressive agency enforcement actions.  FSIS allows the horses out of the barn, and attempts to retrieve them later.

    This shell game is about to end, whether the agency admits it or not.  Their ploy is being discovered.

    Events of this next week will be most interesting as the agency conducts its investigation of the one source slaughter plant, which is as yet unnamed.  Will the agency finally step up to the plate and do what is right?  My guess:  if the source slaughter plant is small, it will soon be extinct.  If it is a large plant, well, perhaps their wrists will be slapped.  Welcome to meat inspection, FSIS-style.

    Top FSIS officials, such as Dr. Elizabeth Hagen, Al Almanza, and Dr. Daniel Engeljohn want to do what is right.  Their primary opposition will be agency lifer bureaucrats, OMB and the Oval Office, all of whom are afraid of legal challenges from the largest packers and their associations.  And because of the agency’s pre-HACCP promises to deregulate the industry, the packers deserve to win in court.  When the agency promised it would embrace a “Hands Off” role under HACCP, would no longer police the industry, and would jettison its previous command-and-control authority, FSIS unwittingly emasculated itself, while justifying its unwillingness to trace back to the source.

    John Munsell

    • Gerald Zirnstein

       Excellent analysis John (and Bill).

  • Richard Raymond

    It will be interesting to see what happens, and, perhaps, game changing. Hang in there John, you are  a voice for the right. I am pleased to call you my friend. And, of course, Kathy too.

  • johnmunsell

    In the 90’s, FSIS made a deal with our industry.  The agency stated that if we would implement HACCP, the agency (1) would (a repeat of above) no longer police the industry, as we could police ourselves.  The agency (2) would also disband its previous command-and-control authority.  It also said it (3)  would embrace a “Hands Off” role.  Furthermore, it stated that (4) plants could write their own HACCP Plans, and the agency couldn’t tell us what had to be in our HACCP Plans.  JDFj, this last promise is an outright farce.  At least at small plants, FSIS dictates the changes we must implement in our HACCP Plans.  If we refuse, we are inundated with NR’s.  And, lots of NR’s are justification for a “For Cause” FSA.  Pretty nifty, eh?

    Because of promises 1 – 3, what right or authority does FSIS to intervene “Hands On” when problems arise?  They can no longer police us, if we take them at their word.  How can FSIS implement enforcement actions against us, when they promised to acquiesce its previous command-and-control authority?  The agency dangled carrots in front of us in the 90’s, promising that in return for us authoring and implementing our paper-based HACCP systems, the agency would allow us to police ourselves.  We jumped for joy.  Now, when HACCP hasn’t been as science-based or effective as originally envisioned, FSIS realizes it must re-embrace a more “Hands On” role, and take back some of its previous police powers.

    JDFj, this is a covert Bait & Switch ploy by FSIS.  The agency jettisoned its pre-HACCP national standards, allowing every plant to author their own protocol, critical limits, CCP’s, etc.  But the agency relishes the privilege of rejecting our critical limits etc as being ostensibly non-science based, inadequate, incomplete, etc.  In the absence of previous national standards, FSIS torments and harasses plants in spite of our infusion of massive dollars and personnel hours engineering our unique HACCP Plans.  However, these problems exist almost exclusively at small plants, which have no clout.  So yes, I agree that the agency gave up NO power or authority at small plants. 

    I still visit with a variety of FSIS personnel, across America.  Most are still agency employees, some are retired.  But with one voice they describe how FSIS ignores obvious, ongoing problems at the largest plants, while hagriding small plants.  Science based, you know.  If I owned a large plant, and the agency attempted meaningful enforcement actions, I’d have them in court before the ink dried on their NR or NOIE.  I’d rub their nose in their pre-HACCP promises, which the agency stated in public. 

    I attended official HACCP Training Sessions in Kansas City and Salt Lake City in 1996.  For several days, I rubbed elbows with plant owners and officials for many days.  We were all incredulous at the deal offered to us by FSIS, too good to be true.  Well, history has shown time and again that the agency’s promises were too good to be true.  FSIS wants to reassert its authority now, while still demanding that our industry live up to our part of the falsified bargain.

    John Munsell

  • jcmcentire

    Whether or not FSIS chooses to trace back to the source is a policy decision, and for the sake of public health, this clearly must be done. FDA has taken this approach for a long time- trying to link the dots identified by PulseNet. Policy decisions aside, the ability to accurately trace back to a degree that a root cause analysis can be done is not always the easiest thing, depending on the level of detail kept in the records by everyone in the supply chain. So even if FSIS decides to follow the path back, is the system-wide infrastructure in place in industry to allow them to do this expeditiously and accurately?

  • johnmunsell

    In all cases, no.  However, there have been many cases this century when more-than-adequate documentation is provided, but FSIS refuses to use the data.