In a recent article about the U.S. Department of Agriculture’s Food Safety and Inspection Service’s (FSIS) subtle move toward more effective and efficient traceback efforts, Scott Goltry, the American Meat Institute’s (AMI) vice president for food safety and inspection services, was quoted as saying:

AMI “believes that it is a misuse of FSIS resources to subject ground beef that has been subjected to FSIS testing at the original production site to be retested by FSIS again, if no other ingredients are added to the ground beef.”

The story was about a simple move by FSIS to collect the names of suppliers at the time bench trim or ground beef was sampled at processing plants. Recent policy was that this information would be gathered only after a sample tested positive, or after an illness was linked to product. But this step appears simple only if you do not know the history.


A similar instruction was issued in 2002, only to be rescinded about three months later for “legal reasons.” I assume “legal reasons” means threatened lawsuits? Some who have been observing FSIS for many years tell me that when HACCP was being debated and discussed back in the 1990s, the issue of tracebacks was one of the major lobbying points. Some felt tracing back to the source just might put packers in a position of “double jeopardy.” I have tried, in vain, to determine if promises were made way back then about tracebacks.

Improvement on traceback efforts by the Food and Drug Administration are being mandated by the Food Safety Modernization Act and improving traceback efforts by FSIS are the subject of bills recently introduced by Senator Tester and Congresswoman DeLauro.

Let me try to explain the public health implications of not tracing back to the source. Left over products from the process of cutting beef into steaks and roasts are called trim. Trim is collected in boxes called combo bins, each usually weighing 2,000 pounds when full. Some trim is tested at the packing establishment for E coli O157:H7, but not all. Trim is often sold to further processors to be used in the production of ground beef and other products, as is boxed beef and other whole cuts, where FSIS may pull another sample of the finished product, ground beef, to test for E coli.

A combo bin may be divided into several components and sold to several processors for grinding. A positive sample at one of these grinders would result in a recall of only that plant’s product if that product had entered commerce, or cooking or destruction if the product was held at the plant. But no action would be taken regarding the other processors’ products made from the same contaminated combo bin products unless an outbreak was involved.


The explanation I received for this flawed policy when serving as the USDA’s Undersecretary for Food Safety was that most ground beef consisted of comingling of product from various sources, and that fact would most often prevent effective traceback.

But I have now learned that in 2010 there were 64 FSIS ground beef samples that tested positive at further processing plants. And of those 64 samples, 29 were from a single source with no comingling of product. None of the 29 positives came from an establishment that did any slaughter, so therefore the contamination had to occur elsewhere. And most, if not all, were very small plants, so they likely would not purchase an entire combo bin of product.


Or maybe they produced their own bench trim from boxed beef. But if that is the case, where did the rest of that contaminated carcass get sent for further processing? And who ate it?

Mr. Goltry says it is a “misuse of FSIS resources” to test product that already tested negative. I say it could help remove contaminated, maybe deadly, product from commerce, thus protecting the public’s health. I believe the statistics revealed in the recently disclosed FSIS data support my thoughts.

I know we can’t test our way to absolute safety in raw meat and poultry, and I support those who say we can’t. That is not my point today.

And I appreciate the millions of dollars industry spends on interventions and testing to protect my health because I love a good hamburger. But let’s look at this issue of retesting from a slightly different angle, going back to my roots as a physician.

Let’s consider that I go in for a physical, and have an electrocardiogram done that is interpreted as negative. A couple of days later I develop crushing chest pain while shoveling snow in 10-below-zero weather. I will not appreciate an American Medical Association or health insurance industry spokesperson saying it would be a “misuse of … resources” to retest again since a previous test was negative.

Decisions are often made using the information at hand. When that information changes, the decisions previously made need to be revisited. When I get chest pain, the normal-appearing EKG needs to be revisited. When a sample tests positive, the decision that was made to place the USDA Mark on the product and place it in commerce needs to be revisited.

I know Scott Goltry. I respect him and I know he does not want contaminated, adulterated product in commerce. I think the AMI that he works for needs to be just a little more open-minded on this issue, and remind themselves of their often-repeated statement that food safety is a non-competitive issue when it comes to protecting the public’s health.

If FSIS does not change its policy of no traceback for a positive ground beef sample, eventually we will have an outbreak that may involve a child’s death from ground beef that was produced at a second establishment that also purchased product from the same combo bin that caused a positive sample at the first grinder. This will be an embarrassment and disaster for FSIS, AMI and the establishments involved, not to mention the victims.

These new numbers have opened a lot of eyes, and we are seeing early action taken toward more effective and efficient traceback to protect the public’s health. The industry can cooperate or they can keep putting out statements that make them appear to be non-caring suits.