The USDA news release dated April 5, 2011, and reported in Food Safety News April 6 by Helena Bottemiller, had this for a headline:


              USDA Announces Proposed Test and Hold Requirement

                              for Meat and Poultry Products

          Will enhance existing procedures, help reduce foodborne illnesses

There has been a lot of press and follow up discussions since that press conference about the need or lack thereof for this new requirement. Much emphasis has also been placed on the possible effect it will have on the very small processors who grind for local customers based on their order for the day. 

In Ms. Bottemiller’s story I was quoted as saying the requirement might be “onerous” for some of the smallest grinders. Doc Mudd tried to take me to task in the discussion following the story, but I will point out right now I did not say whether the required test and hold policy was a good one or not, simply that it might put some very small grinders out of business.


All the numbers you need for a discussion are right here in the Federal Register. These numbers need to come to light for further discussion about the accuracy of the headline that says this “will … help reduce foodborne illness.”


This discussion is especially important if one reads the transcript from the press conference where this proposed new policy was announced. During the Q and A, Secretary Vilsack is quoted as saying “our best estimate is this is going to help prevent 25,000 illnesses.” You can see this for yourself and not have to take my word for it.


If only that were true. If only 25,000 illnesses could be prevented then I might have embraced the AMI petition when they sent it to me as the Undersecretary for Food Safety in June of 2008. If it were true, I would not be worried about one or two very small grinders having to close if they cannot comply with the new test and hold proposal.

But it is not true. A three-year time frame, 2007-2009, was used by the USDA for their statement that 44 recalls happened because product was tested and shipped into commerce before a positive result came back. Of those recalls, 22 were for ground beef with an E coli O157:H7 positive, and 22 were for ready-to-eat products with positives for L. monocytogenes.

Of those 44 recalls, 43 had this statement in the recall notice: “no reports of illnesses associated with consumption of this product.” One recall did have two illnesses associated with it. So the headline that this action will “help reduce foodborne illnesses” is technically correct. But 25,000?

The proposed regulations in the Federal Register, written by FSIS staff, include this statement: “The FSIS model estimated the upper 95% confidence bound of averted E. coli O157:H7 illnesses to be approximately 2.6 for a three year period.”

It goes on to state that the estimated number of L. monocytogenes illnesses that would be averted over the same three year period of time would be 0.18.


These numbers are a long way from the 25,000 stated by the Secretary. That number impressed many in the media and they touted this as a great public health move in the right direction.

Furthermore, FSIS estimates the fiscal savings by avoiding these illnesses would be $7,464 annually, and I seriously question whether that minimal savings warrants the risk of losing some small grinders in rural America. I even question whether an annual savings of 7K warrants the amount of time, energy and money that went into writing the proposed regs in the Federal Register.


And I definitely question whether reducing foodborne illnesses by one case per year, when the CDC estimates there are 63,000 foodborne illnesses per year, warrants a press conference and the media hype.

I think the consensus of the responses I have been seeing echoes these thoughts. Test and hold is a good thing, and the great majority of the grinders already do it. The impact is not going to be a significant reduction of illness, but rather a reduction of negative messages being sent to consumers every time there is a recall. These messages remind them that raw ground beef cannot be considered pathogen free.

The AMI petitioned the Undersecretary back in 2008 because they wanted to improve public relations and all of their members already practiced test and hold, and had been doing so for years. I think another motive for the petition might have been that every time a small grinder needed to do a recall, people like John Munsell were quick to point out that the contamination probably did not occur at the very small grinder, but at the large packing house that they bought ground beef components from.


And the industry as a whole did not embrace mandatory test and hold at that time; the Federal Register points that out very clearly. To say it does now is another inaccuracy.

Looking for total transparency, here are a few more numbers that come from the USDA and FSIS web pages and might shed more light on the true impact of this action.

The total pounds of ground beef recalled as a result of FSIS testing in 2009 were 52,667. Ground beef produced and consumed in the United States, as estimated by the USDA, in 2009 was over 20 billion pounds. The recalled ground beef amounted to 0.00026% of the total produced in 2009.

Total samples tested for ground beef in 2009 amounted to 11,686, of which only 41 were positive, or 0.35% of samples. Of these, 33 were held and then destroyed or cooked and eight, as stated earlier, were out in commerce.

Remember, that is eight lots out of 11,686 lots that we are talking about here.

Lastly, these very small grinders are only subjected to testing for E coli O157:H7 approximately once every three months. That means they can grind and sell product that is not tested every other day of the quarter. How much of that product would test positive?

I don’t know, but I know test and hold is not going to make the ground beef I buy at the local store significantly safer.   

  • Doc Mudd

    Fine, Doc R., that you’re quibbling over the numbers, but please go ahead and complete for us the business case for your “very small grinders [who will be put] out of business”. What are the financial realities that cannot be overcome by these entrepreneurs and their tres chic clientel, so much so that industry advancement must lag or be halted by them?
    Politics and finger-pointing aside, if official FSIS surveillance testing must result in costly industry recalls and untallied impact upon consumer confidence in order to accomodate every Tom, Dick and Shirley, then ordinary consumers should recognize how they are benefitted. In the end, it’s all about marketing and customers, their confidence, satisfaction and safety.
    I think you make this issue too much about the convenience and profit of stray capitalists who are expert at making an embarassing fuss, and too little about intelligent food systems. Just my opinion – nothin’ personal.
    This little issue shouldn’t be personally or politically contentious. One strength of democracy – we replace political admininstrations from time to time to ferret out stodgy bureaucracy and favoritism. One reality of capitalism – sometimes we need to cut loose some capitalists who can no longer function within evolving industries. In each case, that usually brings a flurry of blaming and lame excuses, but those eventually burn themselves out as we move forward. That’s progress and it’s not perfect.

  • doc raymond

    I suggest you click on the link to the FR. It outlines the costs quite well. Or call up Jay at AAMP as he can also clarify the costs much better than I. But that is not the issue as I tried to clarify in today’s article. It is the simple fact that the USDA spent thousands to write the proposal, then put on a dog and pony show press conference to announce that they were taking steps that would prevent ONE foodborne illness per year, yet hyped it as saving 25,000. Someone needs to answer for this PR fiasco and misrepresentation of the facts.

  • minkpuppy

    Doc Mudd,
    As an inspector that works in these small plants, I’ll stand behind Dr. Raymond any day of the week because I see what goes on first hand. The likelihood that FSIS’s infrequent testing of these facilities will catch contamination is minimal. Test and hold is exactly as Dr. Raymond stated–an attempt to make FSIS look better by having fewer embarrassing recalls when actually very few illnesses are prevented and in most cases, there’s no actual illnesses associated with the recall and may never be. This whole thing is hyped for the consumer groups to make them happy and make it look like we (FSIS) are being tough on industry while the big plants run crap through their plants everyday that has to be treated with various chemicals like ammonia to make their product safe. No, Thank you.
    However, you seem to be stuck in your world where small producers must be in it to make a buck by overcharging ignorant foodies and that everything they do and say is profit driven. What you fail to understand is that these small plants are not making product for “tres-chic clientele” as you so eloquently put it. It’s quite easy for someone who doesn’t work in the meat industry and never has to stand in judgement over it.
    This issue isn’t about profits–it’s about whether or not test-and-hold will make any difference at all regarding food safety. It won’t. It’s just another knee-jerk reaction to the bad press the Agency deals with daily.

  • Doc Mudd

    Well, I propose we agree to disagree on this tedious point and cheerfully move on to more important issues.
    Kinda distracted for us to be quibbling over minor protocol when there are hateful activist organizations a-plenty drooling to put us out of the meat biz altogether. You know, “meatless monday” and all that insidious dryrot. I am in no hurry to have us divided, conquered and eventually reduced to stoop labor in some charade of medieval subsistence arugula farming.