Most of us don’t get too many opportunities to lead change in our organizations and businesses. We might be in a position to try, but creating change is very difficult.

One of the best reads on the subject, and a book I quote and refer to often, is John P. Kotter’s 1996 edition titled “Leading Change.”

Kotter lists eight necessities to “drive people out of their comfort zones.” He says the first necessity to create change, and without it he suggests you don’t even try, is that you must have or “create a sense of urgency.”


When the discussions of what to do about non-O157 STECs (Shiga-toxin producing E. coli) first began, there was no sense of urgency. In fact, we believed they were relatively uncommon and not nearly as virulent as the banned E coli O157:H7.

So we planned and held conferences to discuss the pathogens, and we began testing meat to get a better idea of the frequency. We began developing better tests for industry and regulators to rely on, and more public health laboratories began including tests for non-O157 STECs on specimens from persons thought to be suffering from a foodborne illness.


As the testing became better, and more frequent, we began to realize these pathogens were in our meat and were causing foodborne illnesses much more frequently than once thought. Carol Tucker-Foreman and I penned an OpEd piece for Food Safety News to bring everyone up to date (we thought) on these emerging pathogens. 

But still no “sense of urgency” existed. The U.S. Department of Agriculture’s Food Safety and Inspection Service (FSIS) sent a proposal to the President’s Office of Management and Budget (OMB)in January of 2011 on what to do about the Big Six non-O157 STECs, the Big Six at that time being the most prevalent of non-O157 STECs causing illnesses in the U.S.

I don’t know exactly what is in the proposal, but no one has denied that it will be to conduct rule making to declare the Big Six as adulterants, as defined by the Federal Meat Inspection Act. Rule making takes two years at the very least to become enforceable. Much longer if there is industry opposition or trade implications.

But FSIS has alternatives to the formal, transparent and drawn out rule making process.

In 1993 the Jack in the Box outbreak sickened hundreds and left four children dead from eating ground beef containing E. coli O157:H7. At the time, this was one of the largest outbreaks from E. coli ever. It created a “sense of urgency”.

Soon thereafter, in 1994, Mike Taylor, then Acting Undersecretary for Food Safety at the USDA, using the power of his office and the Federal Meat Inspection Act, declared E. coli O157:H7 to be an adulterant in ground beef. Creating this change to make our food safer took months, not years.

In December of 2003, when the Washington state cow was found to have “Mad Cow Disease”, FSIS wrote Interim Rules in weeks that defined how we would assure our international trade partners and our domestic consumers of beef that they were safe. Years later the official, open and transparent rule making process made these amended interim rules final rules.

 The industry had a “sense of urgency” even if the actual human health risk was extremely small.

Anyone not living on a deserted island knows Europe now has a “sense of urgency” regarding non-O157:H7 STECs, specifically O104:H4, and so did Japan with O111 a few weeks ago. In Germany we have been told there are thousands ill, hundreds with hemolytic uremic syndrome and dozens dead. Jack in the Box pales in comparison to what we are seeing right now.


But for some in the U.S., there still is no “sense of urgency.” The Centers for Disease Control, the Food and Drug Administration (FDA) and the U.S. Department of Agriculture held a joint teleconference last Friday to discuss the situation in Europe with reporters and other selected individuals.

On that call, Don Kraemer, Deputy Director of the FDA’s Center for Food Safety and Applied Nutrition, said that they won’t be moving any faster to write new rules under the Food Safety Modernization Act because they were already working as fast as they could. A USDA spokesperson echoed that sentiment, saying it was a complex issue with lots of viewpoints to be considered.

If that outbreak had occurred In the States, I have no doubt both organizations would be working much harder and faster. You can always work faster, it is just a matter of “urgency” and prioritization.


Congressman Waxman and others are now asking for a Congressional hearing on the subject of the outbreak in Europe, and what we are going to do to protect Americans from a similar disaster. The last thing we need is for our high ranking food safety officials to have to take the time to prepare for a hearing, and then have Congress write food safety laws regarding non-O157 STECs.

Instead, these same food safety officials should seize the moment and do something right now to ensure the safety of our food supply.  They have been handed a “sense of urgency” at someone else’s expense. I hope they do not waste this rare opportunity to create change that has been handed to them.