How Many Killer Bacteria Does it Take to Adulterate the Meat I Eat?

That question seems to have been put out there for public debate in quotes attributed to Betsy Booren of the American Meat Institute (AMI) Foundation in a recent USA Today story by Elizabeth Weise that can be read here.

The story was about E. coli O157:H7 being the only deadly strain of E. coli to be declared an adulterant and therefore illegal. It also raised the question of why other strains were OK, even if they could make you sick or even kill you, as we recently saw happen in Japan and Europe.

Naturally Ms. Weise, in an effort to write a fair story, interviewed Ms. Booren of AMI. I think the statements she got in that interview bear a closer look.  I also think that regardless of where the reader stands on the issue of non-O157 STECs that can cause human illnesses being declared adulterants in ground beef, one really has to question the science behind the following quotes from USA Today:

“The meat industry says it’s too early to declare the various dangerous E. coli subtypes as adulterants.

‘We don’t have a true baseline determining the prevalence of these organisms in the beef supply,’ says Betsy Booren of the American Meat Institute (AMI) Foundation, the research arm of AMI. Without knowing how common they are, it’s impossible to say whether they should be considered adulterants, she says.

AMI believes that testing for E. coli O157:H7 in many ways takes the place of testing for a broader range of E. coli variants, because if you get a positive for E. coli O157:H7, you know there’s been fecal contamination and so other variants might be there as well.” 


Three small paragraphs, four very debatable and very puzzling statements. This type of PR work in the media really does not help the public image of the meat trade association that represents the majority of our largest meat packers and processors.

“Too early to declare” non-O157 STECs adulterants? Think Japan and Europe and this statement wilts away. What are we waiting for, the re-incarnation of the “Western States Outbreak” as CDC refers to the 1993 Jack in the Box event? 


“We don’t have a true baseline”? EIH laboratories have one, the USDA Meat Animal Research Center in Clay Center, NE, has one, and Texas Tech now has one. USDA/FSIS announced that they were going to test meat for non-O157 STECs in May, 2008, so they have a baseline. Maybe Ms. Booren meant the AMI Foundation has not done their testing yet?

Whose baseline to use may be debatable, but the next two statements really bother me when spoken by an AMI spokesperson supposedly representing the thinking of the meat industry.

“It’s impossible to say whether they should be adulterants, she says” unless we know how much meat is contaminated with them. What difference does it make if 2% or 20% of chubs are contaminated with non-O157 STECS? Do we really need another 700 people sickened and 4 killed to say we guess there is enough contamination to declare them to be adulterants? 

Any amount of bacteria that can kill you is enough to say that meat is adulterated and must not go to retail as fresh, raw ground product. 

The definition of adulteration can be found at 21 USC & 601 which clearly states:

“(m) The term “adulterated” shall apply to any carcass, part thereof, meat or meat food product under one or more of the following circumstances:

(l) if it bears or contains any poisonous or deleterious substance which may render it injurious to health”

No mention of how many pathogens must be in a pound of ground beef, just if it is enough to make it injurious to my health. No mention of the need for a base line to determine prevalence rates for a poisonous substance, just the need to determine if it could be injurious to my health.


Does anyone else consider it strange that most of the recalls we are seeing are for undeclared allergens? I know it is important for persons with food allergies to know what they are eating, but how many illnesses are found to be due to allergens compared to non-O157 STECs?


But back to the USA Today story and the fourth statement attributed to Betsy Booren that really made me question her science background, or at least her Association’s promise to always put the public’s health first. The news story states that AMI believes you don’t need to test for non-O157 STECs because testing for O157:H7 is sufficient.

I agree with the logical statement attributed to Betsy that if meat is positive for O157 you know you have fecal contamination, and we all know that is not a good thing to have.


But having a negative for O157 cannot even assure you that your meat does not contain E. coli O157:H7, much less some other pathogens found in feces of cattle. WE ALL KNOW THAT. Well, maybe all except Ms. Booren.

We try and hammer home the message to consumers to handle and cook their meat according to recommendations because raw meat should never be considered sterile, no matter how much testing has been done.  AMI has said publicly many times that we cannot test our way to 100% safe ground beef.

Yet it is implied by the spokesperson for AMI that if the meat has tested negative for O157 we do not need to worry about contamination with non-O157 STECs. I thought this must be a typo, but have been reassured this is what AMI’s position is.

AMI, just because a cow did not have O157 in his or her gut does not mean the animal was not inhabited with E. coli O111, or O145, or maybe even O104. AMI, just because testing of the ground beef sample did not detect O157 does not mean there are not other fecal pathogens present.

This is really pretty simple stuff I am talking about here. If we don’t test, we won’t find lethal bacteria. And we won’t have to divert the contaminated and adulterated product to cooking, helping maintain its economic value.

But if we take Ms. Booren’s position about E. coli being a sentinel for fecal contamination and no other tests are needed, then why do we do both Salmonella and O157 testing in beef, and why are we establishing standards for both Campylobacter and Salmonella in poultry?


There might be one small positive from the story. Maybe FSIS can survive the projected food safety budget cuts by discontinuing the current policy of unnecessary and duplicative testing (as implied by Ms. Booren) for different fecal pathogens.