On February 2, I wrote a commentary that appeared on Food Safety News entitled “USDA Inspected and Approved High-Risk Meat.” 

One sentence in the editorial stated “USDA has concluded that Hannaford’s high risk practices likely led to this outbreak,” a reference to Salmonella infections linked to supermarket ground beef. Investigators were unable to trace the contaminated ground beef to any one supplier.

USDA officials subsequently contacted me, claiming that the agency did not say Hannaford’s practices led to the outbreak, and requested I issue a correction. What the agency stated was that Hannaford’s “high-risk practices” for grinding beef, including a lack of grinding logs, were a barrier in its investigation of the outbreak.  


I am writing this today not only as a correction, but also to describe how USDA-approved meat laced with E.coli and Salmonella automatically create “high-risk practices” at retail meat markets, hospital cafeteria and meat establishments that purchase boxed beef from source slaughter plants.  Americans need to know how “high-risk” meat is getting into our food chain.

Following the 1993 Jack In The Box outbreak, USDA required the meat industry to implement HACCP (Hazard Analysis Critical Control Point) systems. The agency’s previous meat inspection system had been organoleptic, i.e., dependent upon the senses such as smell, sight and touch.  Bacteria such as E.coli O157:H7 and Salmonella cannot be detected via organoleptic methods. USDA claimed that HACCP was built upon science-based inspection and meat production, not in organoleptic senses. The “science-based” foundation of USDA-style HACCP was microbial testing of meat, which can indeed detect the presence of invisible pathogens.

All meat plants were then required to devise their own customized HACCP plans, plus associated practices which would result in the production of consistently safe meat and poultry. Each year, the largest slaughter plants issue annual certifications and letters of guarantee, in which they describe the variety of policies and procedures utilized to produce safe food. Most, if not all, large plants now have these certifications and letters of guarantee available on their websites enabling customers to print copies. The information below comes directly from a variety of these websites.

The largest slaughter plants are highly efficient assembly and disassembly lines, deftly slaughtering and processing up to 6,000 beef daily. To their credit, they have invested millions (some claim BILLIONS) to develop and implement a plethora of scientific interventions which have clearly made our food safer. It is estimated that such scientific advancements add 6 – 8 cents per lb to the cost of beef.


The list of laudable interventions and policies is lengthy and exhaustive, including but not limited to:

– Prerequisite programs

– Pre-Operational sanitation programs

– Operational sanitation programs

– Hide-on carcass washes

– Critical Control Points (CCPs), which are points in the process where controls can be used to prevent, eliminate or reduce pathogens to an undetectable level

– Steam vacuuming beef carcasses on the kill floor

– Pre-evisceration and post-evisceration sprays, water and/or lactic acid sprays

– Thermal pasteurization systems: hot water or steam

– Standard operating procedures (SOPs)

– Standard sanitation operating procedures (SSOPs)

– Good manufacturing practices (GMPs)

– Pest control management

– Humane handling protocols

– Allergen control programs

– Testing of carcasses for E.coli, primary generic E.coli

– Salmonella testing programs

– Listeria testing programs

– Test and hold protocols

– Organic acid sprays of carcasses in the cooler

– Product recall programs

– Certificates of Analysis (COAs)

And many, many more.

In recent years, the largest slaughter plants have implemented an additional step with which I am greatly impressed.  When beef carcasses are broken down into component parts such as rounds, loins, ribs, etc, each individual piece of intact meat is placed into a vacuum packaged bag, and then boxed for shipment.  Immediately prior to placement into the vacuum bag, each piece of intact meat is exposed to an antimicrobial spray which further controls pathogens. These intact pieces of meat are, in my opinion, super sanitary, having been exposed to yet one more antimicrobial intervention. Consumers can eat this meat with a high degree of confidence in its safety.


I am quite impressed with a statement found in one slaughter company’s certification:  “We apply lactic acid to carcasses just prior to Fabrication, peroxyacetic acid to conveyor belts in our Fabrication process, and peroxycacetic acid to primal and sub-primals prior to packaging and to trim on the conveyor belt prior to placing into boxes or bins.” This company leaves no stone unturned in its commitment to safe food.

A statement from another slaughter plant: “Primal and sub-primal [intact] products are subject to an antimicrobial spray after trimming but prior to or at bagging. The antimicrobial treatment has been tested in our establishments and has shown to be effective in the reduction of bacteria and is monitored as per our application program.”

These plants are a credit to our industry.

Interestingly, the source slaughter plants test ground beef and boneless trimmings for the presence of pathogens, but do not test intact beef cuts. If pathogens were detected on intact cuts, the slaughter plant (and perhaps USDA) would know that its highly heralded HACCP systems had failed.

What is the true frequency of pathogens in intact beef cuts?  At a meat industry conference in Chicago on Sept. 17, 2008, then-USDA Under Secretary for meat inspection Dr. Richard Raymond revealed results of a recent agency experiment.  Dr. Raymond stated that the agency had tested 24 pieces of intact beef cuts for the presence of E.coli O157:H7.  Of the 24 intact cuts, 8 had E. coli O157:H7 on them, and six of the eight were loin cuts. Even if this test was an anomaly, USDA officials are painfully aware of the true incidence of pathogens on intact beef cuts.  So, how does USDA respond to this threat to public health?  The agency gives a Pass Card to the source slaughter plants, blithely allowing the plants to ship into commerce intact cuts which are surface-contaminated with E. coli O157:H7, as well as Salmonella, much to the chagrin of Hannaford and its customers.

An article in the Portland Press Herald quotes Daniel Engeljohn, assistant administrator of USDA’s Food Safety and Inspection Service:

“Engeljohn noted that there is a lower sanitary standard for the cuts of meat that are used for trimmings than there is for the ground beef that comes in tubes.”

I respectfully disagree. The “cuts of meat” to which Engeljohn refers are the intact cuts described above.  These cuts were exposed not only to the plethora of kill-floor interventions listed above, but also to the antimicrobial spray prior to their being packaged, as described above. If consumers can’t trust the safety of beef after that phalanx of scientific interventions, we’d better not trust beef at all. Part of Engeljohn’s concerns has to do with testing, which will be discussed below.

Several slaughter plants include disclaimers which state that no technology exists that can guarantee fresh meat products are free of pathogens, and that no one is able to guarantee pathogen free raw materials. These statements are absol
utely true:  raw meat, which has not been exposed to a kill step such as irradiation or full cooking, cannot be guaranteed to be pathogen free.

Slaughter plants take one additional step to protect themselves from liability for foodborne outbreaks emanating from consumption of their products. In spite of the fact their intact primal cuts have been exposed to the arduous gauntlet of antimicrobial interventions previously described in this report, some packers claim that their intact beef cuts are “NOT INTENDED FOR GRINDING.”

Slaughter plants thus admit that an inordinate percentage of their intact cuts are laced with deadly pathogens. So much for the efficacy of their “science based” interventions. Packers use this clever machination to insulate themselves from bacterial liability, even though in all likelihood the bacteria entered the food chain on their kill floor.


USDA does NOT object to such disclaimers. Unfortunately, USDA itself admits that the official USDA Mark of Inspection is meaningless. Agency publications have stated:

“Grinders with prerequisite programs should not rely on the mark of inspection (emphasis added) to accept incoming product.”


“An establishment that receives, grinds, or otherwise processes raw beef products cannot conclude that E. coli O157:H7 is not reasonably likely to occur in its production process because the product it receives bears the mark of inspection” (emphasis added).

When USDA itself admits that the Mark of Inspection is valueless, coupled with slaughter plants stating that their meat is “NOT INTENDED FOR GRINDING,” consumers should be fully forewarned that all raw meat carries a high risk of pathogen contamination. All liability for foodborne sicknesses has now been cleverly shifted onto consumers.

USDA has declared E. coli O157:H7 to be an “adulterant,” prohibiting the shipment of adulterant-contaminated meat into commerce. USDA recently proposed adding six more subtypes of E. coli to the list of adulterants. More specifically, USDA states that E. coli O157:H7 is an adulterant in ground beef and in boneless trimmings. Herein lies the rub however:  when E. coli O157:H7 is found on the exterior of intact cuts, USDA classifies the pathogen as a mere contaminant, certainly not a lethal adulterant. Therefore, slaughter plants can ship into commerce intact cuts of meat which are surface-contaminated with E. coli O157:H7, with full agency endorsement.


Subsequently, when downstream restaurants, hospital cafeterias and further processing plants open these intact cuts and process them into steaks, roasts and ground beef, only then do these heretofore feckless contaminants mysteriously morph into lethal adulterants!

Processing these intact cuts produce boneless trimmings, which have always been made into ground beef. Grinding trim emanating from these intact cuts is precisely what USDA refers to as “high-risk practices.”  Why?  USDA officials have stated many times that grinding such trim is high risk because the trimmings have not been tested, nor treated with antimicrobials.  We need to closely scrutinize this agency statement.

First of all, this agency statement contradicts an industry mantra of the last eight years which is that “We can’t test our way to safe food,” an erudite statement. Testing alone does not produce safe food. Testing does not remove pathogens from meat, nor does testing apply antimicrobial interventions against raw meat.  Testing is but an indicator of pathogen presence, a brief window in time which reveals the presence of absence of pathogens in a small, limited amount of meat.

USDA’s statement lulls consumers into thinking that we can build safety into meat via testing. Pillsbury’s original HACCP protocol built safety into meat at each step of the processing line. Testing does not build safety into food.

USDA’s contention that processing intact cuts and grinding the associated trimmings as being a “high risk practice” exposes the biased underpinnings of USDA-style HACCP. We must remember that intact cuts originated from those same beef carcasses which were exposed to the wide array of science-based interventions on the kill floor, in the cooler, and in the fabrication room. While still on the original carcass, these intact cuts were exposed to steam pasteurization, lactic acid sprays, hot water rinses, trimming, and all those interventions previously listed.

To top it off, in addition to all these kill-floor interventions, the packers now apply an antimicrobial spray to the intact cuts just before the cuts are vacuum packaged.  After packaging, if the intact cuts are still laced with adulterants, major insanitary conditions persist at the meat plant. USDA disagrees.

Instead, USDA and many in the meat industry continue to pass downstream all pathogen liability to the end users:  retail meat markets (such as Hannaford), restaurants, hospital cafeterias, and individual households. The end users are reminded to use proper food handling and cooking protocol, including prevention of cross contamination.  An article written by Leslie Bridgers at the Portland Press Herald regarding the Hannaford recall included the following quote from USDA’s Daniel Engeljohn:

“[USDA] Investigators found that Hannaford would grind trimmings and tube meat without cleaning the equipment in between, he said, raising the possibility of cross contamination.” 


Since when has USDA developed a commitment to the prevention of cross contamination?  The fact that the agency allows slaughter plants to ship into commerce intact cuts of meat surface-contaminated with E. coli O157:H7 virtually guarantees that entities which process those intact cuts will cross contaminate their facilities. Intact cuts are touched by gloves, aprons, knives, tables, saws, wrapping equipment, etc. Perhaps USDA perceives that everyone handling intact cuts should replace their gloves and aprons between each intact cut of meat, should wash and sanitize their cutting boards, table tops, saws and all related equipment between each intact cut?

Large retail meat markets like Costco and further processing plants will process dozens if not hundreds of boxes (each containing several pieces) of intact cuts on a daily basis. The probability of cross-contamination is daunting.  And the very idea of cleaning and sanitizing all equipment countless times daily, as well as replacing gloves and aprons, is simply not viable.


Commingling trimmings with other grindable meat such as “tube meat” does NOT introduce pathogens into the finished product. In all likelihood, pathogens arrived on the exterior of intact cuts in boxes proudly bearing the official USDA Mark of Inspection, which states “USDA Inspected and Passed.” This means that USDA knowingly allows E. coli residing on intact cuts to be emblazoned with the agency’s Mark of Inspection. Thus, we now have USDA Inspected and Passed Salmonella and E. coli. When E. coli-laced intact cuts are further processed, those same pathogens are deposited onto steaks, roasts and into ground beef.  The commingling of trimmings from multiple sources does NOT introduce E. coli, but spreads it. Don’t ask USDA to acknowledge this.


USDA’s Recall Press Release of the Hannaford recall on Dec,15, 2011 included these statements:

“Based on an examination of Hannaford’s limited records, FSIS was unable to determine responsible suppliers.”

“FSIS has not yet been able to identify FSIS-regulated suppliers of raw beef ground at Hannaford Stores related to the outbreak that could be subject to recall action.” 

USDA is thus critical of the lack of grinding logs at Hannaford stores
. While the existence of copious logs would have greatly aided in the determination of noncompliant source slaughter plants, we must remember that the lack of grinding logs did NOT contribute to the outbreak!  Grinding logs, or the absence thereof, have no connection to the introduction of bacteria into meat.  An establishment may have superlative grinding logs, and will still produce unsafe meat. Garbage in, Garbage out.


However, how can USDA be critical of Hannaford’s lack of evidence showing the sources of meat being ground?  For many years, the agency itself has steadfastly refused to authorize its own inspectors to document all source evidence at the time of sample collection!

Example:  at a Senate Field Hearing on Dec. 11, 2002, I suggested that when an agency inspector collects a sample of ground beef for E.coli O157:H7 analysis at a USDA Lab, that both the inspector and a plant official should immediately document the source(s) of the meat being ground.  Representing USDA at the hearing was William Smith, then-Deputy Administrator of the Office of Field Operations. He now heads up the agency’s OPEER department.  Smith made these two responses to my suggestion for evidence documentation:

“….we could have inspectors doing more important things”

“….a number of packers would also be very upset about us collecting information on negative [adverse] findings.”

On behalf of USDA, Smith admitted not only that the agency doesn’t want the inspectors documenting evidence in real time, but also that the source slaughter plants would be “very upset” if the agency were ever audacious enough to empower inspectors to document evidence with no restrictions.

In subsequent years, I’ve continually pressured the agency to document all source evidence in real time, only to be continually rebuffed.  Finally, on Oct. 8, 2010, USDA issued Notice 58-10, which authorized inspectors to collect all source evidence at the time of sample collection. How many years has USDA been inspecting meat, and not followed commonly accepted scientific sampling criteria which require documenting all evidence?  Copious documentation of unrestricted evidence should have been part and parcel of USDA’s meat inspection program since Day One, but has not. Yet, the agency criticizes Hannaford for its lack of grinding logs.

USDA collects routine samples of ground beef for laboratory analysis for E. coli O157:H7, referred to as “verification sampling.” From Jan. 1, 2009 to Nov. 30, 2010, the agency’s routine verification sampling revealed 64 samples that were positive for E. coli O157:H7.  Of these 64, 29 were collected at plants which purchased all their meat from but one slaughter provider. In all 29 cases, USDA refused to do a traceback to the one well-identified source. The agency deliberately refused to go to the source plant and require corrective actions to prevent recurrences. USDA adroitly avoided any enforcement actions at the source plant, in spite of these 29 golden opportunities to protect public health. 


Eventually, USDA mismanagement of public health issues caught up to them. On Aug. 3, 2011, USDA Secretary Tom Vilsack gave a speech in Milwaukee, in which he addressed this issue. He stated:

“In 90 days, I expect the agency to announce the first step in transforming our traceback policy…”

The FIRST STEP?  You mean to say that after several decades of being in the meat inspection business, that USDA finally decided to embrace traceback protocol in 2011?  Yes.  Well, what happened at the end of 90 days? No official USDA press releases. But on Dec. 29, 2011, a full 148 days later, USDA sent its traceback suggestions to OMB for approval.

Part of the USDA submission was requesting OMB permission to conduct tracebacks when verification sampling revealed the presence of E. coli O157:H7. This awkward revelation shows that USDA perceives it doesn’t have the authority to do tracebacks to the source, even when the source has already been clearly identified to be one individual slaughter plant!  Yet USDA claims to act with an “abundance of caution” when protecting consumers from foodborne outbreaks.


It is true that USDA referred to “high-risk practices” at Hannaford, but did not state that such practices likely led to the Salmonella outbreak. I am pleased to make this correction. It is only appropriate now that USDA officials publicly state if they believe that Hannaford’s practices had ANY connection whatsoever to the introduction of Salmonella into the meat chain. Don’t hold your breath. USDA is much more comfortable criticizing Hannaford’s allegedly high-risk practices and lack of grinding logs than in admitting that the lack of grinding logs and grinding practices did NOT introduce Salmonella into the meat chain.  Hannaford, and its customers, were innocent victims of purchasing and consuming meat which was already laced with Salmonella when the meat arrived at Hannaford receiving departments.

The real issue here is USDA’s ultra-risky policy of allowing slaughter plants to ship intact meat into commerce which is laced with Salmonella and E. coli O157:H7, and subsequently refusing to do tracebacks to the source.

Comparatively speaking, USDA’s PR image would have more benefitted by stating that Hannaford’s practices likely led to the Salmonella outbreak, than to publicly refer to “high risk” practices.  An in-depth discussion of “high risk” provides us the opportunity to reveal that USDA’s policies at the source originating slaughter plants constitute the ultimate cause of high risk meat.