This commentary was contributed jointly by John Munsell and Dr. Richard Raymond.

Last week, James H. Hodges, Executive Vice-President at the American Meat Institute (AMI), ostensibly penned an opinion piece for Food Safety News titled “Wrestling  With the Science of STEC”. You can read it here.  But in case you are not inclined to go back to the original article, let us enlighten you with some quotes from it and our thoughts.

Jim starts out with “When it comes to our nation’s Shiga toxin-producing Escherichia coli (STEC) policy, some people like to wrestle in the mud. I like to wrestle with the science.” Ouch.


Is he talking about previous OpEds that Food Safety News has published, or is he referring to Bill Marler and his petition for the USDA to declare non-O157 STECs to be adulterants in meat?


Or maybe he is accusing our Undersecretary for Food Safety at the U.S. Department of Agriculture, Elisabeth Hagen, a highly respected M.D. who has relied upon science to make informed decisions her entire professional life, of being a mud wrestler?

First of all, whenever meat industry representatives state that their policies and/or opposition to federal regulations are “based on science” we see more red flags than Khrushchev ever did.


And we are not alone. While we do not necessarily endorse every statement made by Marion Nestle, her book, “Safe Food: The Politics of Food Safety,” has some quotes that resonate with our thoughts:

Page 16: “This book explains how food companies use science as a political tool to oppose requirements to keep harmful microbes out of food.”


Page 22: “In this book, we will see how the failure of food companies, scientists and governmental agencies to recognize the need to address VALUES (emphasis added) as well as science in matters of food safety leads to widespread distrust of the food industry…”  

Mr. Hodges, we suggest that public health obtains, and the average consumer sees, intrinsic VALUE in not having poop in our meat.

Page 30: “We will see how food producers repeatedly deny responsibility for foodborne illness, invoke science to promote self-interest and divert public attention from harm caused by their products…” 


When AMI cannot defend its positions or policies, it simply tries to stifle debate or discussion by hiding behind its definition of “science,” while invoking that term to prematurely terminate any meaningful discussion.  Even the most constructive discussions of food safety rules, including microbial testing, are commonly attempted to be discredited by a default appeal to “science.”

It is our joint goal today to keep the discussion alive and ongoing regarding the testing for non-O157 STEC by FSIS. 

Mr. Hodges, in his piece invoking science, says that, despite the new knowledge that non-O157 STECs cause more illnesses per year than O157s, “most of those illnesses were actually sourced from foods other than beef.” Really, Mr. Hodges, do you have something based on science to defend this statement?


The Centers for Disease Control and Prevention, a highly respected science-based institution, is on record as saying that 80 percent of foodborne illnesses never have the source of the illnesses determined. And for non-O157 STECs that percentage is even higher, due to the simple science-based fact that these illnesses are tremendously underdiagnosed and underreported.


So seriously, Mr. Hodges, how can you say you know the majority of illnesses are “from foods other than beef” when the CDC itself cannot and will not make that statement? 


Nowhere in his submitted opinion piece does the AMI spokesperson acknowledge the outbreak of illnesses that sickened 100 and killed four in Japan, an outbreak caused by eating beef steak harboring one of the six STECs that FSIS has declared to be adulterants in ground beef.

Dr. Hagen has repeatedly said that she is all about prevention of foodborne illnesses, as opposed to reaction to illnesses. This is a laudable step to prevent illnesses and deaths like we saw in Japan.


And we feel we must remind Food Safety News readers that this is the same AMI that filed a lawsuit in 1994 to prevent FSIS from moving forward to take positive action to protect our health after Mike Taylor declared E. coli O157:H7 to be an adulterant in ground beef following the Jack in the Box outbreak.


We assume that lawsuit was based on their “science,” but can you imagine how many more children would have died between then and now from eating ground beef products if AMI had been successful and the industry had not rolled up their sleeves and attacked the problem with real science-based interventions?

By the way, in case you were wondering, yes, James H. Hodges was employed at AMI at the time the lawsuit was filed in 1994.


We can’t help ourselves. We must point out this quote Mr. Hodges offered up in support of his science-based approach to food safety: “As it is, the evidence suggests that contamination with these serotypes is prevented or eliminated by exactly the same interventions that are currently in place to prevent or eliminate O157 STEC contamination.”  The quote is from “Peer Reviewer 1, FSIS Draft Risk Profile:”

No name is even offered up for the quote, one of three in the opinion piece. But we would NEVER quote a source that says the current interventions in place “prevent or eliminate O157 STEC contamination.”  The interventions in place do reduce contamination, but they most certainly do not prevent or eliminate.


We are glad the industry has made such great strides in reducing our risk. But if the non-O157 STECs are actually “eliminated” by current interventions, then AMI members should have nothing to worry about from additional testing, right?


Semantics, yes, but if one wants to stand behind science as his shield, he had better be sure of his facts and state them clearly.


In conversations with directors of public health laboratories on the cutting edge, we hear that they are seeing at least as many positives for non-O157 STECs in specimen samples from humans suffering from foodborne infection as they are seeing for O157s. As more labs test, and as more cases are reported, we will find the move by FSIS to be truly prescient and an action that will have prevented illnesses and deaths without the need for a Jack in the Box or Japanese-like catalyst.

Jim says “we must remain valiant” in what we assume is a reference to AMI and its members. Valiant is described in the World Book Dictionary as: “having courage; brave; courageous.”

We think Undersecretary Hagen and FSIS Administrator Al Almanza are the ones who “must remain valiant” in the next few months.

Maybe the word he was searching for is “vigilant”?

In fairness to Mr. Hodges, we are assuming he did not actually write this opinion piece.  We do invite him to respond, to clarify its authorship.


John Munsell, who ran a USDA-inspected meat plant for 34 years, now oversees the Foundation for Accountability in Regulatory Enforcement, FARE. Dr. Richard Raymond is the former Undersecretary for Food Safety, U.S. Department of Agriculture (2005-2008) who now works as a food safety and public health consultant.