When Michael Taylor declared Escherichia coli O157:H7 an adulterant in ground beef, there were howls of, “Just cook it,” from the industry and from within FSIS. For example, two members of FSIS’ Microbiology Division were adamant in their declaration that cooking was sufficient and quoted from the 1975 American Public Health Association, et al., Appellants, v. Earl Butz, Secretary of Department of Agriculture, et al., “ . . . American housewives and cooks normally are not ignorant or stupid and their methods of preparing and cooking of food do not ordinarily result in salmonellosis.” Had the protesters read further in the court’s decision, they would have discovered, “The record contains facts supporting appellants’ assertion that people are not generally aware of the danger of salmonellae, much less of the safeguards required to avoid salmonellosis. Moreover, a study conducted for the Department of Agriculture and the Food and Drug Administration states that ‘the vast majority of the public and personnel of various food-associated industries barely know that salmonellae exist. Many of them have suffered from salmonellosis, but they do not know why or how to avoid future incidents.'” (United States Department of Agriculture & Food and Drug Administration, An Evaluation of the Salmonella Problem 16 (1969) When the recent outbreaks of salmonellosis were reported, there were still calls of, “Just cook it.” Cooking is but one of the three points in Wilson’s Triad. Wilson’s Triad is treatment, preventing post-treatment contamination, and stabilizing. David Mossel frequently touted Wilson’s Triad in his papers on food safety. He based the triad on Sir Graham Wilson’s 1933 paper on safe milk processing. Scientific research indicates that for preventing salmonellosis, preventing post-cook contamination is critical. In a 2009 review, Luber stated, “In conclusion, cross-contamination events from activities such as use of the same cutting board for chicken meat and salad without intermediate cleaning or spreading of pathogens via the kitchen environment seem to be of greater importance than the risk associated with undercooking of poultry meat or eggs.” Luber continued, “In conclusion, in order to reduce consumers’ exposure to pathogens such as Salmonella and Campylobacter in poultry meat and eggs during preparation of these foods, management activities should focus on cross-contamination risks.” In a 2009 research paper, DeDonder, et al., observed adults and adolescents preparing raw poultry products. Although the subjects knew their actions were being recorded, more than 50 percent of adults touched other surfaces after handling raw product without washing their hands. A third used the same utensil for raw as for cooked without washing it. The adolescents’ actions were worse, although only one-quarter used the same utensil for raw as for cooked. In an earlier paper, Anderson, et al., videotaped 99 consumers in their homes. They reported, “Handwashing was inadequate.  . . . Only one-third of subjects’ hand wash attempts were with soap.  . . . Nearly all subjects cross-contaminated raw meat, poultry, seafood, eggs, and/or unwashed vegetables with ready-to-eat foods multiple times during food preparation. Unwashed hands were the most common cross-contamination agent. Many subjects undercooked the meat and poultry entrees. Very few subjects used a food thermometer.” Even earlier, in the American Public Health Association, et al., Appellants, v. Earl Butz, Secretary of Department of Agriculture, et al., in item 39, the court wrote, “Meat or poultry is not ‘adulterated’ within the meaning of the relevant statutes if the presence of salmonellae ‘does not ordinarily render it injurious to health.’ The court apparently takes the position that meat and poultry ‘ordinarily’ pose no threat of salmonellosis because American consumers are aware of the problem and familiar with the precautions necessary to prevent its occurrence. That, however, is a debatable proposition, and appellants, with substantial backing, seriously dispute it.” The epidemiological data since that court summation support that virulent Salmonella in raw meat and poultry are “ordinarily” injurious. According to FSIS, while Salmonella prevalence in broilers is down, poultry parts remain about 25-percent positive. Thus, those few positive birds are spreading the salmonellae across the carcass breaking surfaces. Imagine what happens in an ordinary kitchen. Lastly, in the December 2013, Journal of Food Protection, Bogard, et al., reported on a study of 385 restaurants in eight states. In about one-third of the restaurants they observed, workers (28-44 percent) using unsafe food handling practices such as using “the same utensils (without washing, rinsing, sanitizing) or gloves (without changing) on raw ground beef and RTE foods.” Safe handling to prevent cross-contamination is critical, but, in my and others’ experiences, it is difficult to attain. For example, I have witnessed a NASA engineer, a House Agricultural Committee staff member, an architect, and USDA staffers mishandle grilled meat and poultry. These were not stupid people, but they were ill-trained in handling potentially hazardous products. In summary, most “ordinary individual” consumers are not competent to safely handle raw meat or poultry contaminated with virulent infective pathogens. The counter argument is that millions of consumers prepare raw meat and poultry daily without negative health consequences. I believe those successes can be attributed to: (1) the low level of pathogens in and on raw meat and poultry, (2) the lower level of virulent pathogens, (3) the partial reduction in the level of pathogens even by undercooking, (4) the dilution of the level of pathogens during cross-contamination, (5) the human immune system that can defeat low levels of pathogens, and, (6) luck. References: American Public Health Association, et al., Appellants, v. Earl Butz, Secretary of the Department of Agriculture, et al., http://cases.justia.com/us-court-of-appeals/F2/511/331/399042/>, United State Court of Appeals, District of Columbia Circuit. – 511 F.2d 331, Argued Jan. 22, 1974. Decided Dec. 19, 1974. Rehearing En Banc Denied April 9, 1975. Anderson, J.B., Gee, E., Mendenhall, V.T., Shuster, T.A., Hansen, K. and Volk, A. 2004. A camera’s view of consumer food handling and preparation practices”, Journal of the American Dietetic Association, Vol. 104, pp. 186-91. Bogard, April K., Candace C. Fuller, Vincent Radke, Carol A. Selman, and Kirk E. Smith. 2013. Ground Beef Handling and Cooking Practices in Restaurants in Eight States, J Food Protect. 76:2132-2140 doi:10.4315/0362-028X.JFP-13-126. DeDonder, Sarah, Casey J. Jacob and Brae V. Surgeoner, Benjamin Chapman, Randall Phebus and Douglas A. Powell. 2009. Self-reported and observed behavior of primary meal preparers and adolescents during preparation of frozen, uncooked, breaded chicken products, 2009. British Food Journal Vol. 111 No. 9, 2009 pp. 915-929) Luber, Petra. 2009. Cross-contamination versus undercooking of poultry meat or eggs — which risks need to be managed first? International Journal of Food Microbiology 134 (2009) 21-28 Mossel D.A.A. 1989. Adequate protection of the public against food-transmitted diseases of microbial aetiology.  Achievements and challenges, half a century after the introduction of the Prescott-Meyer-Wilson strategy of active intervention. International Journal of Food Microbiology, 9: 271-294. Wilson, G.S.1933. The Necessity for a Safe Milk-Supply. Lancet II, 829-832.

  • Don Schaffner

    Nice work, Carl. Except the title should be “Just cook it?”

  • Oginikwe

    Just keep it out of our food makes more sense to me.

  • Mike_Mychajlonka_PhD

    This author of this article (and commentators on it) all seem to assume that the contamination of greatest concern is of the direct type. This thinking ignores biofilm formation. We know that Salmonella for biofilms. We know that if such biofilms are allowed to mature unmolested the bacteria within become resistant to the killing action even of professional-grade sanitizers. We know that consumer kitchens are not equipped to resist the corrosive effects of many sanitizers. It is a safe bet that most consumers do not know how to recognize the presence of a biofilm even if they knew enough to look for one. Even if they find evidence of a biofilm, what can they do about it? If 25% of poultry products coming in to a consumer kitchen test positive for Salmonella then in a household that enjoys poultry on a regular basis the probability of formation of a Salmonella biofilm willl increase with every exposure until the overall probability essentially becomes certainty. Such a kitchen may infect users with Salmonella using as a vector any food produced in that kitchen, not just chicken. Not to put too fine a point upon it, 1975 was 39 years ago. Judges are not infallible. The evidence to overturn the ill-conceived precedent set by APHA et al. v. Earl Butz USDA is in hand. Someone needs to make use of it.

  • farmber

    Excellent commentary!

    Thanks to the iCAFO ndustrialization of our food supply Salmonella has spread throughout the food system and is now present in the chicken and the egg…

    So what does the industry do? Blame consumers!