I am writing this in response to Dan Flynn’s raw milk article which appeared in Food Safety News on April 28.  Mr. Flynn’s article reported on raw milk legislation currently being considered in Georgia, Missouri and Iowa.

The article reports that Georgia’s proposed Raw Milk Dairy Act, not signed by Gov. Kemp, includes several requirements. One is a warning label on the raw milk packaging which must say: Warning: This is a raw milk product that is not pasteurized and may increase the risk of foodborne illness.

Missouri’s proposed House Bill 1977 would legalize selling “Grade A” retail raw milk and raw cream products made in Missouri at  grocery stores, restaurants, soda fountains, and similar establishments. The raw milk products would also be required to post and carry warning labels saying “WARNING: This product has not been pasteurized and, therefore, may contain harmful bacteria that can cause serious illness in children, the elderly, and persons with weakened immune systems.  

The article’s concluding statement is “Pasteurization has prevented millions of people from becoming ill.  Most public health professionals and health care providers consider pasteurization one of public health’s most effective food safety interventions ever.” So true!

Quoting from Mr. Flynn’s article, pasteurization is the process of quickly heating milk to a high enough temperature for a short time to kill illness-causing germs.  The process of heating milk qualifies as a Critical Control Point, the CCP in HACCP which USDA’s Food Safety Inspection Service requires in federally-inspected and state-inspected meat and poultry establishments. A CCP is defined as a point in food production where controls can be implemented which prevent, eliminate and reduce pathogens to a non-detectable level. Interventions such as full cooking and irradiation qualify as CCP’s. Other valuable interventions, such as temperature control, are Control Points but clearly do not qualify for Critical Control Points in  the absence of a kill, or lethality, step.  

By the way, the HA in HACCP represents Hazard Analysis. A thorough Hazard Analysis has extreme importance and value to all production lines, fully cooked or raw, even on non-food items.

This is precisely why USDA frequently issues educational warning missives to the public, reminding consumers to properly handle and fully cook raw products that have not been subjected to a Critical Control Point intervention prior to sale to the public. Candidly stated, the Critical Control Point step in raw food must be conducted by the end consumer, such as restaurants or in home kitchens, where a lethality step can be implemented.

From a public health standpoint, the focus is on the word “RAW,” requiring due diligence by the end user to safely prepare the raw food prior to consumption.  The same reasoning is utilized by the state legislatures in Georgia and Missouri, as stated in Mr. Flynn’s article about legalizing the sale of raw milk in those states.

My purpose is not to take a stand on allowing or disallowing the sale of raw milk.  I can purchase raw milk, but I do not. Rather, my purpose is to question whether other raw products, including vegetables, meat and poultry, etc. should carry a warning statement, similar to warning labels required on raw milk.  

Packages of ground beef in my home freezer all include labeling stating “SAFE HANDLING INSTRUCTIONS.  In small print are found the following instructions:  This product was prepared from inspected and passed meat and/or poultry.  Some food products may contain bacteria that could cause illness if the product is mishandled or cooked improperly.  For your protection, follow these safe handling instructions.  These instructions include warnings to COOK THOROUGHLY (my emphasis), keep food hot, and cold, and keep separated from other foods.

An important point: how can product inspected and passed [under HACCP inspection] possibly contain bacteria?  If raw meat has been produced under HACCP, the meat, by USDA mandate, cannot contain pathogens!

Mandated safe handling Instructions on raw ground beef constitute a tacit admission that USDA acknowledges food safety hazards exist in raw meat.  Such instructions should not be required, because the ground beef — and all raw meat and poultry — processed at FSIS-inspected plants have (1) Raw, Ground and/or (2) Raw, Not Ground HACCP Plans that allegedly have Critical Control Points to reduce pathogens to less-than-detectable levels. Since all raw meat and poultry emanating from FSIS-inspected establishments have ostensibly killed all harmful pathogens, there should be no need for subsequent safe handling labels.

It bears repeating that true, original, science-based HACCP was specifically designed to produce consistently safe food for the Army and NASA. Thus, true HACCP specifically denied the HACCP label for raw food, because raw food lacks a kill step, thus can easily harbor invisible pathogens. Astronaut food, and battle field rations are all ready-to-eat, and certainly not raw. But after the 1993 Jack in the Box hamburger outbreak, the USDA’s embarrassed Food Safety Inspection Service was desperate to introduce a new system which would guarantee the production of safe food. Voila, HACCP was the answer! FSIS intentionally mandated a bastardized version of pseudo HACCP, which included raw meat and poultry under the HACCP aegis, knowingly in the total absence of a valid, legitimate Critical Control Point.

Back to raw milk, the production of which likewise mandates valuable warning labeling for consumers.  Since raw milk must bear warning labels, a laudable safety step, should all raw foods display similar warning labels?  

Mr. Flynn’s article stated “From 1993 through 2012 (19 years) there were 127 outbreaks reported to CDC with links to raw milk. These outbreaks included 1,909 illnesses and 144 hospitalizations.”  These 1,909 illnesses are veritably unfortunate, causing untold heartache and pain to many families. I am surprised that the annual average was only 100, thinking the annual average to be much higher. I’d like to know the annual average of sicknesses attributed to consumption of other raw foods, such as leafy green vegetables, cantaloupe, eggs, sprouts, etc. In spite of the highly acclaimed, but unscientific, HACCP mandate for raw meat and poultry, the industry is not making progress to eliminate salmonella from raw foods. At some time, FSIS must realize that in the absence of a legitimate Critical Control Point kill step, Salmonella will continue to persist in raw food, spawning countless more sicknesses and recalls.

Because of this, shouldn’t all raw food be labeled with warning instructions?  If not, why are raw milk and ground beef singled out, and required to be properly labeled?

We need to remember that the end user must do his/her part in the preparation of consistently safe food for consumer use. Only when all food is subjected to a valid kill step prior to sale to the public, and sold “ready to eat,” will consumers be off the hook for their part in the food safety farm-to-fork continuum. This will never happen, as we all purchase raw foods such as ground beef, chicken breasts, turkey and lettuce, which we will prepare at home. Thus, end users must simply accept some responsibility to properly handle and fully cook raw products.

Lastly, we must admit that USDA’s Food Safety and Inspection Service will totally oppose my recommendations. Why?  Because their “version” of HACCP allegedly prevents, eliminates and reduces pathogens to a non-detectable level in raw meat. Thus, no need for warning labels on any raw meat produced under its HACCP protocol.

USDA’s implementation of its intentionally faulty HACCP protocol has lulled American consumers to sleep, de-incentivizing us from practicing safe handling practices.

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