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My Steak has been needle or blade penetrated or hammered – Really? What about E. coli?

My email box is filling up following yet another FSIS recall – this time the issue is “mechanically tenderized” steaks contaminated with E. coli O157:H7 linked to illnesses in several states.

So, how often are our steaks penetrated or hammered? As you can imagine, that information is not that readily available. It is hard to see that as a positive spin on the menu at your favorite restaurant.

But, how often?  According to A Risk Assessment of E. coli O157:H7 in Tenderized Beef Steaks, “the majority of steaks and roasts destined for hotel, restaurant, and institutional use in the U.S. may be subjected to ‘mechanical tenderization.’” Also, some 18% of steaks are tenderized in retail and 25% of steaks are consumed in restaurants.

And, Why?  According to another industry publications, tenderness is the most important factor affecting consumer ratings of beef. Beef tenderness is affected by two primary factors called background tenderness and protein (muscle fiber) tenderness.

So what is it?  Mechanical tenderization is a method whereby fine incisions are made in the meat by closely spaced, specially designed knives (also, hammering and needling) which cut the connective tissue. The mechanical tenderization process takes less than one minute with a roller type tenderizer or a crank type hand operated tenderizer. Meat, which has been treated in this manner, is immediately tenderized without the use of chemicals or other artificial means or the need to wait for natural bacterial action to take place. The depth and the spacing of the knives and the number of times the meat is passed through the tenderizer permits the degree of tenderization to be determined, thus controlling the amount of tenderizing. Almost every grade of meat can be tenderized without danger of meat fabric deterioration or granulation.

Why should we care? 
A 2005 study found the incidence of E. coli O157:H7 on surfaces of beef cuts intended for blade/needle tenderization by Warren-Serna et al. (2002) revealed a 0.2% occurrence on 1,014 cuts from six packing plants or purveyors geographically dispersed throughout the U.S. The fact that E. coli O157:H7 does (albeit rarely) occur on beef primal/subprimal cuts generates risk of its entry into cuts when blade/needle or moisture-enhancement tenderization technologies are used, and its probability of occurrence is dramatically increased if improper cleaning/sanitizing of equipment is practiced. Gill and McGinnis (2004) collected 25 samples from four grocery stores, two of 100 samples, both from the same store, had detectable levels of E. coli on the internal surface of the product, further indicating that the risk of transferring E. coli O157:H7 to the interior of muscle samples is low and often dependent on site specific cleaning and sanitation programs. Blade tenderization has been found to transfer 3 to 4% (Hajmeer et al., 2000; Phebus et al., 2000) or 1 to 7% (Lambert et al., 2001) of surface contamination to the interior of the muscle; needle injection (during enhancement) results in 4 to 8% translocation of surface contamination to the center of the cut (Lambert et al., 2001).

What to do about it?  As a result of the work of the Blade Tenderization Committee of the CFP, needle tenderized steaks… aka "pinning" or Jacquard processing, must be cooked to 155 degrees F, same as ground meats and injected meats, and is included as such in the 2009 FDA Food Code.

So, what does the Government Say? Keep reading:

Questions & Answers from FDA/CFSAN

1. Are we to assume that all beef that is not labeled as "whole muscle intact beef" or for which the retailer has no written buyer specifications is blade-tenderized and therefore must be cooked to 155°F?

All beef steak that is not labeled as intact and has no buyer specifications to show that it is intact must be assumed to be a non-intact beef product based on standard meat processing industry practices of pinning, tenderizing or injecting these products. This also includes comminuted beefsteak (chopped, flaked, ground, minced, restructured or reformulated). The Food Code cookingrequirements for pinned, tenderized, injected or comminuted beef steak at 155°F are found in paragraphs 3-401.11(A)(2) and (C). Refer also to the definitions of "comminuted," "injected" and "whole-muscle intact beef" in the Food Code.

2. If the answer to the first question was yes, basically all meat would have to be cooked well done until the retail industry forces the processors to label the beef or provide written specifications. How can we expect this requirement to be driven from the retail level up, when USDA, for whatever reason, is not requiring it from the federal level down?

Paragraph 3-201.11(E) sets criteria for whole-muscle intact beef steaks that are intended for consumption in an undercooked form without a consumer advisory. If documentation showing the steaks are intact is available, steaks may be seared for color to a top and bottom surface temperature of 145°F, provided they are not served in a food establishment for highly susceptible populations. Use of disclosure and reminder for a consumer advisory will allow a food establishment to serve rare or undercooked beef steak cooked to a temperature less than that required in 3- 401.11(A)(2) and (C). The Food Code does not specifically address how beef other than steaks can be identified as intact but the same means can be used (purchase specifications or labeling) as for steaks. FSIS in part is using what happened at the Conference for Food Protection with the issue on blade-tenderized steak as well as the recent outbreaks which have occurred since NACMCF issued its report to give notification to the meat processing industry that they are considering labeling requirements for non-intact beef because of survival of E. coli O157:H7 in tenderized or comminuted beef products.

3. ALL injected meat is supposed to be cooked to 155°F, but the labeling or buyer specifications in the Code, if they exist, only address intact beef. How are we to know if a piece of pork or other non-beef meat is injected or not? With no labeling or buyer specification requirement, it would seem to me that all non-beef meat would have to cooked to 155°F unless the processor could prove otherwise.

The research and epidemiological investigations have only been associated with beef. There is no evidence at this time to indicate that non-intact whole muscle pork has been associated with illness. But the potential for introduction of contamination from the surface exists if needles or blades are used in tenderizing or marinating pork as well. When a meat product is marinated, it usually has the marinade injected into the meat muscle or, in some cases, it is scored to allow better penetration of the marinade into the muscle. These practices could allow entry of pathogenic microorganisms that may be present into the meat. The ingredients of the marinade must be listed on the label under ingredients. Whenever marinade ingredients are listed on the label, the meat should be considered non-intact, whether it is beef or pork. When meat cannot be specifically identified as non-intact, it has to be cooked thoroughly to 155°F unless some other intervention was done such as fermentation or salt-curing.

4. If this is such a concern, why isn’t USDA proposing a new labeling rule?

The FSIS now bases its meat safety program on HACCP. Because of the 2002 NACMCF report that said there was not enough evidence to support a labeling requirement for non-intact meat, the FSIS has not been able to propose a rule requiring labeling. Several additional outbreaks as well as the issue at CFP have given them grounds to reexamine the issue. These factors prompted FSIS to issue the Notice of HACCP Reassessment to control the hazard at the meat processors. At this time, until FSIS makes any further changes in its regulations or the industry makes changes in its practices, we will consider beef and beef steak to require a 155°F cooking temperature unless the processor has shown otherwise through labeling, letter of guaranty, purchase specifications or product specifications on the invoice.

That clearly answers the question?