As I noted in an earlier post on a different blog about the USDA’s decision to, in a matter of speaking, take its head out of the sand and recognize that E. coli O157:H7 is a problem that starts (and someday will hopefully end) with the slaughter and dressing process, the agency is finally appearing to take a more reality-based (which is to say, less industry-biased) approach to ensuring food safety.  For the earlier post, see

Specifically, the only way that meat gets contaminated is because insufficient care was taken during slaughter and feces or ingesta cross-contaminates the previously uncontaminated carcass. Knowledge that this cross-contamination is commonplace is what has given rise over the years to post-slaughter “interventions” like steam-pasteurization and organic acid washes. Put bluntly, there is no need to try to remove the poop on the meat if it does not end up there in the first place.

Since the Pathogen Reduction; HACCP Final Rule was issued in 1996, it has been the stated policy of the USDA that E. coli O157:H7 be reduced to an "undetectable level." This is the so-called zero-tolerance policy for this deadly pathogen, which is based on the irrefutable fact that if the “presence [of E. coli O157:H7] can be prevented, no amount of temperature abuse, mishandling, or undercooking can lead to foodborne illness.” See HACCP Final Rule, 62 Fed. Reg. at 38,962. Now, seemingly more intent at make zero-tolerance a reality, USDA yesterday issued notice that it was mandating an increase in the frequency of its in-plant testing for E. coli O157:H7 in raw ground beef. While this is an improvement, it is but a baby step, since the most frequent testing that will occur under this policy is 4 times per month, and this is only at plants that produce volumes of ground beef greater than 250,000 pounds PER DAY.

For more on this change in policy, please click on CONTINUE READING.

As the agency noted in FSIS Directive 6410.1, "it considers an acceptable reduction of E. coli O157:H7 to be a reduction to an undetectable level." It thus announced that it was going to start increasingly demand that plants reassess their Slaughter HACCP plans when a sample tests confirmed-positive for E. coli O157:H7. This policy change is now being buttressed by an increase in the frequency of the testing that the USDA performs in each plant producing ground beef, with such frequency determined by each plant’s daily production amount. While this is certainly improvement, the increased testing is in large part symbolic, as the USDA has come close to admitting when it defended the chosen frequency by stating:

The number of samples that you would need to collect to have some statistical confidence that if it was contaminated you would find it is in the hundreds," he said. "I mean, it is a lot of samples that need to be collected. At $20 to $100 a sample, you have to make some decisions as to what you can afford.

For the full article from which this quote was taken, see:

Although I applaud any increase in testing, it seems to me that the American public deserves a testing-frequency that achieves statistical significance. Furthermore, it is time for the USDA to implement a meaningful testing program at retail, and stop using the American public as guinea pigs to determine how much E. coli O157:H7 is not eliminated in the plant.

The one final step that the FSIS needs to take to make this new and much improved approach really work is to eliminate, once and for all, the absurd fiction that a presumptive positive is not a "real" positive test result. Confirmatory testing should be required of all presumptive positive test results. Or, in the alternative, if the plant objects to the expense of doing confirmatory testing, then the presumptive results should be presumed to be confirmed positives for purposes of prompting further corrective actions and enforcement efforts.

It is time for the FSIS to enfore a true zero-tolerance for E.coli O157:H7; and with this new Directive, the agency has taken a great step in the right direction.