Yesterday, the USDA Food Safety and Inspection Service issued a largely useless, but still widely published, news release entitled “Independence Day: Drills for the Grill.” See News Release, While notable for a cheery and reassuring tone, the information provided is, at best, unhelpful, and, at worst, is dangerously misleading. In addition to providing little in the way of substantive food safety information about how to “safely” grill a burger, the FSIS news release deceitfully soft-pedals the real risks posed by ground beef, generally, and outdoor grilling in particular. For example, the new release clumps together hamburgers, steak, chicken, hot dogs, and ribs as if all can be treated in the same way, and pose the same relative risk—which is blatantly false. And also, how can anyone at FSIS expect to educate the public about safely grilling ground beef (the real risk here) without once mentioning E. coli O157:H7, the primary risk?

  Take, for example, the introductory quote from FSIS Administrator, Alfred V. Almanza, who states: “Safe food handling is always important, but during the warm summer months — peak grilling season — there is an increased need for awareness of safe food handling practices.” Well, Mr. Almanza, why is that? Could it be because numerous research studies have shown that the incidence of E. coli O157:H7 in cattle rises significantly during the spring, and peaks during the summer months? See, e.g., Edrington, et al, 2006. Seasonal shedding of Escherichia coli O157:H7 in ruminants: a new hypothesis. Foodborne Pathog Dis 3:413-21; Hancock, et al., 1994. The prevalence of Escherichia coli O157.H7 in dairy and beef cattle in Washington State. Epidemiol Infect 113:199-207; Hancock, et al., 1997. A longitudinal study of Escherichia coli O157 in fourteen cattle herds. Epidemiol Infect 118:193-5; and Hussein, et al., 2005. Prevalence of Shiga toxin-producing Escherichia coli in beef cattle. J Food Prot 68:2224-41.  Why not level with the public and tell them that ground beef simply tends to be more dangerous in the summer, and that is when a higher than average percentage of E. coli O157:H7 infections occur?  Of course, that might make the USDA look bad, and could further depress the sales of ground beef.

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Another reason the safe grilling practices are particularly important is because grilling burgers on a barbecue grill is an exceedingly risky practice that is almost certain to result in burgers not consistently reaching an internal temperature of 160 degrees Fahrenheit? Snyder, O. P. 2005. Cooking hamburgers on a Weber outdoor grill. HITM. St. Paul, MN.:  And the USDA spent years and years telling people to rely on color as an indication of doneness when cooking hamburger patties, but then switched in June 1997 and started recommending the use of thermometers to determine doneness. See FSIS Technical Publication, Color of Cooked Ground Beef as it Relates to Doneness, available (citing the studies that prompted the changed recommendation). Or because once the USDA started to recommend the use of a thermometer use, it was inappropriate and inaccurate bi-metallic coil thermometer (the one that appears on the USDA safe-handling instructions on all meat) that was consistently suggested. See, e.g. O. Peter Snyder, Ph.D., The Dangerous Bi-Metallic Thermometer, available at (“USDA-recommended bimetallic coil thermometer is an inaccurate, awkward, and complicated device for measuring the temperature of highly contaminated, government-inspected and improved raw foods that cooks must pasteurize”).

Notably, yesterday’s press-release recommends the “use of an instant-read thermometer,” which is an excellent recommendation. But few consumers even own this kind of thermometer, let alone use one. McCurdy, et al., 2004. Availability, accuracy and response time of instant-read food thermometers for consumer use. Food Prot. Trends. 24(12):961-968. A 2006 food safety survey conducted by—you guessed it—the USDA (and FDA) found that only 13% of consumers always or often use a thermometer, of any kind, when cooking hamburgers. Lando and Verril, 2008. 2006 USDA/FDA Food Safety Survey, And there is also the significant risk that the temperature measured in one place on the hamburger will be different than the temperature elsewhere. Berry, B. W., and Bigner-George, M.E. 2001. Postcooking temperature changes in beef patties. J. Food Prot. 64(9):1405-1411.

And then there is the low infectious dose of E. coli O157:H7, and its virulence. Patricia M. Griffin, et al., Large Outbreak of Escherichia coli O157:H7 Infections in the Western United States: The Big Picture, in RECENT ADVANCES IN VEROCYTOTOXIN-PRODUCING ESCHERICHIA COLI INFECTIONS, at 7 (M.A. Karmali & A. G. Goglio eds. 1994) (“The most probable number of E. coli O157:H7 was less than 20 organisms per gram.”) Patricia M. Griffin & Robert V. Tauxe, The Epidemiology of Infections Caused by Escherichia coli O157:H7, Other Enterohemorrhagic E. coli, and the Associated Hemolytic Uremic Syndrome, 13 Epidemiologic Reviews 60, 73 (1991) (“an organism that can be transmitted by exposure to extremely few organisms.”) Indeed, the USDA has repeatedly noted that a primary reason behind the decision to treat E. coli O157:H7 as an adulterant per se is “the low infectious dose of E. coli O157:H7 associated with foodborne disease outbreaks and the very severe consequences of an E. coli O157:H7 infection.” See  Beef Products Contaminated with Escherichia coli O157:H7, 64 Fed. Reg. 2803, at 2804 (Jan. 19, 1999).

Finally, there is the issue of the cooking instructions that appear on the packages of frozen ground beef patties, one of the most popular products purchased for purposes of outdoor grilling. By law, the USDA is supposed to approves the labels of meat and poultry products, which includes any cooking instructions. But a recently published study compared the cooking instructions on 37 retail packages and found a huge variation in suggested cook times (from 1.5 to 8 minutes per side), and inconsistent advice on whether to use a thermometer or rely on the color of the patty to determine doneness. S. McCurdy, et al., Label Instructions and Cooking Times for Retail Frozen Ground Beef Patties, Food Prot. Trends, 29 (6, 335-41 (June 2009). The study found many cooking instructions “are inadequate to produce a safely cooked patty.” And these are instructions supposedly approved by the USDA.

So if consumers cannot even rely on the USDA-approved cooking instructions printed on the box of frozen ground beef patties, how can they be expected to take seriously a new release about the “food safety ‘drills of the grill’”? I certainly wouldn’t.

(Oh, and by the way, if you do want to grill burgers, I would suggest that you cook all hamburger patties on a cooking rack in your oven set at 350 degrees. After cooking for 15-20 minutes, check the temperature of each patty in multiple locations with a digital read thermometer. If all readings are above 150 degrees, remove the patties from the cooking rack to a warm platter. Now take those patties out to the barbecue grill so you can put grill marks on them. Happy cooking!)