For years, the USDA Food Safety and Inspection Service (FSIS) has allowed meat plants to divert meat that has tested positive for E. coli O157:H7 (or some other pathogen) to a further-processing facility where it is cooked for a time and at a temperature sufficient to kill the pathogens.  What FSIS has not done, however, is require immediate corrective action of the plant’s slaughter and sanitary dressing procedures so as to determine how the meat came to be contaminated in the first place.  Because, let us be clear: ground beef, trimmings, an intact cuts of meat do not get contaminated with E. coli O157:H7 unless the carcass is contaminated, or cross-contaminated, druing the slaughter or carcass-dressing process.  Bottom-line: Meat is not contaminated but for the manner of its slaughter and dressing. 

So lax has been the FSIS focus on and oversight of the slaughter and dressing process that it has routinely allowed plants to send meat that has tested presumptively positive for E. coli O157:H7 to be sent for further-processing without requiring that confrimatory testing be done.  This give the plant a free pass by avoiding a confirmed positive test result for E. coli O157:H7, something that would be higly likely to prompt a comprehenisve assessment at the plant, and the requirement that the plant’s HACCP plan be re-assessed and re-validated.  This also allows both the plant and FSIS to pretend that the Slaughter HACCP plan has not failed for not reduciing E. coli O157:H7 to an "undetectable level"–something that FSIS policy has required since October 7, 2002.

Now, if in reading the above the image of an ostrich with its head in the sand came to mind, then you are definitely grasping the gist of my criticism here.  But, that said, I am happy to report that FSIS finally seems to have pulled its proverbial head out of the sand and seen the light. 

Yesterday the agency issued FSIS Directive 6410.1, and it is a very good thing indeed.  For more on this, please hit the CONTINUED READING link.

For the first time, the agency has explicitly announced its recognition that E. coli O157:H7 is a problem that starts (and someday hopefully ends) with the slaughter and dressing process.  As a result, from this point forward, FSIS is going to take note:

of the increased number of E. coli O157:H7 positive samples of ground beef and trim collected by FSIS and an increased number of recalls associated with E. coli O157:H7, including those specificall initiated as a consequent of human illness. These increases can be attributed, in part, to ineffective sanitary dressing and process control procedures that create insanitary conditions during slaughter.  Effective sanitary dressing annd process control procedures are crucial to an establishment’s ability to produce clean, safe, and wholesome product.

The importance of this shift in FSIS enforcement efforts cannot be overstated, and hopefully it represents a sea-change that will lead to a reduction in death and serious injury.  In particular, this may put to an end the inane argument, incessantly advanced by the meat industry, that deadly pathogens are somehow inherent to meat, and thus it must fall to consumers to make meat safe to eat by cooking it "safely." As the agency noted in this recent directive, "it considers an acceptable reduction of E. coli O157:H7 to be a reduction to an undetectable level." In other words, it is not supposed to be there in or on meat at all, and, if it is, the meat is adulterated.

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.