Twenty-four ill in 15 states, with one case of HUS, is reason enough to re-examine the frozen food industry’s reliance on consumers to make a bad product–i.e. food contaminated by E. coli–good.  Several of Farm Rich’s frozen products–quesadillas, mozzerella bites, philly cheese steaks and pizza slices–have been fingered as the likely cause of a large E. coli O157:H7 outbreak.  As was to be expected, Farm Rich’s website contains the following proviso:

Please note, each of our product packages contain cooking instructions that, if followed, will effectively destroy any E.Coli bacteria. These preparation instructions have been validated following the Grocery Manufacturers Association industry protocol to ensure food safety.

What of the industry’s practice/habit of making these kinds of statements?  Is it merely a face-saving measure, or does the industry really factor consumer cooking into its food safety efforts?  If the latter, that is problematic.

It is worthwhile to revisit a 2009 article from New York Times reporter Michael Moss, who won a Pulitzer Prize for his piece on Marler Clark E. coli client Stephanie Smith.  The 2009 article, which Moss wrote after the ConAgra pot pie Salmonella outbreak, was called “Food Companies are Putting the Onus for Safety on Consumers“.  Here is what he found, and had to say, about consumer cooking of frozen products:

Federal regulators have pushed companies to beef up their cooking instructions with the detailed “food safety” guides. But the response has been varied, as a review of packaging showed. Some manufacturers fail to list explicit instructions; others include abbreviated guidelines on the side of their boxes in tiny print. A Hungry-Man pot pie asks consumers to ensure that the pie reaches a temperature that is 11 degrees short of the government-established threshold for killing pathogens. Questioned about the discrepancy, Blackstone acknowledged it was using an older industry standard that it would rectify when it printed new cartons

Some food safety experts say they do not think the solution should rest with the consumer. Dr. Michael T. Osterholm, director of the Center for Infectious Disease Research and Policy at the University of Minnesota, said companies like ConAgra were asking too much. “I do not believe that it is fair to put this responsibility on the back of the consumer, when there is substantial confusion about what it means to prepare that product,” Dr. Osterholm said.

In fact, the Times article continued:

attempts by The New York Times to follow the directions on several brands of frozen meals, including ConAgra’s Banquet pot pies, failed to achieve the required 165-degree temperature. Some spots in the pies heated to only 140 degrees even as parts of the crust were burnt.

A ConAgra consumer hotline operator said the claims by microwave-oven manufacturers about their wattage power could not be trusted, and that any pies not heated enough should not be eaten. “We definitely want it to reach that 165-degree temperature,” she said. “It’s a safety issue.”

In 2007, the U.S.D.A.’s inspection of the ConAgra plant in Missouri found records that showed some of ConAgra’s own testing of its directions failed to achieve “an adequate lethality” in several products, including its Chicken Fried Beef Steak dinner. Even 18 minutes in a large conventional oven brought the pudding in a Kid Cuisine Chicken Breast Nuggets meal to only 142 degrees, the federal agency found.

It is only a natural reaction for Farm Rich to highlight consumer cooking practices in defense of its product, particularly in the wake of a large E. coli outbreak.  But there is a problem if Farm Rich factors consumer cooking into its food safety efforts.  Consumers cannot be the last line of defense because, for many reasons, consumers’ ability to ensure the safety of products they buy will never be a 100% guarantee.  There are too many variables involved, including, to name just a few, differences in cooking devices and the temperatures acheived; differences in the observance, or even reading, of instructions (after all, are mozzerella bites and frozen quesadillas not marketed, in large part, to kids? Do your kids reliably read and observe cooking procedures on packages?); and differences in the habitual usage of certain products (think Nestle cookie dough E. coli outbreak; did Nestle not know and fully expect that people consumed this product raw?)