In 1999, the USDA-FSIS asked the National Advisory Comittee for Microbiological for Foods whether tenderized beef presented increased risks of contamination by E. coli O157:H7.  The answer, of course, was that it does, and that risks to consumer health increased correspondingly.  See Recommendations

This is not surprising, of course, nor is it particularly newsworthy in and of itself given the recent outbreak linked to tenderized beef from National Steak and Poultry.  In other words, we already knew that.  What i am interested in at this point is what questions we need to ask of National Steak and Poultry in upcoming litigation over the outbreak.  Essentially, what did National Steak and Poultry, and the industry at large, know about the risks of tenderized beef, and what did they do in order to reduce these risks and make a safer product. 

FSIS recommended several such steps, which certainly do not exhaust the list of things that manufacturers of tenderized beef need to do, but are good first steps at least:

First, the FSIS asked each plant operater that mechanically tenderizes beef to specifically consider in their annual reassessment of their HACCP (hazard analysis and critical control points) plan the significance of E. coli outbreaks linked to tenderized beef as a hazard that is reasonably likely to occur. 

Second, FSIS asked that each of these processors implement purchase specifications requiring the incoming product to be treated to reduce or eliminate E. coli to an undetectable level or apply an approved antimicrobial treatment to the meat.  See yesterday’s post on this subject.

Third, though not really a recommendaiton, FSIS was "considering" a requirement that raw, mechanically tenderized beef be labeled to show that it had undergone mechanical tenderization.  (A brilliant idea, and one that all state legislatures should consider independently of any FSIS commandment on the subject; consumers should, at the very least, know whether the meat they are about to consume has undergone a tenderization process that may require a different cooking approach to make the product safe to eat)

Further, in light of the FSIS research and recommendations, the Dairy and Food Protection Branch (Division of Environmental Health, Department of Environmental and Natural Resources) issued the following additional recommendations:

1.  All beef not labeled as intact and without buyer specifications to show that it is intact must be assumed to be a non-intact beef product based on the standard meat processing industry practices of pinning, tenderizing or injecting these products. This also includes comminuted beef steak (chopped, flaked, ground, minced, restructured or reformulated).

2. Cook non-intact beef products to a temperature of 155°F as measured by a properly calibrated food thermometer as required by the FDA Food Code.

3. If you currently tenderize beef steaks or other beef products in your restaurant kitchen, please stop this practice.

4. Educate your staff about the identified risks of mechanically tenderized (non-intact) beef products.

5. When possible, notify consumers about the risk of getting E. coli from mechanically tenderized (nonintact) beef steaks and roasts

I wholeheartedly agree, particularly with any recommendation aimed at achieving elimination of bacterial contamination by the slaughterhouses, as well as with any recommendation that aims to educate the consumer about the risks he or she faces by consuming tenderized beef.  National Steak and Poultry, which of these steps were you actively taking at the time of the outbreak?