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.
 Continue Reading Baby Steps: USDA Implements Increase in E. coli O157:H7 Testing.

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.Continue Reading USDA Sees the Light on E. coli O157:H7 and Meat