The following Guest Blog first appeared on Safety Zone, a regular blog feature on the Meatingplace.com site, and is reproduced here with the kind permission of its author, Dr. James Marsden.
When Undersecretary Michael Taylor announced that USDA would consider raw ground beef contaminated with E. coli O157:H7 to be adulterated within the meaning of the Federal Meat Inspection Act, he made a courageous stand for food safety.
His move accomplished quite a lot. It certainly got the attention of the meat industry. After an unsuccessful attempt to block the policy change in federal court, a number of actions were taken to reduce the risk of E. coli O157:H7. Over the past 16 years, measureable progress has been made and beef is undeniably microbiologically cleaner and safer today than it was in 1993.
However, the problem is still not solved. We know much more about the causes of E. coli contamination than we did in 1993. Given what we know today, it’s time to recognize that the policy announced by Mr. Taylor has a fatal flaw. That flaw is the regulatory focus on contaminated ground beef instead of contaminated beef carcasses. If we are going to truly solve the problem, we need to rethink our approach. (In fairness to Mr. Taylor, he probably recognized this flaw at the time, but his options were limited because he knew that USDA would have to defend their position in federal court. A policy that addressed ground beef was more likely to be upheld).
At a recent NAMP Meeting, former Undersecretary for Food Safety, Dr. Richard Raymond and I both spoke about the need to shift the emphasis to chilled carcass pasteurization. Dr. Raymond discussed carcass irradiation as an option. I addressed all of the available technologies, including carcass irradiation, treatment with Ammonia Gas and treatment with Reactive Oxygen Species (Ozone and Vapor Hydrogen Peroxide).
During the discussion with NAMP members, an analogy developed that I believe makes the case for a course correction and defines exactly where our focus should be placed. I will call it the “Cantaloupe Theory”.
Over the past several years, cantaloupes have been implicated in several Salmonella outbreaks. Imagine if FDA had announced that Salmonella is an adulterant in cut, prepared cantaloupe, but not on whole cantaloupes. Taking the analogy to the next step, imagine if regulatory and industry efforts to solve the problem focused on technologies to eliminate Salmonella from cut cantaloupe. If this had occurred, the problem would probably never be solved. Instead, the regulatory and industry focus was properly placed on eliminating Salmonella from the outside surface of cantaloupes. When cantaloupes are whole and intact, all of the contamination is on the outside where it is relatively easy to eliminate.
We have the exact same situation in the beef industry. E. coli contamination starts on the outside of beef carcasses. The meat inside contaminated carcasses is sterile until contamination occurs from the outside – in.
Regulatory focus and industry control strategies should address contamination on chilled carcasses, before they are fabricated and turned into ground beef and other consumer products. This is the point in the process when E. coli contamination is limited to one finite area. It is also the point where E. coli contamination is easiest to eliminate and where there is ample time to apply pasteurization technologies.
If we solve the problem on chilled carcasses, processing that occurs downstream will always start with a pasteurized raw material. Of course, food safety would still be a shared responsibility. Processors should continue to use effective interventions to prevent recontamination and to apply excellent sanitation measures.
The key to this approach is that instead of trying to accomplish the impossible – the decontamination of all of the small pieces after they become contaminated, we would take care of the problem when it is solvable, when the carcass is whole.
That is the solution to the E. coli problem.
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