Guest Blog: The Raw Milk Debate

The following Guest Blog first appeared on the ePerspective, a feature of the IFT newsletter, the weekly, and is reproduced here with the kind permission of its author, Dr. Catherine Donnelly.

The Raw Milk Debate: Economic Opportunity or Legal Liability?

Despite claims of health benefits associated with raw milk consumption, raw milk is a well documented source of bacterial pathogens which can cause human illness, and in some instances, death. Consumers who choose to purchase and consume raw milk should understand that raw milk may contain dangerous bacterial pathogens. Consumers should also understand whether they are in a risk group, which increases their chances of adverse health impacts from exposure to bacterial pathogens.

The dangers posed to public health by bacterial pathogens associated with raw milk consumption are numerous. Listeria monocytogenes, Salmonella Typhimurium, Escherichia coli O157:H7, and Campylobacter are just four of the pathogens of concern in raw milk. The bacterial pathogens posing a risk to consumer health have become more dangerous in the past two decades.

During this same period, the percentage of our population at risk for foodborne illness has increased significantly. It is critically important to understand risks posed by raw milk consumption, why the pathogens have become so dangerous, who is at greatest risk for severe illness and death, and why we need public health policies that limit exposure and warn susceptible consumers about dangers posed by raw milk consumption.

Of all of the food commodity sectors in the U.S., no sector is more committed to public health than the dairy industry. The reason for the absolute commitment to public health stems from early in the 1900s when raw milk was a major source of human disease, including tuberculosis and scarlet fever. Numerous deaths were linked to raw milk consumption. The public health response to this crisis was the crafting in 1924 of the Pasteurized Milk Ordinance (PMO), a comprehensive document which governs all aspects of production, processing, and marketing of milk and dairy products. Pasteurized milk is not a safe product simply due to the heat treatment which milk receives; milk safety is achieved because the PMO outlines a comprehensive system to assure milk safety.

The PMO is constantly updated, guided by scientific experts, farmers, and dairy industry personnel working through the National Conference on Interstate Milk Shipments (NCIMS) which works to “assure the safest possible milk supply for all the people” through enforcement of Grade A milk sanitation laws. The PMO has made pasteurized milk one of the safest food products available to consumers, and this ordinance has had a profound positive impact on public health. The PMO is the accepted operating guideline for the handling and production of milk and dairy products in most states. Adherence to the PMO importantly protects the U.S. milk market by enhancing consumer confidence in dairy product safety and reducing liability costs of this economically significant sector of the U.S. agricultural economy.

Many states have recently passed legislation to expand the sale of unpasteurized milk, allowing farmers to sell larger quantities of unpasteurized milk and thereby enhance economic opportunities in these times of severe economic challenges for so many dairy farmers. However, should economic opportunity be met at the expense of public health? Does pursuit of economic opportunity for some create the right to jeopardize the image of an entire industry that has built its reputation on the safety and wholesomeness of its products? Has this legislation created two standards for milk production in the U.S. and if so, what does this pose for the future of the U.S. dairy industry? There are important liability issues faced by individuals producing products causing harm to consumers, so the key question remains: Has raw milk legislation created economic opportunity or legal liability for farmers engaged in the sale of unpasteurized milk?

About Cathy Donnelly: Dr. Catherine Donnelly is Professor, Dept. of Nutrition and Food Science, University of Vermont and Co-director, Vermont Institute for Artisan Cheese.


Guest Blog: Solving the E. coli Problem – The Cantaloupe Theory

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.

Solving the E. coli Problem – The Cantaloupe Theory

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.

About Jim Marsden: Dr. James L. Marsden is Regent’s Distinguished Professor of Food Safety and Security at Kansas State University, and the senior science advisor for the North American Meat Processors Association. He is the past president of the American Meat Institute Foundation in Washington, DC and a graduate of Oklahoma State University.

 

Guest Blog: Listeria monocytogenes and Food Processing Equipment, 3/3

The following Guest Blog first appeared as a three-part series in French on Le Blog d’Albert Amgar, a regular feature on ProcessAlimentaire.com, and is reproduced here in English (translation by Phyllis Entis) with the kind permission and cooperation of its author, Albert Amgar.

A continuation of Listeria monocytogenes and Food Processing Equipment, 1/3 and 2/3

Equipment suppliers have made some progress, but they still have a way to go. Thus a large manufacturer of packaging equipment can make the following claim:

“Perfect hygiene. Outside and in!

The whole of the B 310 can be soaped and washed down. 
And every part of the machine is easily accessible for cleaning:

  • The inside of the tilting lid in a comfortable standing position and in a good light.
  • The control cubicle and the inside of the machine – with removable side panels.
  • The conveyor belt – which is loosened at the touch of a button and can be removed completely.
  • The smooth, sloping stainless steel surfaces with no recesses or sharp edges.”

All of these elements point to true progress. But why indicate that a machine is designed for easy soaping and washing down?

Also, there is no mention of a set of instructions, as I alluded to in part 1/3 of this series of articles. In fact, it’s difficult to believe that “washing down” would be a recommended cleaning method. AFSSA, the French Food Safety Agency, in its discussion of biofilm control, suggests, “… it is essential to minimize the amount of water used. Water not only encourages microbial growth, but can also be a contaminating channel as when running over a biofilm it carries and spreads a part of the micro-organisms that compose it, which may be pathogenic” (such as Listeria monocytogenes).

Sanitary design, therefore, must facilitate cleaning; nevertheless, not just any compound can be used for cleaning. Strict rules apply.

Since I began with Maple Leaf Foods, it is appropriate to reflect here the Company’s Food Safety Action Plan, as given on their website:

  • Improved sanitization.
  • Doubled the amount of environmental testing.
  • Increased the amount of food testing.
  • Strengthened our product recall procedures.

Personally, I would have much preferred that the Company would have begun by improving their cleaning protocols. To illustrate, the following is a video distributed by the Company to demonstrate the cleaning and disinfection procedures in use in Maple Leaf Foods’ Bartor Road processing plant – the source of last year’s Listeria monocytogenes contamination.

Be observant, and don’t hesitate to improve equipment design, cleaning procedures, cleaning practices, and cleaning materials. And above all, pay close attention to the management of the cleaning crew. A contamination problem is always a management problem.

About Albert Amgar: Albert Amgar lives in Changé near Laval in Mayenne, France. He worked as young scientist at the Parasitology and Tropical Medicine Service of the Pitié Salpétrière Hospital and later spent 12 years in the pharmaceutical industry. In 1989, he became director of a new association of agro-food industrialists named ASEPT in Laval (France). He was the general manager of ASEPT until his recent retirement.