Sep 12

“Cause for Significant Concern”

FSIS Notice No. 65-07,  issued October 12, 2007 by the U.S. Department of Agriculture (USDA), is titled “Notice of Reassessment for Escherichia Coli O157:H7 Control and Completion of a Checklist for all Beef Operations.” Strangely, this FSIS (Food Safety and Inspection Service) Notice is for internal use only, i.e., not for release to the public.  Its stated purpose is to “make inspection program personnel aware of a number of significant developments involving Escherichia coli O157:H7 (E. coli O157:H7) in beef products that occurred since the beginning of the high prevalence season for this pathogen in April.  ”FSIS Notice 65-07 acknowledges a serious problem with increased meat product contamination, yet it also conceals this vital information from the public.  The FSIS Notice instructs inspection personnel to meet with establishments (that slaughter, fabricate, grind, mechanically tenderize, or “enhance” beef products), review developments at the meeting, and advise establishments that developments constitute changes that could affect the establishment’s hazard analysis or cause the establishment to alter its Hazard Analysis and Critical Control Points (HACCP) systems.

Contaminated Meat Dumped in Landfill, O'ahu

Inspection personnel are to document their findings so the FSIS can determine “approaches for the risk-based verification testing program.  ”The FSIS monitors the percent positive rate (i.e., the percentage of raw ground beef samples analyzed by FSIS) for E. coli O157:H7.   The established maximum target percent positive rate is 0.200%. According to Notice 65-07, the percent positive rate in calendar year 2002 (CY2002) from raw ground beef samples collected by the FSIS (in federal plants, retail stores, and at import houses) was 0.787%. In 2003, the percent positive rate dropped to 0.305%.   Since then, through CY2006, the Notice says there has been a decrease in the percent positive rate, even with a steady increase in the number of similar samples analyzed.

However, thus far in CY2007, FSIS found 20 E. coli O157:H7 positive samples, compared to 20 positive results for the entire CY2006.   That is a percent positive rate of 0.208, and Notice 65-07 states that this “uptick in the percent positive rate is cause for concern.”   Stated another way, for CY2007 the FSIS has requested 13 recalls involving about 29 million lbs. of meat “associated with E. coli O157:H7.”  In contrast, there were 8 recalls involving less than 200,000 lbs. of meat for the entire CY2006.

Recalls Initiated as a “Consequence of Human Illness”

In July 2007, FSIS found an “unusual number” of positive samples in a short span of time: 5 positives in a span of only 3 days, with no linkage among the samples and no evidence of FSIS laboratory contamination.  It says, “This is believed to be a rare event in the 13 year history of verification testing by FSIS for this pathogen” and it “presents a basis for concern that the control measures implemented by beef operations may not be adequate to address the degree of contamination by E. coli O157:H7.”

The Notice discloses that the increased number of recalls are “specifically initiated as a consequence of human illness.”   This begs the question: If the government is so concerned about this “threat to public health,” then why wasn’t the alarm sounded to inform the public of the large-scale contamination?   The alarm was sounded, but only for those within the government itself.

Food Safety Testing Falls Short

The Notice says, “FSIS recognizes the Healthy People 2010 food safety objective for E. coli O157:H7 infections as the public health goal.”   Notice 65-07 discloses that 2004 was the only year in which the “2010 target” was met.   Since then, there has been an “adverse trend” and a “repetitive implication” of certain “source materials” used in the production of ground beef, including “boneless manufacturing trimmings;” and components “beyond the traditional boneless manufacturing trimmings” including “primal/sub-primal cuts, head meat, cheek meat, weasand (i.e., throat, gullet) meat, heart meat, low temperature rendered beef; meat from “advanced meat recovery systems,” and “specially handled beef” (a product treated with an anti-microbial, designated for grinding).   The Notice concludes that FSIS “has reason to believe that establishments are not effectively ensuring that E. coli O157:H7 is adequately controlled at the slaughter and fabrication operations” and that the development “is cause for significant concern.”

Safety of Meat Products in Hawaii

Why hasn’t the USDA made any effort to inform our citizens about the threat to public health posed by contaminated meat products?  I don’t know about you, but I’m glad I’m vegan, because the government hasn’t informed us of anything.  They are educating the business people, but not the consumers.  But then, the USDA is known for its cozy relationship with big business, isn’t it?

Just recently there was a recall of Totino’s and Jeno’s brand frozen pizza, because the pepperoni was contaminated with E. coli. I called the FSIS Circuit Supervisor on Oahu, and was informed that they are aware of FSIS Notice 65-07, and the “program is being implemented.”  Unfortunately, I was told that no other information could be released, because the agency is charged with not only food safety but food security as well.  I was instructed to call the USDA Public Affairs Office in Washington, D.C., if I had further questions.

I would like to think that our Hawaii legislators have enacted laws aimed at increasing raw meat inspections.  The State should play a role in food safety, allocating money for inspection, public information, etc.  The State Department of Agriculture (DOA), Livestock Disease Branch, informed me that since about 1995, the State of Hawaii no longer inspects or tests meat products for contamination.  This function is the domain of the USDA.

On November 7, 2007, I called the office of DOA Director Sandra Kunimoto, to see if she is aware of FSIS Notice 65-07.   Unfortunately, I was told that Ms. Kunimoto was not available.  Instead, I spoke with the Public Information Officer (Ms. Saneishei), who told me that the State DOA was not aware of FSIS Notice 65-07.  She stated that in August 2007, because of the high incidences of E. coli O157:H7 contamination, the DOA began sending letters to farmers, ranchers, and livestock operations (adjacent to farm operations), reminding them about “best management practices” such as mitigating runoff.  She said they are offering a “food safety audit” for such operations, if they choose to take advantage of it.

However, if the meat was not produced in Hawaii, these efforts would be moot.  Moreover, the DOA, like the USDA, is only informing businesses, not the consumers who purchase the products.  I realize the DOA is not involved in enforcement efforts, but it could (and I believe should) at least provide education to the general public.  But if the public knew just how dangerous it is to eat that double cheeseburger, they might get scared and that “wouldn’t be good for business.”

I checked the USDA website on November 6, 2007, and found data that had been updated as of November 3, 2007. The website revealed that, slightly less than 1 month after issuance of Notice 65-07 (October 12, 2007), there have been nearly one-third more recalls for E. coli contamination in less than 20 days — and, the year’s not over yet! This information is listed under “Open Federal Cases”:

 More Recalls, after FSIS Notice 65-07 Issued

Product Recalled                                                                                                                                         

051-2007, Cargill Meat Solutions Corp., 59 Separate Beef Products (E. coli O157:H7)                    Nov. 3, 2007

049-2007, Totino’s and Jeno’s Frozen Meat Pizza Products (E. coli O157:H7)                                  Nov. 1, 2007

048-2007, Del-Mar Provision Co. Ground Beef Products (E. coli O157:H7)                                      Oct. 27, 2007

047-2007, Blue Ribbon Meats Frozen Ground Beef Products (E. coli O157:H7)                              Oct. 24, 2007

046-2007, Arko Veal Co. Ground Beef Products (E. coli O157:H7)                                                     Oct. 13, 2007

045-2007, J & B Meats Frozen Ground Beef Products (E. coli O157:H7)                                                         Oct. 13, 2007

042-2007, Cargill Ground Beef Products (E. coli O157:H7)                                                                           Oct. 6, 2007

040-2007, Topps Ground Beef Products (E. coli O157:H7)                                                                           Oct. 6, 2007

025-2007, Ground Beef, United Food Group LLC (E. coli O157:H7)                                                             Jun. 9, 2007

020-2007, Richwood Meat Co. Ground Beef Products (E. coli O157:H7)                                                          Apr. 20, 2007


Here’s one last point: How can the USDA conclude that consumption of animal products results in “healthy people,” whether or not the meat is contaminated?