Big One becomes Big Seven

Escherichia coli O157:H7 has now been joined on the FSIS most unwanted list by the "Big Six" - other strains of E. coli capable of producing Shigatoxin.

As we saw in May and June 2011 in the German outbreak, Shigatoxin-producing E. coli can cause a potentially deadly food borne infection that can leave survivors damaged for life.  The outbreak also resulted in huge economic loss in several European countries as fresh produce was either banned by authorities or shunned by consumers.

As of the 13th September 2011, these seven strains - O157:H7, O26, O11, O103, O121, O45 and O145 - will not be permitted in non-intact raw beef in USA.  If they are found to be present, the meat must either be destroyed or cooked before sale.

It has been a long road to get to this point. In October 2009, Bill Marler, a US attorney, filed a petition with USDA/FSIS for an Interpretive Rule declaring all enterohaemorrhagic Shigatoxin-producing serotypes of E. coli, including non-O157 serotypes, to be Adulterants within the meaning of the Federal Meat Inspection Act.

Not much has been heard since, though there has been a certain amount of correspondence.  Even the regulatory authorities didn't seem to have a united view.  On the 3rd June 2011, the Deputy Director of CFSAN, Donald Kraemer, stated on the FDA website "FDA considers any disease-causing strain of E. coli in food to be illegal”.  The FSIS deems only O157:H7 to be an adulterant.  Tellingly, Kraemer’s comment was removed from FDA website on 5th July 2011.

The new declaration is being hailed as a victory.  Elisabeth Hagen, head of food safety at the Department of Agriculture, said that this was "one of the biggest steps forward in the protection of the beef supply in some time.  We’re doing this to prevent illness and to save lives.”  A worthy cause.

However, I have some concerns about this optimism.  Will the reclassification of the Big Six make meat safer?  I'm not so sure.  Certainly, if these bacteria are detected in meat, the product will not be allowed on the market unless it is diverted to cooked products.  This may be a challenge for the meat processors - since 1994, O157:H7 in raw ground beef has been declared an adulterant with zero tolerance by FSIS.  In October 2007, the Topps Meat Company recalled 21.7 million pounds of ground beef, bringing the total recalls in the US between April and October 2007 to over 30 million pounds of red meat, mostly hamburger.  A company manufacturing frozen hamburger patties is unlikely to have the capacity to redirect this much meat to a cooking process and there may be difficulties in finding a buyer for the product, so it may have to be destroyed.

Secondly, as far as I am aware, there is no requirement for processors to test for these bacteria.  If this situation doesn't change, the first indication that something is wrong may still be when people start showing up at the hospital with gastrointestinal disease.

Thirdly, the cost of testing is currently very high and the testing may take up to 5 days, even when things go well.  I have already written about the impossibility of guaranteeing safe food by testing.

Finally, testing for the Big Seven will miss any Shigatoxin-producing non-members, as was the case with the German outbreak of O104:H4

The FSIS move is a good start and is motivated by good reasons.  However, the only way that safety of food can be improved is by development of risk management plans and rigorous application of critical control points throughout the food chain, including food service outlets, i.e. farm to fork.  Consumers should not receive contaminated food, but they too must play their part by prevention of cross contamination in the home and proper cooking of foods.  Future posts will deal with some of these approaches.

Where does that leave us with foods like sprouts?  Food for thought.

Since I wrote this article, Shawn Stevens has written an article "Big six declared Adulterants: Is it a good thing?" in Meatingplace.com, a blog for the meat industry in the US.  It seems that he too has some concerns. You may have to register to read the article, but registration is free.