US: Changes to FSIS traceback and recall policy
Posted: June 26th, 2012 - 10:21am
In a move that was expected and welcomed by many, FSIS announced in the Federal Register (FR) on May 7, 2012, its proposed new procedures that FSIS would implement when it finds raw ground beef to be presumptive positivefor E coli O157:H7.
The entirety of the 8 page document that outlines the public meeting and comment process in great detail can be seen here.
What I found most interesting in the FR announcement were some numbers, and that is why I picked this topic for today. I was also reminded of a previous misconception I had held up as the truth when I was at the USDA and in a position to make the move that Undersecretary Hagen has now made.
I was advised that a traceback effort for a positive ground beef sample would most likely be futile because so much of the product was blended from multiple sources.
This announcement points out that in a two year period between January 1, 2009, and December 31, 2010, there were 65 Agency samples of ground beef that tested positive for E. coli O157H7.
Of those positives, 41, or 63 percent “were taken from production lots created using source material from a sole supplier.”
Some of the suppliers of the source material may not have split lots, and therefore no recall would be requested.
But if the supplier or downstream users split the implicated lot before sending it to the establishment where the positive sample was found , then FSIS intends to request a recall from the slaughter or trim supplier establishment as the source materials sent to other end users would be considered adulterated.
There are multiple steps involved as explained and expanded upon in the announcement, but the main point I want to highlight is that if a lot was split, and more than one end user (grinder) was the recipient, then it makes perfect sense to try and get the rest of that lot out of circulation, a critical step that has been missing until now.
Lives will be saved. Will one of them be your grandchild or mine? We will never know. That is the world of public health that Dr. Hagen operates in.
By reading the comment sections in the FR announcement, one can clearly see that some in industry are opposed to this move, basically claiming double jeopardy since the product has already been sampled, tested and found negative for E. coli O157:H7.
I would remind industry that after Pink Slime, beef is under attack. Help FSIS make the consumption of your product as safe as it can be.
You know, and I know, that testing is intended to provide evidence that HACCP measures are in place and are effective in addressing the pathogen.
Testing does not provide proof that the labeled beef trim is free of E.coli O157:H7. Please stop implying that it does.