Having owned and managed a USDA-inspected plant for seven years since HACCP's inception, and enduring a recall myself, I've heard numerous agency officials make the blame-shifting remark that consumers are responsible for sicknesses, caused by their inappropriate cooking methods, constituting self-infliction of pathogens. To a much lesser degree, I've heard industry representatives make the same comment. I've made few friends when I've suggested to the agency and industry that both should instead be proactively involved in improving production/inspection methods whereby we detect the true ORIGIN of contamination, implement unilateral corrective actions to prevent recurrences, and discontinue blaming consumers. If our primary goals are safe food and public health, we won't attempt to shift the blame onto these allegedly negligent consumers. Instead, we will place the blame on those portions of the industry where E.coli bacteria are INTRODUCED, which by definition is the slaughter plants since E.coli bacteria are enteric. When the Great Lakes were greatly contaminated decades ago, primary emphasis was not on municipalities to clean up someone else's contaminants, which admittedly was useful in the short term. Instead, the long term emphasis was to detect the SOURCES of pollution and require them to discontinue illegal discharges. While downstream consumers need to take actions to protect themselves, such as municipal water plants, future long term corrective actions which will guarantee improvements in public health imperatives require going back to the SOURCE of harmful discharges. The same is true of the meat industry, and especially with USDA which has been given a legislative mandate to protect the public from food-borne outbreaks. For the agency and the industry to place the ultimate responsibility on consumers is the height of irresponsible arrogance. HACCP's insulation of the large slaughter plants from accountability, while allowing USDA to embrace a semi-retired stance of meat non-inspection, circumvents the Federal Meat Inspection Act which initially mandated federal inspection. If for no other reason than public image, both USDA and the industry should totally blame themselves for the presence of contaminated meat in commerce.

Mr. Marler commented on meat thermometers. I've never used one when grilling ground beef, because instructions state the need to insert into the middle of the patties when cooking to ensure that the middle reaches an internal temperature of at least 160 degrees. I'm not confident that the tip of the thermometer would always reside in the middle of the thin patties (would work in a thick steak), and that the tip would occasionally go entirely through the patty and be exposed to direct heat from the gas grille, producing an inaccurate reading. Today (Fathers' Day), extended family joined us for a hamburger barbecue, and I cooked eleven patties on our grille. What is the chance I would have correctly implanted the thermometer exactly into the middle of those eleven patties and obtained precisely correct readings? Also: my grille is blasted hot, minimizing the time I have available for personal research on the wholesomeness of those eleven patties which I purchased in a box which was proudly emblazoned with the official USDA Mark of Inspection? Yup, some folks conclude that I am personally responsible for contamination which the slaughter plants INTRODUCED into meat I cooked for my family. Thermometers should not be required, nor is their use practical. Previously, I enjoyed rare ground beef. I no longer have the confidence to cook ground beef in this fashion: not because I have failed as a consumer, but because the slaughter plants have been failing..........as is being proven by these multiple recurring recalls thus far in 2007. As of June 3 this year, the number of E.coli recalls have already matched the total number compiled in all of 2006. This isn't progress.

One last thought: the NCBA published "America's Favorite Beef Recipes" cookbook in 1998. The following statements are found on page 6. "First, the wholesomeness of our meat supply is ENSURED (emphasis added) by meat inspection conducted by the U.S. Department of Agriculture (USDA). All meat that is sold must, by law, pass inspection. INSPECTION PROVIDES ASSURANCE THAT ALL MEAT SOLD IS WHOLESOME AND ACCURATELY LABELED". (Emphasis added). I challenge everyone to find a similar guarantee, either by the agency, industry, or industry association like NCBA since 1998. I don't think it exists, because the statement would now be correctly construed as blatant misrepresentation.

While my personal perception is that we will never force ground beef labeling to state that its consumption could be hazardous to one's health, I nevertheless acknowledge that labeling meat with the official USDA Mark of Inspection is not justified, and should be discontinued. Instead, all meat should merely be labeled as having been produced under the HACCP umbrella, which is at least one galaxy away from ensuring wholesomeness.

John W. Munsell
Manager, Foundation for Accountability in Regulatory Enforcement (FARE)
Miles City, MT
June 17, 2007 Fathers' Day

With regard to labeling, the alcohol industry was forced to put an ominous label on their products. Why shouldn't the meat (or the food) industry have to do the same? I haven't checked the sales figures but this label doesn't seem to have affect alcohol sales much and people have to eat but consuming alcohol is optional.

-WEH
Seattle