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Marler Blog Providing Commentary on Food Poisoning Outbreaks & Litigation

FSIS Notice 05-09 MEASURES TO ADDRESS E. coli O157:H7 AT ESTABLISHMENT THAT RECEIVE, GRIND, OR OTHERWISE PROCESS RAW BEEF PRODUCTS

Now, that is a mouthful. It is a cold and rainy day in Seattle and I had some time to catch up on some of my reading and stumbled upon FSIS notice 05-09.  What was most fascinating was the honesty:

I. PURPOSE

E. coli O157:H7 is hazard that establishments that receive, grind, or otherwise process raw beef products need to address in their hazard analysis. FSIS is issuing this notice because the rate at which it is finding E. coli O157:H7 in product, and the recent recalls because of the pathogen’s presence, evidence that the measures employed by a number of establishments to address E. coli O157:H7 are inadequate.

However, what is most concerning is the acceptance that there is little to be done by inspection:

II. INADEQUATE MEASURES TO ADDRESS E. coli O157:H7

An establishment that receives, grinds, or otherwise processes raw beef products cannot conclude that E. coli O157:H7 is not reasonably likely to occur in its production process because the product it receives bears the mark of inspection. The mark of inspection is a reflection of a finding made by FSIS personnel that the establishment has followed the validated procedures in its HACCP plan, not that the pathogen has been eliminated or reduced to undetectable levels.

OK, so here is a thought – don’t you think that all food should not have material (shit) in it that can sicken or poison you?   Why don’t we simply use the language of the Federal Meat Inspection Act and say, if a meat product has something in it that can sicken or kill you it is adulterated? See below:

SUBCHAPTER I – INSPECTION REQUIREMENTS; ADULTERATION AND MISBRANDING

§601. Definitions….

As used in this chapter, except as otherwise specified, the following terms shall have the meanings stated below: …

(m) The term ”adulterated” shall apply to any carcass, part thereof, meat or meat food product under one or more of the following circumstances:

(1) if it bears or contains any poisonous or deleterious substance which may render it injurious to health; but in case the substance is not an added substance, such article shall not be considered adulterated under this clause if the quantity of; …

(3) if it consists in whole or in part of any filthy, putrid, or decomposed substance or is for any other reason unsound, unhealthful, unwholesome, or otherwise unfit for human food;

(4) if it has been prepared, packed, or held under insanitary conditions whereby it may have become contaminated with filth, or whereby it may have been rendered injurious to health; …

(6) if its container is composed, in whole or in part, of any poisonous or deleterious substance which may render the contents injurious to health; …

So, let’s keep it simple.  Our food should not have shit in it.