To me, larger issues include FSIS's blithe disregard for the adverse implications associated with these other EHEC's. The mere decision to define all EHEC's as adulterants will accomplish nothing, unless FSIS develops the courage to address another larger issue which is to Force the Source to implement meaningful corrective actions. Let's be honest here: although FSIS piously proclaimed 0157:H7 to be an adulterant, the agency arduously circumvents tracebacks to the SOURCE, which is the originating slaugher plant.

FSIS made friends with consumer groups and public health officials when it declared 0157:H7 to be an adulterant. So what? What actions and policies has FSIS implemented to aggressively require corrective actions in the gate-to-plate meat continuum? The agency is perfectly comfortable with assessing all liability against the downstream further processing plant, retail meat market, or institutions where "Adulterated" meat is detected. Therefore, if your local Safeway meat department unwittingly sells E.coli-laced meat, and their consumers are sickened, you guessed it, Safeway is solely accountable. The same scenario plays itself out if patrons at your local Olive Garden or Sizzlers get sick, or clients at your local nursing home. E.coli and Salmonella are enteric bacteria, which by definition emanate from within animals' intestines, and proliferate on manure-covered hides. Well, Safeway, Olive Garden, Sizzlers, and nursing homes/hospitals/school cafeterias have no intestines or manure-covered hides on their premises. Nevertheless, when FSIS is left in charge of investigations, agency research starts and stops at the downstream destination facilities. FSIS monolithically resists tracebacks to the SOURCE of contamination. Why?

Please know that 88% of America's feedlot cattle are slaughtered at the Big 4 packers: (1) JBS-Swift (a Brazilian company), (2) Tyson, (3) Cargill, and (4) National Beef. These huge conglomerates, with multinational operations, enjoy enormous political clout. They also enjoy deep pockets, enabling them to legally challenge FSIS if the agency were ever stupid enough to attempt implementing meaningful corrective actions against any of these Big 4 packers. The Big 4 constitute a formidable litigation adversary, which the agency is loathe to challenge in court. In stark contrast, the smaller DESTINATION facilities lack political clout and the economic largesse to challenge the agency. Therefore, agency comfort is maximized by limiting its investigative work and enforcement actions against these feckless downstream destination facilities which innocently inherit meat which was previously contaminated with pathogens, which arrived at the downstream facilities in containers bearing the agency's official Mark of Inspection which states "Inspected & Passed". Strange as it may sound, FSIS inspects and passes E.coli.

I suggest that public health's primary enemy is NOT the label we place on pathogens (Adulterant versus Contaminant). Rather, the primary foe is the very government agency which claims it utilizes "An Abundance of Caution" to protect consumers from foodborne outbreaks, while it intentionally turns its back on the true SOURCE of unsafe food. Even if all the EHEC's were labeled "Poison", "Unfit for Human Consumption" or any deleterious label, the label has limited value as long as FSIS refuses to Force the Source to clean up its act.

Decades ago, the Great Lakes were greatly polluted. How were they cleaned up? By identifying the sources of harmful discharge into the Lakes, and requiring these sources to eliminate their harmful discharges. Our government did NOT solve this problem merely by mandating that all destinations (municipalities as an example) clean all water removed from the lake. Although municipalities do indeed operate water purification facilities, such facilities did not clean up the Great Lakes. History has proven in countless occasions that ongoing problems are only solved when the source is detected, and to subsequently Force the Source to implement corrective actions. When the NASA Shuttle disintegrated several years ago when re-entering earth's atmosphere, toxic debris was showered over several east Texas counties. If FSIS had been responsible for the ensuing investigation, FSIS would have concluded that the horrific accident was caused by inadequate air quality control standards in those east Texas counties because they allowed toxic debris to enter their air space. We would never claim that the accident would have been prevented if NASA had only previously declared that such toxic debris was considered to be "Adulterants". Terminology changes are not the answer! Rather, changes in FSIS attitude to (a) determine the SOURCE of pathogens, and (b) to Force the Source to clean up its act is the answer.

E.coli is NOT our ultimate enemy here! Our primary adversary is a government agency whose goal is to maximize its comfort level (don't challenge the Big 4), and to assess all liability against downline destination entities, which includes allegedly ignorant consumers who fail to fully cook pathogen-laced meat. Yes, we stupid consumers are the primary culprit here, as proven by FSIS's frequent reminders that we must use thermometers when cooking ground beef. Passing the buck didn't clean up the Great Lakes, nor prevent additional Shuttle disasters.

John W. Munsell, Manager
Foundation for Accountability in Regulatory Enforcement (FARE)
Miles City, MT

thank you,

Ken L.