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Marler Blog Providing Commentary on Food Poisoning Outbreaks & Litigation

This is like Déjà Gouda E. coli again

“This is like déjà vu all over again” by Yogi Berra is what I was thinking as a read the below article from the REVUE CANADIENNE DE SANTÉ PUBLIQUE as I was researching the FDA’s “60 day rule.”

An Outbreak of E. coli O157:H7 Hemorrhagic Colitis Associated with Unpasteurized Gouda Cheese

Yogi Berra.jpgLance Honish, BSc, Gerry Predy, MD, Nyall Hislop, BSc, Linda Chui, MSc, Kinga Kowalewska-Grochowska, MD, Larry Trottier, BSc, Cornelia Kreplin, DVM, Ingrid Zazulak, CPHI(C)

Background: A cluster of E. coli O157:H7 hemorrhagic colitis was identified in metro Edmonton, Alberta through notifiable disease surveillance in late 2002.

Methods: Environmental health officers collected food histories and clinical information from cases in the cluster. The provincial public health laboratory conducted pulsed field gel electrophoresis (PFGE) analysis on E. coli O157:H7 isolates from cluster cases. Public health and food regulatory agencies conducted an investigation when a food source (unpasteurized gouda cheese) was implicated.

Screen shot 2010-11-28 at 4.55.41 PM.pngResults: PFGE analysis revealed an “outbreak” profile in 13 cases. Onset dates for the outbreak cases ranged between October 2002 and February 2003. Two cases, aged 22 months and 4 years, developed hemolytic uremic syndrome as a result of their infection. Consumption of unpasteurized Gouda cheese produced at a local dairy farm was reported by 12 of 13 outbreak cases in the 2 to 8 days prior to illness. E. coli O157:H7 was isolated from 2 of 26 cheese samples manufactured by the implicated producer. The cheese isolates had indistinguishable PFGE profiles as compared with outbreak case isolates. Implicated cheese was found to be contaminated with E. coli O157:H7 104 days after production, despite having met regulated microbiological and aging requirements.

Conclusion: To our knowledge, this is the first confirmed outbreak of E. coli O157:H7 infection in Canada associated with raw milk hard cheese. A review of federal legislation vis-à-vis raw milk hard cheese may be in order.

It is going to make it a bit hard for Bravo to complain that the recent E. coli O157:H7 outbreak was something that could not be anticipated. And, in this 2002-2003 outbreak the Gouda had aged 104 days! Makes the FDA’s “60 day rule” seem more than a bit beside the point.

  • John Munsell

    Is there reliable, independent, 3rd party validation of the cheese makers’ claims that they are indeed aging products for 60 or 104 days? My guess is “NO”.
    Consumers continue to pay the price for our government’s systemic deregulation of food production. Does FDA “inspect” (that’s a misnomer) cheese faciltiies once every 5 – 10 years, then blithely issue a brief report stating that all is in order?
    Reminds me of USDA/FSIS findings at the ConAgra plant in Greeley, CO in July 2002, subsequent to ConAgra’s recall of 19.1 million lbs of ground beef potentially contaminated with E.coli. Because of the investigation, the agency had its first opportunity to review results of ConAgra’s in-house testing of ground beef. Agency investigators reviewed ConAgra’s internal test results from the previous 100 days. According to the local Greeley Tribune, investigators discovered that ConAgra had experienced 34 days (out of 100) in which their own in-house testing revealed E,Coli-contaminated meat. Well, what corrective actions did ConAgra implement on those 34 days to prevent recurrences? If there were ANY corrective actions, they were obviously inadequate.
    A 34% positive rate for E.coli 0157:H7 should be cause for concern. Obviously not, in a deregulated environment in which government oversight is woefully missing. FDA is certainly not unique in their ignorance of obvious problems: USDA is likewise ignorant, by intentional agency design, a gift of “USDA-style HACCP” which has removed police authority from the agency, with official agency endorsement.
    Unfortunately for Gouda manufacturers, they can’t accuse consumers of not cooking the cheese to 160 degrees, the ubiquitous diversionary tactic used by the large meat packers (and their associations) to transfer responsibility to consumers while insulating the source slaughter meat plants from accountability.
    John Munsell

  • Gabrielle Meunier

    Bill, good for you. Must be a great feeling to get a lead like this.

  • Bill Anderson

    I would not characterize Gouda as a “hard cheese.”
    Gouda that is dry-cured for 2+ years can become quite hard. It is delicious too, if it is made with good milk and good cultures.
    But most mass-produced gouda is a moderately high-moisture and high-pH cheese. Like this one you are talking about.
    Again, Bill, your focus on the 60 day rule is misguided. That is not the issue. The issue is the quality of the milk (which is a direct result of the dairy farming practices) and the soundness of the cheese making process.
    Obviously this cheesemaker was using poor quality milk.
    I don’t think there is “de-regulation” of the food system at all. I think there is corporatization of the food system. As the regulation of small processors increases, so does the power and money of the large corporate agri-businesses to influence FDA priorities.

  • Adam Shearer

    Uhh, it says “unpasteurized” right in the description, shouldn’t that be enough warning that it’s potentially dangerous? No sane person eats unpasteurized dairy products thinking they’re 100% safe. Move along people, nothing to see here.

  • I would not characterize my focus on the 60 day rule as misguided at all. Frankly, I really do not care if it’s 42 days or 94.5 days. I just want these people to make a safe product. It does seem, however, that the 60 day rule has been used as a guideline for a presumption of safety that retailers and consumers have been incorrectly relying on. I do not have a preordained thought on the number of days it takes to make safer cheese, but 60 days does not seem to be cutting it. Or, as you point out it is not the days that matter it is the inputs and the care taken to produce a safe product.

  • Bill Anderson

    FDA will never admit that “it is not the days that matter it is the inputs and the care taken to produce a safe product”, because this would fly directly in the face of established Federal Dairy policy — “Milk is Milk” all milk is the same and there is no point in distinguishing between the CAFO rBGH milk for pasteurization and the grass grazed milk of sustainable family farms.
    These guys control Federal Dairy Policy, FDA, NCIMS, FMMOS, etc..