# Presentation: 196866

## 
Daniel Engeljohn 
USDA, FSIS
May 7, 2001

**Daniel Engeljohn **
**USDA, FSIS**
**May 7, 2001**

**National Advisory Committee on**** Microbiological Criteria for Foods****_________________**** Blade Tenderized, Non-Intact Beef ****and**** *****Escherichia coli *****O157:H7**

**Notes:**
All current FSIS policy documents, including proposed and final regulations, are available at the FSIS website at:
www.fsis.usda.gov/oppde/rdad/publications.htm

The FSIS docket room is open to the public Monday through Friday, 8:30am to 4:30pm.  The docket room contains copies of current proposed and final regulations and associated public comments.  The location is:
300 12th Street, S.W., Room 102, Washington, DC  20250-3700

Questions regarding FSIS proposed and final regulations should be directed to the Regulations and Directives Development Staff at:
300 12th Street, S.W., Room 112, Washington, DC  20250-3700
Phone:  202-720-5627
Fax:  202-690-0486
E-Mail:  FSIS.regulations@usda.gov

## Background on the Issue

**1994**
** ****FSIS declares *****E. coli *****O157:H7 to be an adulterant in raw ground beef**
**1997**
** ****Subcommittee, NACMCF, gives recommendations for cooking temperatures for intact beef**
** ****Subcommittee gives further recommendations regarding non-intact beef**

**Background on the Issue**

**Notes:**
 In 1994, FSIS notified the public that raw ground beef products contaminated with E. coli O157:H7 are adulterated within the meaning of the FMIA unless the ground beef is further processed to destroy this pathogen:
 Raw ground beef products present a significant public health risk because:
 They are frequently consumed after preparation (e.g., cooking hamburger to a rare or medium rare state) that does not destroy E. coli O157:H7 organisms that have been introduced below the product’s surface by chopping or grinding (64 FR 2803-2804, January 19, 1999--attachment “A” in packet).

 In 1997, FDA requested recommendations, for use in the 1999 Food Code, on appropriate cooking temperatures for intact beef steaks for the control of vegetative enteric pathogens.  The definition of “intact beef steak” was limited to “[a] cut of whole muscle(s) that has not been injected, mechanically tenderized, or reconstructed.”  On the issue of non-intact beef steaks, the Meat and Poultry Subcommittee of NACMCF stated that there is a lack of scientific and/or epidemiologic data to identify any hazard associated with these processes that may compromise the integrity of the surface of the meat and may allow penetration of microbial pathogens to the interior, e.g., mechanical tenderization, penetrating marination (I.e., non-intact beef steaks).  The Subcommittee also recommends that as new research data becomes available, the current recommended cooking time and temperatures should be reviewed for continued public health safety (from the NACMCF discussion adopted November 20, 1997--attachment “C” in packet).  

## Background on the Issue (continued)

**1999**
** ****FSIS issues policy on beef products, including   **** non-intact beef steaks and **** roasts, contaminated with *****E. coli *****O157:H7**
** ****KSU presents findings of research on *****E. coli   ****** *****O157:H7 in blade tenderized beef steaks**** **
**2000**
** ****FSIS hosts a public meeting to discuss recent  **** developments regarding beef products   **** contaminated with *****E. coli *****O157:H7**

**Background on the Issue (continued)**

**Notes:**
 In 1999, FSIS published its policy regarding beef products contaminated with E. coli O157:H7, providing specific discussion on intact beef, non-intact beef, and intact cuts of beef that are to be further processed into non-intact cuts prior to distribution for consumption (64 FR 2804, January 19, 1999--attachment “A” in packet):
 Intact beef cuts of muscle include steaks, roasts, and other intact cuts (e.g., briskets, stew beef, and beef “cubes for stew,” as well as thin-sliced strips of beef for stir-frying) in which the meat interior remains protected from pathogens migrating below the exterior surface. 
 Non-intact beef includes:  beef that has been injected with solutions; mechanically tenderized by needling, cubing, Frenching, or pounding devices; or reconstructed into formed entrees.  In addition, non-intact beef includes those beef products in which pathogens may be introduced below the surface by a comminution process such as chopping, grinding, flaking, or mincing.
 Intact cuts of beef that are to be further processed into non-intact cuts prior to distribution for consumption must be treated in the same manner as non-intact cuts of beef since pathogens may be introduced below the surface of these products when they are further processed into non-intact products.  Manufacturing trimmings are an example of this type of product.  
 FSIS believes that with the exception of beef products that are intact cuts of muscle that are to be distributed for consumption as intact cuts, an E. coli O157:H7-contaminated beef product must not be distributed until it has been processed into a ready-to-eat product (I.e., a product that may be consumed safely without any further cooking or other preparation).
 The 1999 KSU dissertation stated that the blade tenderization process they used transfers 3-4 % of surface contamination to the interior of the muscle.  The author concludes that the blade tenderization process was found not to significantly affect the safety of beef steaks when cooked to and internal temperature of 140 degrees Fahrenheit (60 degrees Celsius) and above.  In addition, the author did not find any significant differences in E. coli O157:H7 in intact and non-intact steaks using the oven broiling method at cooking temperatures ranging from rare (130 degrees Fahrenheit) to well done (170 degrees Fahrenheit).

## Background on the Issue (continued)

**2001**
** ****FSIS issues proposed rule on ready-to-eat products, including intact and non-intact beef steaks and roasts**** **
** ****FSIS seeks guidance from NACMCF regarding *****E. coli *****O157:H7 and blade-tenderized, non-intact beef**

**Background on the Issue (continued)**

**Notes:**
 FSIS traditionally has provided guidance to consumers on safe preparation and handling of meat, and the guidance has been more conservative than that which is provided to inspected establishments (I.e., or beef steaks, FSIS has provided consumers with a temperature of 145 degrees internal whereas the regulations require a specific lethality).  FSIS is interested in providing temperature and time combinations to consumers which have reasonable safety margins due to potentially less control than the inspected facilities.

 For the KSU study, the D values for E. coli O157:H7 seem much less than previously used for comminuted beef.

 The 1998 National Cattlemen’s Beef Association “Beef Steak Color Guide; Degrees of Doneness” identify very rare as approximately 130 degrees Fahrenheit (55 degrees Celsius); rare as approximately 140 degrees Fahrenheit (60 degrees Celsius); and medium rare as approximately 145 degrees Fahrenheit (63 degrees Celsius). 

## Background Documents

**Beef Products Contaminated with *****Escherichia coli *****O157:H7**
**(a.1) **_**FR Notice:  February 11, 2000**_
**Recent Developments Regarding Beef Products Contaminated with *****Escherichia coli *****O157:H7**
**(b) **_**KSU dissertation**_
***Escherichia coli *****O157:H7 Risk Assessment for Production and Cooking of Blade Tenderized Beef Steaks, 1999**

**Background Documents**

## Background Documents (continued)

** ****Recommended cooking temperatures for intact  **** beef steaks (November  21, 1997) **
**(d) **_**Food Code (1999) information**_
** ****Definition of whole-muscle, intact beef**
** ****Cooking procedure for whole-muscle, intact beef**
** ****Public Health Reasons:  Seared Steak**
**(e) **_**Proposed rule on ready-to-eat meat**_
** ****Performance Standards for the Production of Processed Meat and Poultry Products; Proposed Rule (February 2001)**

**Background Documents (continued)**

## FSIS Questions to NACMCF

** ****Is the available information on non-intact products adequate to answer the following questions ****(questions 2 and 3 below)?**
** **
**If not, are there any other reasons to conclude ****that the translocation of *****E. coli *****O157:H7 that ****occurs with blade tenderization or similar ****processes renders traditional cooking (very ****rare or rare) of these products inadequate to ****kill the pathogen?**

**FSIS Questions to NACMCF**

## FSIS Questions to NACMCF (continued)

**Do non-intact, blade tenderized beef steaks present a greater risk to consumers from *****E. coli *****O157:H7 compared to intact beef steaks if prepared similarly to intact beef steaks (very rare or rare)?**
** ****If yes, what should be the scientifically supported **** cooking process for safe ready-to-eat non-intact **** blade tenderized beef steaks?**
** ****If yes, should consumer cooking instructions differ **** from those for the industry (e.g., retail, **** institutions)? **
** ****If no, is the cooking process for intact beef steaks **** (very rare or rare) sufficient for non-intact, blade **** tenderized beef steaks?  **

**FSIS Questions to NACMCF (continued)**

##  If no, is the cooking process for intact beef roasts (very  rare or rare) sufficient for non-intact, blade tenderized  beef roasts?  

** ****Do non-intact, blade tenderized beef roasts present a greater risk to consumers from *****E. coli *****O157:H7 compared to intact beef roasts if prepared similarly to intact beef roasts (very rare or rare)?**
** ****If yes, what should be the scientifically supported **** cooking process for safe ready-to-eat non-intact blade **** tenderized beef roasts?**
** ****If yes, should consumer cooking instructions differ from **** those for the industry (e.g., retail, institutions)? **
** ****If no, is the cooking process for intact beef roasts (very **** rare or rare) sufficient for non-intact, blade tenderized **** beef roasts?**

**FSIS Questions to NACMCF (continued)**