The USDA “E. coli loophole” in Ground Beef: Much Ado About Nothing

Washington, DC, November 28, 2007 -- Over the past few weeks there has been a flurry of articles about a seemingly diabolical plan between the meat industry and the USDA that permits presumptively positive ground beef and beef trimmings that have failed to be “non-negative” for E. coli O157:H7 (http://www.ehagroup.com/epidemiology/illnesses/e-coli-O157-H7.asp) to be sent for further processing—which includes cooking to the thermal death stage for all pathogens. 

“It is inconceivable to me how this story has gotten as much traction as it has,” says Melvin N. Kramer, Ph.D., M.P.H., president of a prominent public health consulting group (http://www.ehagroup.com/publichealth/). 

According to Dr. Kramer, the focus of all food safety programs and educational campaigns regarding raw proteinaceous foods (poultry, beef, pork and even fish and shellfish) is proper cooking.  Cooking to a thermal death level will kill all harmful or pathogenic bacteria, such as E. coli, salmonella, campylobacter and other pathogens that may be present in these raw foods of animal origin that were never intended to be consumed raw or undercooked. 

Therefore, permitting a company that suspects or, in fact, knows that a lot of ground beef or beef trimmings has or may contain E. coli O157:H7 to be able to sell it with appropriate security (at a significant discount) to a different segment of the industry that is under USDA inspection and scrutiny to properly process this product into a ready-to-eat product not only makes perfect sense microbiologically, but it has zero impact on the public’s health.  As part of the mandatory HACCP program of these “processing or cooking establishments”—they will be processed at a high enough temperature to kill any and all of the E. coli O157:H7 organisms that may be present. 

The recent articles go on to enumerate that some of these products may include “precooked hamburgers, meatloaf, meatballs, crumbled taco meat and other products.”  An author of one of these articles—from the Chicago Tribune—noted: “There is no evidence that ‘cook only’ meat has directly sickened consumers.”  Dr. Kramer agrees: “I was pleased to read that.  I would add that there is no inferential evidence that any of these products have been involved in any foodborne illnesses.” 

Many processors that cook meat, as a matter of policy, choose not to purchase any products that test not negative for E. coli O157:H7 and, in fact, require a certificate of analysis showing the negative result.  This is purely at the discretion of the individual company.  However, Dr. Kramer states, “The circulation of these articles only serve to undermine the good work that is being done by the beef industry—particularly, at the slaughterhouse level—utilizing numerous interventions to reduce and eliminate E. coli O157:H7, followed by microbiological testing for product destined for raw hamburger meat, which is serving as a model for other food commodities.”  He goes on to explain, “That is not to say that there is a zero risk that a consumer will get raw hamburger meat that does contain E. coli O157:H7 and, although, according to USDA regulation, that product is adulterated, the consumer has the responsibility also to cook the product thoroughly to 160oF minimally, wash their hands, and not cross-contaminate between raw beef and ready-to-eat foods—whether via hands, cutting boards, plates or utensils.” 

Food safety is clearly a partnership, one that is getting stronger from the farm to the fork.  However, all segments—including consumers—must do their part.  Worrying about whether or not your pre-cooked hamburger or meatball at one time contained E. coli is meaningless.  Utilizing a food thermometer to validate your cooking temperatures for all protein foods, as well as constant handwashing and avoidance of cross-contamination between raw and ready-to-eat foods is much more appropriate for the ultimate goal the CDC has set out for all people in their Healthy People 2010 (http://www.healthypeople.gov/) guidelines.