During the past several months, some food safety critics, including a former Under Secretary for Food Safety, have chastised the meat industry and its trade association for raising strong concerns about the government’s inclination to declare certain non-O157:H7 shiga toxin-producingE. coli (nSTEC) as adulterants in ground beef. They say that such a position represents a callous disregard for the safety of the American public. One can only surmise that these critics’ charges stem from ignoring the facts surrounding the issue or a misguided belief that only the government can make food safe – or both. So let’s start by examining the facts.

Any reasonable analysis of the risk posed by nSTEC in ground beef shows a remarkably safe ground beef supply. A review of the Centers for Disease Control and Prevention’s (CDC) foodborne disease outbreak data shows that between 1998 and 2008, more than 2000 outbreaks involving thousands of individuals was caused by bacterial pathogens. A variety of foods and many different pathogens caused the outbreaks, but no outbreaks directly associated with nSTEC in ground beef were documented. While the CDC database has not been updated since 2008, we are aware of only one outbreak in 2010 involving three individuals that was associated with nSTEC in ground beef.

One concern often raised about these statistics is that the CDC database does not reflect the actual occurrence of nSTEC illnesses because public health laboratories do not routinely screen for nSTEC, even though they have been reportable diseases since 2000. CDC reports the number of illnesses caused by nSTEC has increased in recent years due to more screening and reporting. In fact, last year, approximately 5,000 human isolates ofE. coliO157:H7 and 5,000 isolates of nSTEC were submitted to CDC for analysis. If a public health crisis existed regarding nSTEC in ground beef, we would expect the most recent CDC data to show the emergence of a problem. It did not.

Even if you assume that there may be a crisis in the making that our public health agencies have not detected, management principles tell us that the first step in managing a crisis is to gather facts and define the scope of the problem. With that in mind, the US Department of Agriculture’s Food Safety and Inspection Service (FSIS) should publish a comprehensive assessment of the public health risks posed by nSTEC in ground beef for public review and comment. Publication of a public health risk assessment is needed to inform FSIS and the general public of the incidence of the potential hazard, the projected illness rate and severity of the disease, the estimated outbreak frequency and the capability of the government to effectively intervene before a costly new government program that is likely to yield little or no public health benefit is implemented.

The actual presence of nSTEC in ground beef and the factors that make these microorganisms capable of causing human disease are not well understood. Several studies have been conducted using various laboratory methods to determine the presence of the organism, but most of the studies have been unable to determine if the particular microbes and/or the combination of virulence factors detected will cause human illness. If a new regulatory initiative is to yield the maximum public health benefit, such a question needs to be answered.

Some observers in the US cite Europe’s recent outbreak attributed toE. coliO104:H4 in sprouts as a reason for FSIS to further regulate nSTEC in ground beef. They suggest that we must act before Americans are impacted. There are simple facts to keep in mind. The strain that impacted Europe has not been found in meat. In fact, it has not been found in any food in the United States.

Finally, it should be noted that the industry has and continues to fund research to determine ifE. coliO157:H7 prevention technologies currently used in US beef slaughter operations are also effective against nSTEC. Published research results and preliminary data from unpublished studies show that the existing microbial interventions and process controls employed today work equally well forE. coliO157:H7 and nSTEC. Our public health dollars must be allocated where they can make a difference. In the case of nSTEC, data show that our current food safety technologies stand as a defense against strains ofE. colithat have been identified as a possible public health concern.

Producing safe food for American consumers is the right thing to do ethically and it makes good business sense. The future of our industry depends on making products that are as safe as possible. Our goal is that no illness is associated with our products, and we will continue to work every day to achieve that goal.