FSIS’S DISTURBING RAW RED MEAT AND POULTRY HACCP - (1-28-2022)

"I hold it that a little rebellion now and then is a good thing, and as necessary in the political world as storms in the physical.”―?Thomas Jefferson

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HACCP is a preventive system for the production of safe food products. It’s based on technical and scientific principles applicable to every step of the food production chain, from growing/breeding activities to production and systems, to the moment the food reaches the final consumer – International Commission on Microbiological Specifications for Food (ICMSF) 1991.

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?FOCUSED PATHOGENS FOR FSIS RAW BEEF AND POULTRY HACCP

The Center for Control, Disease, and Prevention (CDC) recently offered on their website the top 4 pathogens (in order below) that cause illnesses from food consumed in the United States.

1.????Salmonella – CDC estimates salmonella causes 1.2 million illnesses, 23,000 hospitalizations and 450 deaths every year. Food was the culprit for about 1 million of these illnesses.

2.????Clostridium perfringens – C. perfringens is a spore-forming gram-positive bacterium that is found in many environmental sources as well as the of humans and animals. It is all too common on raw meat and poultry.

3.????Campylobacter – Campylobacter causes an estimated 1.3 million illnesses each year in the United States. Most illnesses occur due to eating undercooked poultry, or eating something that came in contact with undercooked poultry.

4.????Staphylococcus aureus – Staph food poisoning is an illness caused by eating food contaminated with produced by this pathogen.

Other selected pathogens don’t cause as many illnesses, but when they do, the illnesses can lead to hospitalization and death.

Escherichia coli?(E. coli) – Shiga toxin producing E. coli (STEC) are food-borne pathogens of zoonotic origin, which are responsible for a number of human illnesses - ranging from watery or bloody to the hemorrhagic and hemolytic uremic syndrome. While most outbreaks have been attributed to E. coli O157:H7, outbreaks associated with other serogroups including O26, O111, O103, O104, and O145 have been reported.

?E. coli O157:H7 and the six Non-O157:H7 Shiga-toxin STECS are the only declared adulterants - to date - by the USDA/Food Safety Inspection Service (FSIS).

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?PREFACE

“Ahh, Houston … snap/crackle/pop … crackle … we didn’t have a HACCP Gap in ‘69.”

When rock bands were churning out classics during the summer of ’69, George Orwell introduced Winston Smith to me at my local Torrance, California library – including those tyrannical Big Brothers at the Ministry of Truth.

That very same summer of ’69, the spinning world nearly stopped on its axis when Armstrong and Buzz bounced on the powdered-sugar surface of the Sea of Tranquility - each resembling the Pillsbury Doughboy with classic NASA/HACCP nourishment onboard their Eagle lunar module.

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INTRODUCTION - HACCP BACKGROUND SNAPSHOT

Everyone in the industry knows the story of the building blocks of HACCP that were developed for the Pillsbury Company that was led by Dr. Howard E. Bauman, a microbiologist from Minneapolis.

Dr. Bauman and his team are credited with developing ready-to-eat foods for NASA’s nascent manned space programs of the late 1950s and early1960s that cascaded to today’s HACCP.

Pillsbury’s HACCP ultimately defined and executed true preventive measures in the guise of critical control points (CCP’s) for space-bound foods/liquids.

Today, some 58 years later, FSIS has in place a highly regulated and politically critiqued HACCP system for a variety of raw meat (beef, poultry) not-ready-to-eat (nRTE) – as per §317.2(l) and 381.125(b)) - end products - that do not have a true CCP that is - a point, step, or procedure at which control(s) can be applied that will?consistently prevent/reduce/eliminate (PRE) virulent/targeted pathogens.

Raw meats are in reality, dependent on the credulous end consumer to safely handle (following safe handling instructions - blended with a #collop (#small piece of meat) of pragmatic common sense), and ultimately cook the raw meat at a heat and time ratio that will kill targeted pathogens - or better said - the end consumer applies a true CCP for the company that the raw meat was purchased from directly or indirectly.

?Not too science-based now is it – or - is it?

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?2022 FSIS RAW BEEF HACCP

Like countless others, I’ve developed from scratch -

Global Food Safety Initiative (GFSI) (BRC, SQF, FSSC 22000) programs

Agricultural Service (AMS) /USDA National School Lunch Programs (NSLP) technical proposals for raw/frozen trimmings/ground beef

AMS’ Export Programs

FSIS/FDA-FSMA HACCP

FSIS/FDA-FSMA SSOP's

FSIS/FDA-FSMA Prerequisite programs

FSIS’ Sanitation Performance Standards (SPS) and

FSIS/FDA-FSMA GMP themed programs for FSIS establishments (raw, NRTE and Ready To Eat (RTE)), including dissimilar FDA-FSMA- food/beverage/ pharmaceutical company’s starting in 1995 – and I’m still learning from my myriad errors - and that of others.

The HACCP systems that I’ve subjectively scripted (and GFSI audited) have been critiqued/audited by (other) GFSI accredited auditors, FSIS and their Notice of Intended Enforcement (NOIE) officers, state inspectors and - AMS, FDA-FSMA and city inspectors/auditors - that were ultimately declared the systems to be effective/verified/validated as intended – all supported by germane academia studies via in-house verifications and validations.

These HACCP systems, which are supportive by prerequisite/SSOP/GMP programs, have generated in their own individual and unique ways, safe foods/beverages for commerce - for the most part.?

For the most part - that is - the HACCP systems that contain a pathogen kill step in which controls can be applied to?consistently?PRE (prevent, reduce and/or eliminate - (last time!)) food safety hazards to an acceptable level - a true-blue CCP step that mimics Pillsbury’s 20th?century system.

Further establishments whose finished products are raw meats prior to final destination/shipment to commerce - have been -?for the most part, at the mercy of an invisible naked to the eye, needle in a haystack upstream harvesting (slaughtering) establishment that supplies them their boxed/binned, or a hooked raw meats (gasp) - with the always ubiquitous FSIS passed-mark-of-inspection and establishment numbered/lettered bug that’s clearly pre-printed on each and every container that’s delivered to refrigerated (Let’s hope) receiving docks of retailers.

Today, establishments that process non-intact and intact raw meat, play Russian raw meat roulette with virulent microscopic pathogens being represented as potential bullets in the guise of toxins.

One can apply any of the latest/conventional/multi-hurdle pathogenic interventions upstream in pre-harvesting (pre-slaughter) and harvesting (including multiple interventions that may be applied/performed by the many down-stream middle processors) that are available in 2022 and cannot still assert that the raw meat is pathogen free as FSIS has/is indelibly implying.

At this stage – thousands of raw meat HACCP systems - worldwide - some perched upstream and even more exponentially downstream – can potentially fail their systems intended CCP objectives - a - oh no - not again HACCP failure.

What is the most commonly utilized academia study cited nation/worldwide to support raw meat HACCP CCP's?

FSIS requires by 9 CFR law, that all meat establishments have at least 1 - (one) CCP in place and working as intended (hopefully).

The 99.999901…% majority of FSIS inspected raw meat middle processors (including upstream harvesting) involving raw intact and non-intact meats incorporate pathogen control of raw meats as their declared refrigerated/freezer CCP.

So does CCP (1-Biological) - cold temperatures meet the stated criterion of what FSIS constitutes as a CCP as highlighted above?

?No.

1P. Prevent(s) – Cold/frozen raw meat temperatures does not prevent the pathogen(s) that may already be present.

1R. Reduce(s) - Cold/frozen raw meat temperatures does not reduce the pathogen(s) that may already be present.

1E. Eliminate(s) – Cold/frozen raw meat temperatures does not eliminate the pathogen(s) that may already be present.

Classic rote.

Is FSIS’ raw HACCP science-based - or - politically science based?

Can the ever populated/bursting from the seams?Tompkin paper?be used to support an establishment's CCP for a storage temperature for raw meat of 45o F, or lower as per 9 CFR 417.5(a)(1) – as supporting documentation during validation?

Yes, so says FSIS’ Ask Karen as per verbatim of her quote that’s available in both English and Espa?ola on the FSIS website.

“The?Tompkin paper?can be used to support a storage temperature CCP for raw meat of 45o F. Although, the Tompkins paper cites specifically that 44.6 o F., as the temperature for minimum growth of the selected food-borne pathogens.

Establishments may maintain a storage temperature of up to 45 o F., because the growth rate of?salmonella?at 45 o F., is not significantly different from its growth rate at 44.6 o F. Furthermore, when temperatures are converted from Celsius to Fahrenheit, as in the Tompkin paper, numbers are often converted as fractions, which establishments may round to whole numbers because of practical measurement limitations of equipment in establishments.”

So, does all that shilly-shany from above, meet FSIS’ own CFR criterion of what a viable CCP must lawfully be?

No, certainly not.

Every middle processor HACCP systems that I’ve seen from 1995 to 2022 regarding raw and NRTE intact and non-intact meats cites the infamous and over-populated Tompkin’s Study regarding temperature control of raw meats.

Why not?

It’s easy, affordable, hassle-free, and a get out of regulatory card if there’s ever been one.

To be fair - most FSIS raw meat establishments (Harvesting and further processing) have prerequisite plans that are strategically layered within one's HACCP system to lend support (though separate!) of their CCP.

GRAS approved sanitizers (let's nickname it - “Killer Quat”) at prescribed PPM that’s recommended by the manufacturer, are sprayed evenly (let’s hope) onto the surface of both (selected) intact and all non-intact meat – at prescribed heat and time application duration.

During the recent FSIS requirement of several years ago concerning verification/validation studies of one's HACCP systems - establishments had to pick an academia study that matches Killer Quats ideal efficacy (time exposure, PPM, temperature, etc.) and describe what the microbial log reduction potentially/historically was attained.

However - know that under the perfect conditions of lab studies, the same results of attaining a certain log reduction amount does not always mean exact replication when placed into the real/actual working environments. Know too that even a 10-log reduction still leaves approximately 10% of microbes left to do their thing.

Another big problem opportunity that’s tap-rooted for Big Brother FSIS HACCP and their well-defined CCP’s – is that prerequisite program(s) both individually and/or collectively meets FSIS’s own definition of what constitutes a CCP (PRE) – much, much more than a stand-alone temperature control CCP does.

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“Quixotic at its very, very upper apogee apex, my dear Mister Watson."

’‘In-dee-ed, Mister Holmes! … (sounds of throat coughing/clearing/swallowing) – This is diametrically equivalent to USDA inspecting hooked, line and sinker Mississippi catfish - I dare saaay, Misster Sherlock!"

"Yes, ah, precisely, elementary my dear Mr. Watson, please, is the pure organic, gluten free 5th Downing Street tea not yet ready? I hear the hotty pot water whistling Dixie!’

"Yes, Mr. Holmes, I 'm adding a teaspoon of your favorite brown sugar imported from Kaui, right this very exact moment - I didn't want to miss the dramatic drum rolling poultry scene ..."

"Patience is a virtue, my dear Mr. Watson - We're nearly there..."

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Temperature control of 44.6 o F., or lower for raw red meat and 40.00 o F., or lower for raw poultry is what is commonly practiced today - worldwide.?

Question: But the melting pots of vituperative pathogens are not PRE at an acceptable level by temperature alone - now are they?

Answer: No. The powers to be at FSIS, from the very beginning - have used its procurement power, then legislating regulating options - and finally - its litigating powers regarding raw HACCP that we’re presently stuck with today.

But wait.

The USDA’s Agricultural Marketing Service (AMS) has had its HACCP raw products as the 'Right Stuff' since '02 - and every year thereafter regarding raw and cooked beef.

How’s that?

The AMS has had in place a Zero Tolerance Standard for all salmonella positives and pathogenic E. coli for the NSLP whose products are raw and frozen beef prior to their final shipment to other FSIS establishments north, south and east of Route 66.

There’s been zero salmonella and toxic E. coli related illnesses from school lunches from 2005 - 2014.

How draconian must AMS’ guidelines be for such sparkling results?

(Stage Whisper...) - They’re embarrassing their Big Brother - FSIS/USDA.

And that’s because of a true CCP (1-Biological) validated – a la ‘69s pure and unadulterated vintage year – thermal heat kill step(s) that’s charted onto histograms and control charts – compounded with assigned AMS inspectors (and FSIS inspectors) doing what they do best at harvesting - by performing their assigned jobs and rejecting salmonella and toxic emitting E. coli. tainted meat when detected and verified - via - a - la culture confirmation.

The?National Advisory Committee of Microbiological Criteria for Foods?(NACMCF) had recommended to the AMS 5 years ago that selected boneless beef trim and raw ground beef that was intended for further processing at FSIS inspected establishments (that has a scientifically validated CCP time/temperature cooking-to-ratio process in place), with AMS inspection in regular attendance including monthly verification audits by the Quality Assessment Division (QAD)) discontinue testing for?E. coli?O157:H7 and?salmonella.

This pragmatic Thomas Payne spin-off of ‘Common Sense’ - the loosening of the hangman’s non-compliance record regulatory rope - and the progressive NACMCF recommendations cited below, became a reality with the implementation of the AMS’ brilliant 3-phase initiative beginning back in 2014.

AMS’ HACCP trendsetter is being used as originally intended and the feds are (at least a branch of them) giving private industry space/autonomy they need which had been stated by top FSIS officials when raw meat HACCP was stillborn back in July ‘96.

Phase 1?– During the 2014 purchase season, fresh/raw boneless beef for further processing intended for fully cooked items was tested for only indicative organisms (standard plate count, generic?E. coli?and total coliforms) with no required testing of?E. coli?O157:H7 or salmonella?like years past.

Phase 2?– During 2015s purchase season, two - (2) types of categories were created involving specifically; coarse ground beef.

???Type 1?– Coarse ground beef that was intended for further processing into fully cooked items were only tested for indicative organisms.

???Type 2?- Coarse ground beef tested for pathogens (E. coli O157:H7; 6 NON-O157:H7 STECS and salmonella), including indicative organisms (total plate count, generic E. coli, total coliform) as done in years past.

Phase 3?– For the purchase season of 2016, boneless beef trim that was targeted in Type 1 (above) coarse ground beef for further processing intended for fully cooked items was only tested for indicator organisms. Boneless beef for Type 2 (above) coarse ground beef and all fine grind ground beef items would continue to be tested for?E. coli?O157:H7, 6-NONE O157:H7 STECS,?salmonella, and indicative organisms as previously before.

Listed below are notable, ‘three-year microbiological snapshots’ involving NSLP fresh boneless beef trimmings and raw ground beef products from the time period of July 2011 through June 2014 that was published in the?"Journal of Food Protection,"?(Sept.1, 2015).?

NSLP Boneless Beef and Ground Beef Totals: 2011 - 2014

???537,478,212 lbs. of fresh boneless beef were produced during this 3-year period.

???428,130,984 lbs. of raw ground beef were produced during the same 3-year period.

?NSLP Boneless Beef Samples: 2011 - 2014

# Samples tested: 230,359

???82 (0.04%) of the samples tested positive for E. coli O157:H7 – (Positive = automatic rejection)

???924 (0.40%) of the samples tested positive for salmonella – (Positive = automatic rejection)

???222 (0.10%) of the samples exceeded standard plate count limits – (100,000 CFU/g)

???69 (0.03%) of the samples exceeded generic E. coli limits – (500 CFU/g)

???123 (0.05%) of the samples exceeded total coliform limits - (1,000 CFU/g)

?NSLP Raw Ground Beef Samples: 2011 - 2014

# Samples tested: 46,527

???30 (0.06%) of the samples tested positive for E. coli O157:H7 – (Positive = automatic rejection)

???360 (0.77%) of the samples tested positive for Salmonella – (Positive = automatic rejection)

???20 (0.04%) of the samples exceeded standard plate count limits – (100,000 CFU/g)

???22 (0.05%) of the samples exceeded generic E. coli limits – (500 CFU/g)

???17 (0.04%) of the samples exceeded total coliform limits – (1,000 CFU/g)

Know that the unforgiving microbiological testing parameters involving NSLP products are not derived from the FSIS’ conventional/commercial N-60, 12-surface-piece composite sampling of each single combo bin consisting of 5 combo bins (of approximately 10,000 lbs.), rather - NSLP microbiological testing is exponentially and indelibly more rigorous?for raw boneless beef trimmings, raw coarse and fine grind ground beef products.

The AMS has effectively and cleverly forced feed/driven selected private raw meat establishments to examine and re-examine again, again and again, every solitary phase of their pre-harvesting (delivery, humane care in the corrals) and harvesting operations.

What a paradigm shift this truly is for raw meats.

Good meat isn't cheap - and - cheap meat isn't good.

The AMS requires a validated 3-log reduction of indicator organisms of the entire harvesting continuum, as well as exposing – bare nakedly - the efficacy or inefficacy of their vital/essential sanitation department - as well as - those oh-too-important employee training programs – that’s contained within a nurtured and well documented robust food safety culture that’s all bottled into one remarkable (nearly) hermetically sealed glass jar.

By performing auditing/private consulting and being the HACCP coordinator/AMS technical proposal contributor for 6 long, long years (while riding the blood-spattered coattails of hard working blue-chip production, sanitation and maintenance employees), at vertically integrated pre-harvest, harvest, further processing operations - that were deemed qualified to manufacture and proffer NSLP excellent conditioned raw and frozen beef contracts for - our young trusting/naive ones - I can subjectively say - wow to the AMS way. (Thanks to Steve and Sue Olson creative keyboards - now retired.)

Conversely, I know of selected FSIS establishments that have failed with their attempt(s) to supply NSLP raw beef because their microbiological results (exceeding indicative organisms levels and/or pathogenic bacterium detections) couldn’t meet the outwardly and seemingly draconian ISO themed standards of safety (and quality standards - fat %, etc.) set into place by the clever and sublime folks employed at the AMS.

Finally, some may not know that the folks at the AMS have had in place the option of irradiating raw and frozen non-intact meat for the NSLP since 2003 – some 16 years ago.

What about raw poultry?

Hold on, this is a rough, tough and expensive one.

2019 FSIS RAW POULTRY HACCP

When consumers purchase raw chicken at their local grocery store, they see a package reading – ‘Inspected and Passed by USDA Est. P-000.’

So tell me, are consumers reading the safe handling instructions besides the trendy and often misleading labeling such as - - - no steroids ever (despite steroids never ever being allowed ever since Noah's biblical flood), all natural, GMO-free, gluten-free, organically raised, free-range (gasp) labeling declarations?

Yes and no.

Are consumers misinformed and a bit mixed up by today’s (approved by you know who) imaginative labeling as well as food safety?

Yes, they are.

?I am 2.

As pointed out at the get-go -?salmonellosis?is a common cause of food-borne diseases in the industrialized world. Selected zoonotic infections are often transmitted from healthy carrier animals to humans via contaminated foods. The reservoir of zoonotic?salmonella?is food animals with the main sources of such infections derived from raw meat and eggs.

As one of many examples to choose from regarding pathogenic strains of salmonella and poultry - lets dial back to 2012.

The CDC?documented?600 individuals infected across 29 states with a virulent strain of?salmonella. Investigations pointed to?Foster Farms, the sixth largest chicken producer in the U.S. as the likely source. Upon USDA investigation, they found 25% of the chicken sampled was?contaminated?with the outbreak strain of?salmonella.

The European Union meat industry has many of the same problems as the states do. However, by considering performances/results of selected pro-active EU countries like Denmark and?especially Sweden's..................

Back in the states,?don’t lose sight that salmonella?causes more hospitalizations/deaths than any other food-borne illness.?

Starting at the poultry hatcheries, farms, transporting of live fowl to the harvesting establishments - those specific areas need to be cleaned and sanitized much, much more than there are today. I know of this because I’ve seen my share of free-range and caged poultry farms, chicken transports and poultry harvesting operations during my - 'Traveling Wilbury tours' of days gone past.

Studies and work performed in selected EU countries and in the states have shown that a good % of where the pathogens originate R at the top of the pre-harvesting chain as the surviving/mutating pathogens begin cascading downwards onto customer’s grills and dinner plates.

The poultry industry needs some major overhauling and very expensive investments that will be effective and truncate even more of those ever growing and mutating pathogenic microbes. The poultry folks have made some great progress reducing pathogens over the years, but much, much more needs to still be done - and they all darn well know it.

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2022 FSIS HACCP SUGGESTIONS

Are current FSIS regulations involving raw poultry/beef HACCP systems and other applicable regulations/programs shared within the FSIS regulatory tome -?"Strategic Plan for 2017-2021"?– selectively flawed?

Yes – selectively - when it comes to attaining true and unadulterated raw meat HACCP.

Where’s the beef and chic-de-filet in the 2017-2021 Strategic Plan?

Let your own fingers do the walking on the www and double-clip the 2017 - 2021 Strategic Plan above and see for yourself.

1, 2, 3, Fire!

FSIS needs to regulate in the 21st century and declare -

Salmonella Enteritidis,

Newport,

And, Typhimurium as poultry/turkey adulterants like they did the seven (7) toxic strains of E. coli referenced earlier.

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"No....................! My Stars - God Save The Queen, Mr. Holmes! What an exquisite, aplomb and indelibly Braveheart deduction..."

"Mr. Watson, such a - - - Hey, do you want a Revolution declaration - - - in time, would be one giant leap for raw meat, and one small step forward in the right direction for the deflating FSIS style raw HACCP - including its ultimate end consumers - on - I dare quip - a global scale."

"Mr. Wattttson, have you seen my faithful Toby sniffing around? That bloody loyal royal blue-blooded bloodhound is turning Vegan on me, Watson! I caught that hound pup earlier this morning munching on my FedEx delivered FDA regulated 99.11% organic romaine lettuce freshly imported from Central California."

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Regardless of the above - pathogens will continue to be detected, product recalls will continue to be made (regulatory forced?) and the health of the end consumer will continue to be at risk, because *most of today’s ‘science-based’ conventional interventions for raw meats have shown not to be?faithful FSIS themed CCP’s – include too - the consumers who mis-handle and/or undercooks their raw meats.

FSIS’ raw meat HACCP is simply not a bona fide HACCP system as its been touted to be by the FSIS from the Ministry of Truth since the publication of the Mega Reg on Jul. 25, 1996.

The majority of past/present raw meat recalls (including undercooked nRTE, RTE meat recalls) resulting with acute/chronic illnesses and related deaths substantiate this.

A glance at the most recent raw turkey debacle presently going on involving 49 people ill and one dead with the culprit being – once again toxic strains of salmonella being the culprit.

One of 2 many – once again - another unwanted curtain call encore.

The FSIS has cockeyed raw meat HACCP with selected results not unlike Apollo 1 and 13 - driven to a measurable degree by Big Domestic/International Meat Corp$ and their lobbying Bureaucrat$ - that no one seems to ever want to scribble about.

You better believe it – T.J. Billy Boy Bully?- (Thanks, Mr. Munsell (John)).

By FSIS declaring the three stated virulent strains of salmonella (among the others) as adulterants the co$t to private business (chicken/turkey coops on down) shall equate to lots and lots and lots of money to get their act together like selected EU companies have already accomplished.

Is this why, among other reasons, zero toxic strains of salmonella have not yet been declared as an adulterant by FSIS?

$?

Too - omnipresent?

Does the Washington DC swamp include selected areas of FSIS/USDA?

I know of selected FSIS inspected establishments having their Grant of Inspection withheld for good by FSIS because their plant received tainted/adulterated meats from their upstream supplier(s) that was not detected until it hit them - or worse yet - in commerce – all resulting with Big Brother jumping on their regulatory John Wayne tinted bandwagons – fully equipped with their shiny and recently polished Deputy badges including their traditional black J. Edgar Hoover high -collared trench coats - fully loaded with regulatory iron fists and keyboards.

I know oh too personally firsthand, just how federal colonoscopies can be and feel like – even 11 years later.

It’s usually a nightmare - in line with a dreary Charles Dickson novel – at best.

For one transparent example of past federal enforcement actions by FSIS - www - Food Safety News and place an enlivening-to-B search for John Munsell.

There are several articles that’ll pop up on your silver screen that’s authored by Mr. (articulate) Munsell describing/detailing his once upon a time multi-generational family owned FSIS inspected meat establishment that was destroyed by invisible O157:H7 pathogens and FSIS actions and inactions - via a regulatory sledgehammer in the likes of King Henry VIII and an ex-wife named Ann Boylen.

It’s an amazing and frustrating story. For Mr. Munsell’s most recent article in Food Safety News of Feb.13, 2019 concerning portions of the contents of this blog - tap here.

It’ll be well worth your time to view this Meat Mavericks story – if you haven’t already.

Promise.

I’m afraid that Mr. Munsell will have a sour taste for his remaining years (me too). And I thought good things happen to good, honest, hardworking responsible people. Not always here, there, or anywhere.

*There are several pathogenic intervention technologies - High-Pressure Processing (HPP) and Irradiation that are in use by selected FSIS establishments and the EU. I’ve consulted and reviewed GFSI HACCP systems with HPP at several USDA establishments and spent some “enlightening” time at Iowa State University where an electron beam was utilized for the irradiation of meats, seafood, and vegetables back in 1998.

They work.

With either one of these two technologies put into place at a raw meat establishment, it would allow all of us to sleep better at night.

But the majority of raw meat plants don’t/can’t incorporate these verified/validated higher than high log-reduction technologies for a number of practical and fully understandable reasons - time, location, costs, packaging availability, etc.

?Lets wrap up this triathlon with the end consumer responsibilities.

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2022 **END CONSUMER RESPONSIBILITIES

A FDA study revealed that 46 percent of consumers surveyed showed that they’ve never used a meat thermometer when cooking chicken parts, while 66 percent said they never used one when grilling hamburgers.

Worse yet, RTI International, Tennessee State University and Kansas State University collectively performed another similar study that was published back in Jan. 2015, which evinced that less than two-thirds of consumers questioned owned a food thermometer and that less than 10 percent of those actually used a thermometer to check the internal temperature of the poultry that they were preparing.?

What’s missing here?

?Hello.

Measuring the internal temperature of raw meats during cooking as recommended by the USDA is surely prudent. It’s one of the last lines of defense (along with avoiding mishandling and cross-contamination before, during and after proper cooking/grilling) of the farm to fork safety continuum.

?Is private industry/GFSI/FSIS/FDA – all the top players - expecting too much of the consumer to properly use a thermometer when grilling? Look what keeps going happening with raw milk outbreaks and consumers (children) becoming ill. How about parents withholding vaccination shots?

**Historical data then, says more yes than more no.

However, if you had a loved one become a handy-capable for life or died of a related beef or poultry virulent pathogen - we all know what your answer would more than likely be.

?CONCLUSION

Point ‘69 towards your smoke and mirrors mirror - and keep wishing you’ll see ‘69 reflecting back to you – not the opaque-screened twenty-first century ’96 version of Big Brother raw meat HACCP that today's meat industry and its trusting/innocent consumers - are presently destined to fumble and juggle with - until perhaps - Homo sapiens walk on the sub-zero surface of the ex-planet, Pluto.

And finally. Will the continuing multiple industry woes (greenhouse gas effects (real or imagined), continued pathogen-related recalls/sickness/deaths, sly labeling practices, immigration employment woes, EPA air, land, water concerns; OSHA safety, humane handling of feed animals issues, etc,) that's inherent/inveterate within the meat industry - continue to drive customers (and some big domestic and international meat corps who have already invested in company's that manufacture such plant-based proteins) ... towards the burgeoning plant-based proteins/goods?

"Stay tuned, will you - Mister Watttson?"

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SOURCES

Excerpts Used From Meatingplace.com (Double clip each title below to view)

Meatingplace.com January 06, 2017?| The Emperor's new clothes

Meatingplace.com November 25, 2016?| Denmark’s chicken fight with salmonella

Meatingplace.com July 22, 2016?| Is industry expecting (way) too much of the consumer?

Meatingplace.com September 25, 2015?| Raw meat HACCP – USDA’s quixotic regulation

Meatingplace.com November 27, 2015?| AMS continues to hone beef requirements for school lunch

Meatingplace.com June 12, 2014?| Hide removal practices are critical to producing safe beef

Meatingplace.com May 29, 2014?| Blind faith

Meatingplace.com May 09, 2014?| Major paradigm shift involving the 6 NON-O157:H7 STECS

Meatingplace.com May 08, 2014?| Zero tolerances

Meatingplace.com May 01, 2014?| Winning the battle against zoonotic airborne pathogens

Meatingplace.com April 17, 2014?| Hot spot

Meatingplace.com February 13, 2014?| Are you buying trouble? Part 1

Meatingplace.com April 03, 2013?| Zero tolerance: It would take a miracle to comply

Meatingplace.com January 16, 2013?| GFSI and HACCP decision-making

Meatingplace.com June 01, 2011?| Upton Sinclair is omnipresent in 2011

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**Academia Intervention Reference Studies For Handling Raw Meat - Raw & RTE Beef/Poultry - Irradiation Of Raw Beef/Poultry

Maughan, et al. 2016. Food Handling Behaviors Observed in Consumers When Cooking Poultry and Eggs. J.Food Protec. 79: 970-977 -- 101 Consumers observed preparing chicken breasts, turkey patties, & eggs. Thermometer use: 37% chicken 22% turkey, 0 for eggs. Cooked to 165°F/74°C: 77% chicken, 69% turkey, 49% of fried eggs. Safe hand washing: 40% handling chicken breast, 44% handling turkey patty.

2015 Kosa et al. Review of 17 papers: “Salmonella and Campylobacter can be easily transferred from raw poultry to hands and kitchen surfaces/food safety experts estimate that the home is the primary location where foodborne disease outbreaks occur” “Based on the survey findings, we conclude that education is needed to improve consumer handling practices. ”

?Kosa, et al. 2015. Consumer-Reported Handling of Raw Poultry Products at Home: Results from a National Survey. J. Food Protect. 78:180-186 – LAST CENTURY: “ By just watching food processing and particularly the preparation of raw foods of animal origin, the high probability of its occurrence becomes readily apparent. Washing hands and cleaning surfaces between raw and cooked food handling are often neglected.”

Bryan, Frank L. 1988. J. Food Protect. 8: 663-673 LAST: “It is known that improper handling of food and lack of adequate refrigeration are contributing factors in most outbreaks of salmonellosis.” Flippin, Harrison F., and George M. Eisenberg. 1960. The Salmonella Problem. Trans Am Clin Climatol Assoc. 1960; 71: 95–106.

(The above studies were contributed/provided to me by Carl Custer, retired Multi-Food Microbiologist USDA/FSIS 1972 - 2007)

(The remaining studies referenced below were taken from the FSIS/USDA website(s))

Bauermeister, L.J., J.W.J. Bowers, J.C. Townsend, and S.R. McKee. 2008. Validating the Efficacy of Peracetic Acid Mixture as an Antimicrobial in Poultry Chillers. J. Food Prot. 71(6): 1119-1122.

Food and Drug Administration Environmental Decision Memo for Food Contact Notification No. 000323: April 10, 2003

Food and Drug Administration Environmental Decision Memo for Food Contact Notification No. 000323: April 10, 2003.

FSIS No Objection Letter for Use of PAA spray, June 12, 2007 on file with company “ABC”.

Challenge study from “XYZ” laboratory demonstrating a 1- log reduction Salmonella on poultry carcasses after spraying with PAA using critical operational parameters specified.

21 CFR 173.325 for poultry parts and acceptability determination for ground poultry.

FSIS Directive 7120.1 Safe and Suitable Ingredients used in the Production of Meat, Poultry, and Egg Products.

Chemical manufacturer’s pamphlet demonstrating a 1- log reduction Salmonella on poultry parts following acidified sodium chlorite dip using critical operational parameters specified.

Dormedy, E.S; M.M. Brashears, C.N. Cutter, and D.E. Burson. 2000. Validation of acid washes as critical control points in hazard analysis and critical control point systems. J. Food Prot. 63:1676-1680.

Gastillo, A, L.M. Lucia, K.J. Goodson, J.W. Savell, G.R. Acuff. 1998. Comparison of Water Washing, Trimming, and combined Hot Water and Lactic Acid Treatment for Reducing Bacteria of Fecal Origin on Beef Carcasses. J. Food Prot. 61: 823-828.

Hardin, M.D., Acuff, G.R., Lucia, L.M., Oman, J.S., Savell, J.W. 1995. Comparison of Methods for Decontamination from Beef Carcass Surfaces.?J. Food Prot. 58: 368-374.

Delmore, R.J., J.N. Sofos, G.R. Schmidt, K.E. Belk, W.R. Lloyd, G.C. Smith. 2000. Interventions to Reduce Microbiological Contamination of Beef Variety Meats. J. Food Prot. 63: 44-50.

Documentation from the supplier assuring that the supplier employs validated interventions addressing E. coli O157:H7, certificates of analysis or web-based information that conveys the same information, records of ongoing communication with supplier and verification data to support the achievement of the first two conditions.

Beef Industry Food Safety Council. 2009. Best Practices for Raw Ground Beef Products.

Carpenter, C.E., Smith, J.V., and Broadbent, J.R. 2011. Efficacy of washing meat surfaces with 2% levulinic, acetic, or lactic acid for pathogen decontamination and residual growth inhibition. Meat Sci. 88:256-260.

Harris, K.; M.F. Miller, G.H. Loneragan, and M.M. Brashears. 2006. Validation of the use of organic acids and acidified sodium chlorite to reduce Escherichia coli O157 and Salmonella Typhimurium in beef trim and ground beef in a simulated processing environment. J. Food Prot. 69:1802-1807.

K.R. Davey, M.G. Smith. 1989 A laboratory evaluation of a novel hot water cabinet for the decontamination of sides of beef. Int J Food Sci Tech. 24: 305-316.

Dorsa, W.J., C.N. Cutter, G.R. Sirgusa, M. Koohmaraie. 1996. Microbial Decontamination of Beef and Sheep carcasses by Steam, Hot water Spray Washes, and a Steam-vacuum Sanitizer. J. Food Prot. 59: 127-135.

AMI Lethality model, demonstrating lethality at 160°F at carcass surface.

Nutsch, A.L., R.K. Phebus, M.J. Riemann, J.S. Kotrola, R.C. Wilson, J.E. Boyer, and T.L. Brown. 1998. Steam pasteurization of commercially slaughtered beef carcasses: evaluation of bacterial populations at five anatomical locations. J. Food Prot. 61:571-577.

Nutsch, A.L., R.K. Phebus, M.J. Riemann, D.E. Schafer, J.E. Boyer, R.C. Wilson, J.D. Leising, C.L. Kastner. 1997. Evaluation of a Steam Pasteurization Process in a Commercial Beef Facility. J. Food Prot. 60:485-492.

Tompkin Paper and Storage Temperatures

Published 06/15/2011 10:16 AM?| Updated 03/15/2018 09:20 AM

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Plant specific dosimetry procedures. 4.5 kGy fresh red meat, 7.0 kGy frozen red meat.

9 CFR 424.22(c), Irradiation of meat food and poultry products. Available at: https://cfr.vlex.com/vid/ 22-certain-other- permitted-uses- 19611025.

?NOTE: This blog and its entire contents (including possible unintended errors within) are of my own subjective opinion and free will (and right to express) – that’s based on my limited and personal experiences and not that of any one person, or anyone privately owned company, or anyone news format named and/or referenced to, by me, within this LinkedIn blog - unless otherwise noted/documented by me beforehand.