I am elated that this article referred to the possibility that the meat may have been contaminated at the slaughter facility which sold the meat to Meat Market. Although this is but one of numerous possibilities in this outbreak, at least its mention hopefully presages America's willingness to trace back to the true source of contamination.

Let's assume for a minute that the meat indeed had been previously contaminated at the slaughter house, and that Meat Market had unwittingly and legally purchased meat laced with invisible pathogens. Let's also assume that Meat Market loses customers over this issue, experiences adverse media publicity, gets sued, and goes out of business. Long term, will its closure improve public health? No. Future production of contaminated meat and recurring shipments of lethal meat into commerce will continue unabated until the slaughter house origin of contamination is identified and required to implement effective corrective action.

E.coli and Salmonella are enteric bacteria, which by definition means that they emanate from within animals' intestines. Meat Market does NOT have animal intestines or manure-covered hides on its premises, so in all likelihood did not introduce the E.coli, but merely further processed previously contaminated meat. Therefore, if every Meat Market and retail grocery store in America is shuttered, we will still not have addressed the true origin of contamination, and recurring outbreaks are virtually guaranteed because the DESTINATION of contamination has been made responsible, rather than the ORIGIN of contamination. What are the long term ramifications of blaming the destination facilities for the presence of pathogens?

The answer has been abundantly clear this year, as can be seen by a close review of recent recalls.

Most recently, the 360,000 lb recall announced by United Food Groups (UFG) in Vernon CA interestingly is at a non-slaughter plant. Has USDA required UFG's slaughter source supplier plant to implement corrective action to prevent recurrences? No. USDA-style "science" requires that the agency focus exclusive responsibility against United Food Groups, which merely resolves the current outbreak, but does nothing to prevent future slaughterhouse production of contaminated meat.

Another CA meat plant announced a 107,943 lb recall of E.coli meat on April 20, 2007. Richwood Meat Co in Merced CA is getting to be an old hand at recalls, realizing that it had earlier announced a previous recall of 90,000 lbs of e.coli meat on February 24, 2004. At first blush, one would think that Richwood Meat Co is filthy and should be closed down. It would appear that Richwood lacks the necessary sanitary protocol to safely dispose of intestines and manure-covered hides at its plant. However, Richwood does NOT slaughter, thus has no intestines at its facility. As such, Richwood and thousands of other downline further processing plants operate at the total mercy of the originating source slaughter plants from whom they purchase all their meat for further processing. Since E.coli are invisible bacteria, Richwood could not detect the pathogen. Furthermore, all meat purchased by Richwood arrives at their docks in containers bearing the official USDA Mark of Inspection which proudly says "USDA Inspected and Passed". An underlying problem in America is that USDA continually allows slaughter plants to ship into commerce contaminated meat bearing the agency's seal of approval, the value of which remains in a freefall.

Public health imperatives demand that USDA determine if these two downline CA plants purchase meat from the same source slaughter plant. Is USDA willing to connect the dots, and bring enforcement actions against the noncompliant slaughter facility? Don't count on it.

Earlier this year, large E.coli recalls were announced at Hoss's Fresh Xpress in South Claysburg, PA and at Davis Creek Meat & Seafood in Kalamazoo, MI. True to form, neither of these plants slaughter. Did the USDA conduct tracebacks to the slaughter house origins of meat used at these downline further processing plants? Don't hold your breath.

Weeks ago recalls were announced at two Minneapolis retail chains, Byerlys and Lunds, which of course do no slaughter and have no intestines or hides on their premises. Were these two retail chains guilty of shirking their public health duty? What suggestions do we provide them (and all other retail meat markets in America) to purify incoming meat which may be laced with invisible pathogens? The only two options are (a) irradiation, and (b) full cooking. Neither option is practical, viable, or acceptable to consumers. Irradiation is enormously expensive, so much so that even the huge slaughter plants do not consider irradiation. Secondly, studies have shown that consumers do not want to buy irradiated (nuked) meat. Thirdly, consumers should not be required to purchase irradiated manure. The second option (full cooking) would cook meat to 160 degrees or higher, which would kill all E.coli bacteria. However, consumers want to buy fresh steaks, burger and roasts at retail stores and perform their own cooking at home. Therefore, USDA's ubiquitous suggestion that further processing plants become proactively involved in food safety by implementing irradiation or full cooking is but an agency public relations ruse with no merit.

An equally ludicrous USDA suggestion to downline plants which experience recalls is that the plant discontinue purchasing from the originating slaughter facility. Now think about the wisdom behind this common agency suggestion! First of all, when the agency makes this suggestion, the agency is admitting that it is fully cognizant that the slaughter plant has been shipping contaminated meat. But, USDA is unwilling to engage the slaughter plant with enforcement actions. Secondly, discontinuing purchases from the slaughter plant merely means that the slaughter plant will ship its hot meat to other downline destination plants, instead of to the plant currently experiencing the recall. Since USDA lacks common sense suggestions for victimized further processing plants, the agency is forced to degenerate into unscientific and illogical conclusions in its attempt to "ASSIST" these small, downline plants.

Fortunately, the Minnesota Dept of Public Health fearlessly investigated the outbreak stemming from meat purchased at Byerlys and Lunds and traced the contaminants back to PM Beef Holdings in Windom, MN. Please note that MN officials conducted this successful investigation, not the USDA! This fact is becoming commonplace: the previously-mentioned recall at United Food Group in Vernon CA was the result of investigations conducted by state health officials in CA and CO, not by USDA! The story continues: The Richwood Meat recall also was the result of investigations conducted by the California Department of Health Services. The picture is quickly emerging that only when state health officials present smoking gun evidence to USDA does the federal agency sluggardly implement enforcement actions against noncompliant slaughter plants which are the true origin of E.coli contamination.

Another lesson can be learned from the recalls at Byerlys and Lunds in Minneapolis, caused by their purchase of contaminated meat from their slaughter supplier, PM Beef Holdings in Windom, MN. Last year, a recall was issued at Fadlers, a USDA plant in Tulsa, OK, which likewise does NOT slaughter. In my discussions with Fadlers, the company stated (a) USDA showed no interest in tracing back to Fadlers' slaughter suppliers, and (b) that the slaughter supplier plant involved was, guess who, none other than PM Beef Holdings in Windom, MN. Did USDA implement enforcement actions against PM Beef subsequent to Fadler's recall in 2006? If so, I've failed to see it.

The point to be made here is that recurring outbreaks and recalls will continued unabated until the truly non-compliant source slaughter plants are required to implement effective corrective actions to prevent recurrences. Until this is accomplished, public health and meat eaters specifically continue to be at risk. This laudable traceback objective faces a formidable foe: USDA. The agency staunchly resists tracebacks to the large slaughter plants because such enforcement actions are too uncomfortable to an agency which is enjoying semi-retirement as a result of the HACCP concept. USDA is much more comfortable in targetting smaller downline plants which lack the political clout and financial wherewithal enjoyed by the huge, often multi-national slaughter plants to engage the agency in protracted litigation to defend their rights.

If we accept the twin tower goals of public health and food safety, we must eventually deal with the need for tracebacks to the source. All other solutions have short-term merit only. "Force the Source" must be our battle cry, instead of focus on the destination.

John W. Munsell
Foundation For Accountability in Regulatory Enforcement (FARE)
Miles City, MT
June 9, 2007

It's not just food safety, it's water safety as well. Google Walkerton Tragedy. Half of this town's people got sick ( 2400 people )seven died. Walkerton Ontario has one of the highest stroke rates ( per capita ) in the world. This all happened because cow manure washed in this town's well. The source of contamination is actually on every ranch and farm in North America where as much as half of all herds are affected. Oh, don't forget those cute little petting zoo's all around the country too. The USDA has, in their sweet little hands, an application for an E.coli 0157:H7 vaccine approval from Bioniche Life Sciences that will stop 99.47% E. coli shedding from cows ,with three doses at less than $ 10 per cow. Hey , it's a Canadian company so they will never approve it.