Some say that history continuously repeats itself. The evolution of pathogen control in our national food supply is no exception.
Perhaps you recall the shock expressed by the meat industry in 1994 when USDA first declared E. coli O157:H7 to be an adulterant in raw ground beef. In hindsight, the surprise expressed in 1993 is no different than the bewilderment expressed by the food industry this year when FDA declared Listeria Monocytogenes to be an adulterant in frozen vegetables – that are intended to be boiled. Or, the befuddled reaction from industry when USDA recently began to signal that Salmonella may also someday be added to the list of growing adulterants in ground beef. Indeed, the patterns we witnessed in the 1990s and are witnessing again today from both regulators and industry are virtually the same.
Indeed, in 1993, effectively controlling or eliminating the spread of E. coli O157:H7 contamination during slaughter was thought to be impossible. In response to USDA’s policy, it was loudly declared by industry that “promoting food safety by outlawing pathogens would be like like promoting airline safety by repealing the laws of gravity.” Nevertheless, despite the calls of impossibility from industry, the federal government pressed forward. In addition to declaring O157:H7 to be an adulterant in ground beef, in the late 1990s USDA also required industry to develop and implement written food safety plans (HACCP) to control for pathogenic risk. Nobody believed these efforts would be successful at virtually eliminating O157:H7 contamination from ground beef and the resulting outbreaks. Notwithstanding the pessimistic outlook, a high level of industry collaboration and efforts eventually proved to be successful.
Today, those calls of impossibility are once again being echoed.
I hear repeatedly from colleagues that, given current technological limitations, it is impossible to eliminate Listeria Monocytogenes from certain ready-to-eat environments or Salmonella from certain raw animal foods. So, what’s the deal? Who’s right in the continued evolution of pathogen control? Is the FDA justified in adopting a zero-tolerance approach for Listeria in virtually all foods? Is USDA correct in tightening the Salmonella performance standards on its journey to eradicate pathogens from raw animal products? Are the regulators correct saying that a zero tolerance (or, near-zero tolerance) approach is both reasonable or achievable?
Or, is industry correct, saying that some things are, in fact, impossible, and that there are better ways to control risk. In the beef industry, for instance, safe-handling labels and instructions are used today to educate and also protect consumers from raw animal products that become contaminated (despite best efforts) with harmful pathogens. Perhaps, both industry and the regulators are right. Industry should continue its efforts to control the spread of harmful pathogens, and FDA should be more open to using a combination of regulatory enforcement standards AND education, labels and warnings to protect the consuming public.
With that said, my prediction is that whatever solution industry develops over the next decade, that solution will likely look very similar to the solutions adopted in the past. Written food safety plans will result in safer products, FDA enforcement policies will continue to incentivize regulatory compliance, and consumers will become increasingly educated and knowledgeable in how to appropriately handle, prepare and consume the ever-expanding list of higher-risk foods.