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OIG Says FSIS Should Reevaluate N-60 Sampling Program, But Agency Says Very Low Prevalence of E. coli O157:H7 Makes Pathogen Extremely Difficult to Detect

Monday, March 7, 2011

(American Meat Institute)

In a report released today, USDA’s Office of Inspector General (OIG) recommended that the Food Safety Inspection Service (FSIS) take steps to thoroughly reevaluate its N-60 sampling program, noting that this sample size and design may not be adequate for detecting E. coli O157:H7 in beef trim given the “presumed low occurrence of the pathogen,” but FSIS expressed concern that the very low – and declining – prevalence of the pathogen makes it extremely difficult to detect E. coli O157:H7 in ground beef. 

The OIG acknowledged the inherent challenge, noting that, “The dilemma facing FSIS is that as plants’ controls and interventions become more effective at eliminating fecal material on carcasses, the presence (or prevalence rate) of E. coli O157:H7 contamination in beef trim becomes lower. Statistically, the lower the prevalence rate, the more difficult the pathogen is to find and the more samples need to be taken to detect it.”   

FSIS told OIG that increasing the number of samples will require significant additional labor and laboratory costs.   OIG recommended that FSIS take advantage of the fact that many plants are independently performing hundreds of their own E. coli O157:H7 tests daily and perhaps utilize these plants’ testing results to augment the agency’s own tests.  FSIS currently has access to those test results under federal regulations.  

OIG also recommended that the agency “move to an inspection system that will determine which processing plants are at a higher risk of E. coli O157:H7 contamination.”

Other OIG recommendations for action include:

This report in response to a Congressional request represents the results of Phase I. In Phase II, OIG will examine testing procedures at plants.

To view the report, click here: http://www.usda.gov/oig/webdocs/24601-9-KC.pdf

AMI Response

In response to the report, AMI Executive Vice President James H. Hodges cautioned that testing must be put in perspective. 

“Product testing verifies that food safety systems are operating properly, but testing cannot guarantee that a meat product is pathogen free. This is particularly true when pathogens are present at an extremely low level as they typically are in ground beef,” Hodges said.

He also noted that beef trim testing requires something called “destructive sampling.”  Under N-60, 60 samples are pulled and each is destroyed by the testing process.  He pointed out that there is no “litmus test”  that offers a yes or no answer about the presence or absence of pathogens without destroying product.

“This report illustrates the central dilemma that we face. The more we reduce E. coli O157:H7 in beef trim, the more tests we will need to conduct to find it.  So, if the prevalence goes to .0001 percent, does the agency need to sample all the trim (and in the process destroy it) to conclude it’s not there?”

He also added that the government has full access to records under existing HACCP rules and they can use that data to verify that food safety systems are working.  Finally, he noted that the OIG report focuses on trim testing. Trim is processed into ground beef and there are additional pathogen tests done later in the process by FSIS and industry.

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