The FDA has (at least in the past) said:
1. since you can't control _E. coli_ don't even monitor for it, because it
is normal.
2. you must monitor for O157:H7 because we are getting heat from the public.
So they issued a special advisory asking O157:H7 be monitored January 1997.
The FDA will add a law forcing the monitoring and control of O157:H7 in the
new HACCP rules this will be mandatory on December 12, 1997.
3. even then, if you find it you do not HAVE to recall your product, but it
is highly suggested.
6. since there are no really good controls for raw beef, you are out of
luck unless you gamma irradiate your beef. But, some people don't what you
do to that either.
<< Was it
an unfortunate and largely unpreventable accident? >>
At this point cooking and kitchen sanitization are the prevention. There is
no effective prevention for raw beef.
<< Is it mounting
carelessness and lack of thorough quality control?>>
It is a lack of a good raw beef (raw means uncooked) control for _E. coli_
And some food sellers let raw (no antimicrobial control) beef be consumed, by
undercooking it.
<< Do the workers in
the meat-processing plants give a rat's ass what the general public
throw down their gullets? >>
Maybe, but _E. coli_ is "normal." The meat processing people don't even
consider it a problem, because cooking is thought to be the control, not
them. They have no controls really, they never have had controls (besides
the poor ones listed below).
<< Do the FDA inspectors?>>
What can the inspectors really do if there is no microbial controls for _E
coli_ in beef? Well, they look at it, check for gross problems, look to see
if a lot of intestinal matter is being ground in, check temperatures, and
equipment sanitization and make sure the batch records are adequate in case a
recall is recommended. But, that's about it.
<< Do the stockholders
of the companies supplying meat . . . >>
They had better, because right now their companies are in danger of being
shut down and they will loose their investment.
------------------------------------------------------------------------------
--------------------------
Davin C. Enigl, MEAS, Master of Environmental Arts and Sciences
President-Microbiologist, HACCP Validations (tm). Quality Assurance, Quality
Control, Research and Development
Co-author of _Preservative-Free and Self-Preserving Cosmetics and Drugs_,
Kabara and Orth, eds. Copyright 1997,
Marcel-Dekker, ISBN 0-8247-9366-8, Telephone: 1-800-228-1160
Microbiology Services for: Biotechnology, Cosmetics, Foods, and
Pharmaceuticals
Water System Design and Validation
Preservative Formulation and Stability Testing
FDA Validation Protocols
Hazard Analysis and Critical Control Points (HACCP)
Current Good Manufacturing Practices (cGMP) Audits
Facility Start-Ups
Microbiology Training
Web Site: http://members.aol.com/enigl/
August 25, 1997
3:14 pm PACIFIC