Australia has joined a chorus of protest over proposed changes to US regulatory testing procedures for six additional strains of E. coli, known as non-O157:H7 STECS.
Cattle and meat organisations from Australia, Canada, Uruguay and New Zealand have joined ten significant domestic US stakeholders including the National Meat Association and Meat Importers Council of America in asking the US Department of Agriculture to delay its new testing policy, due to start next March.
The new rule would declare six additional disease-causing types of E. coli (O26, O103, O45, O111, O121 and O145) adulterants in beef trim and other raw ground beef components. Manufacturing meat dominates Australia’s exports to the US.
The strains are found much less frequently than the more common 0157 E. coli strain, and are not commonly associated with beef.
The opponents questioned the public health rationale and the science behind the new policy and the risk assessment , which it fears will be expensive and deliver little in the way of improved public safety.
The issue was first raised on Beef Central by former under-secretary for the office of food safety in the USDA, Dr Richard Raymond in an article “Big changes ahead in food safety arena” uploaded on August 26.
The group’s letter to US agriculture secretary Tom Vilsack said USDA’s Draft Risk Profile regarding the testing has significant flaws and the policy could also violate the US’s World Trade Organisation obligations.
The letter follows a conference call/meeting between USDA’s Food Safety and Inspection Service and industry and foreign government representatives earlier this month, where the opponents urged that the implementation of the new requirement be delayed and reconsidered.
The groups outlined various reasons why implementation should be delayed. Many of the comments highlighted the fact that the scientific experts commissioned by FSIS to review the Draft Risk Profile criticised important elements of the profile.
The Australian and NZ governments both expressed concerns about the absence of an adequate risk assessment, the lack of a reliable test for the pathogens and the potential for an unjustified disruption in trade.
Costs could top $300m/year
Several meeting participants also noted the inadequacy of the cost analysis provided by FSIS.
Some comments expressed concern about the impact the policy will have on small businesses. Others provided preliminary information that the likely cost behind the testing process, which they believe could top US$300 million annually.
The FSIS acknowledged that point in the FDRC, when it said: “For example, we do not know how many illnesses will actually be prevented. It is not clear whether, on net, there will be a reduction in the number of illnesses."
The FSIS also said it was challenging to know what the industry cost will be because it is difficult to predict how many establishments would start to test and to what extent industry would take additional measures to prevent or reduce those hazards, as they did with O157 STEC.
Any considered analysis of CDC (Centers for Disease Control) data shows that STECs are not an urgent and unique public health crisis, the opponent groups argued.
Rather than rushing headlong into this questionable policy, there was time to conduct a risk assessment, ensure the accuracy and efficacy of test methods and collect data needed to determine the extent of the problem, they said. From there, if warranted, the policy could be implemented and expanded if necessary.
One well-respected US meat science source said while the objectives of the FSIS policy on non-O157 STECs were well-intended, the testing component was simply not ready for implementation.
“Testing for a group of STECs is quite different from testing for a specific single organism like E. coli O157:H7. This poses enormous challenges that are still unresolved," he said.
Another of the problems associated with the test is that if a positive is detected in beef trim – sourced either from an exporting country, domestic US supply, or a combination of both, as often happens with blended burger pattie manufacture – the product must be diverted for use in cooked products only, at greatly reduced value.
Respected US scientist Dr Mohammed Koohmaraei warned that there was likely to be many more positive test results for non-O157s. He predicted that the potential positive rate for beef trimmings could be 4-10pc, which could mean much more beef trim being diverted to cooking.
While all this diuscussion is occurring, US consumer and public health advocates continue to urge the FSIS to implement the new policy without delay. Implementation would represent the biggest change in US meat regulation since the declaration of the much more common E. coli O157:H7 as an adulterant.
Comment on the proposed rule is due to close today.