“However, this company has made the commitment and invested the dollars to minimize that risk as much as possible given the state of current available technologies," Marsden wrote. "Imagine how low the risk will be as additional interventions become available. Call me an optimist, but it appears that the beef industry is close to having the tools to claim victory over E. coli.”
Dr. Marsden’s blog earned an almost immediate response from John Munsell who heads up F.A.R.E., the Foundation for Accountability in Regulatory Enforcement. Their mission statement says they represent legitimate small plant owners in dealing with the USDA and suggest common sense policy changes to the USDA agency.
Writing about the financial commitments required to achieve the levels of safety Marsden saw and the burden those costs might be for the little guy, Munsell said, "Without question, our industry has spent millions implementing multiple pathogen hurdles. The evidence of this success is the reduced numbers of E. coli positives and outbreaks due to meat consumption."
But here is Munsell's cautionary note: "Dr. Marsden, can you reveal to us the dollar cost of this plant implementing its system of spraying trimmings? The next question is the elephant in the room, which is the ability of small plants to make such investment, realizing the low volume of burger production, and the fact that small plants don’t even grind daily. Hard to justify major expenses when the equipment is used minimally. Bottom line: since this particular technology is not viable for small plants, what alternatives (which are equally efficacious) do you suggest for small plants?"
Munsell raises a critical, deal breaker of a question. Are we looking at an even more important bottom line - the staggering cost of an outbreak of food borne illness caused by a contaminated product and the inevitable 'going out of business' sign on the front door of any small- to medium-sized plant that can't make the necessary investment in food safety?
If there are less expensive alternatives that are “equally efficacious,” maybe the little guys can stay in business. Having looked at some of the most efficacious alternatives and the price tags attached to them, though, it's not promising.
Add this fact to that cost problem; a single hurdle, no matter how effective, will not achieve the necessary, government mandated results. Time and again, the “cleanest” ground beef comes from plants with multiple hurdles in place. For an even larger margin of safety, some of those hurdles have to be applied to trim supplied by an outside resource.
It was, in fact, contaminated beef from an outside resource that caused Munsell to lose his business, Montana Quality Foods & Processing, in 2002.
So here is the business proposition for the small guys: Rely on one or two affordable hurdles, keep it clean, watch your supply source like a starving hawk and hope for the best.
Here is the fatal flow in that scheme: a lawyer friend said all he has to do in a court case is ask the defendant this, "Were you aware that there was a better way available to you to help prevent contamination of your product?"
If the defendant answers "Yes," the case is closed. A very large award will be the result. A small business will probably have to shutter its doors.
So if you're producing small amounts of ground beef, the trade off is simple. Go “naked” and, with crossed fingers, hope your product is never linked to serious illness or death. The chances are extremely slim and maybe you'll find an affordable insurance policy that will protect you or accept the inevitability of it all and get out of the ground beef business. Producing whole muscle cuts is much safer business decision.
Here's something to help you make that decision from Mark Mina, Deputy Administrator, FSIS Field Operations, commenting about the 1997 Hudson Beef recall: "There are two types of businesses; those that have had a recall and those that will have a recall."
The opinions expressed in this commentary are solely those of Chuck Jolley, a veteran food-industry journalist and commentator.
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