It is the food service if you accept hand washing is the leading cause
as CDC statistics show. But on the other hand, if we didn't have the
cook to wash the fruits and veg and cook the meat, poultry and fish,
there would be a massive amount of illness, much more than today, and
the source would be the growers and harvesters.
Pete Snyder
--
O. Peter Snyder, Jr., Ph.D.
Hospitality Institute of Technology and Management
670 Transfer Road, Suite 21A; St Paul, Minnesota 55114; USA
http://www.hi-tm.com
Tel 651-646-7077 FAX 651-646-5984
One worldwide uniform set of retail food safety guidelines
[Carl]: O.K. not as succinct as counselor Marler's but:
That "The consumer mishandled our product." is one of industry's
favorite defenses.
Both FDA and FSIS have carefully tread the line between action and the
status quo. Both FDA and FSIS have similar definitions for
adulteration and both use the "may render" and "does not ordinarily
render it" . . . "injurious to health" clauses (See below)
I'm more familiar with the Meat Inspection Act so will use it as an
example. Decades ago, the Secretary of Agriculture determined that
certain diseases of animals, e.g. brucellosis and tuberculosis would
ordinarily be a hazard to consumers. Therefore he (way before Ann
Veneman) determined that those carcasses and any meat derived from
them were adulterated (9 CFR 311). In some cases, he determined that
the meat could be salvaged by cooking (9 CFR 315).
In 1994, The FSIS Administrator, acting on behalf of the Secretary of
Agriculture, determined on the basis of epidemiological evidence, that
Escherichia coli O157:H7 in ground beef was ordinarily injurious in
the hands of consumers and therefore, an adulterant-in-ground-beef.
That determination for the end product has wagged the entire industry
by the tail.
In a similar vein, The Secretary of HHS (or his designee) has
determined that certain pathogens on fresh produce, such as melons,
spinach, etc. are ordinarily injurious to health in the hands of
consumers and therefore adulterated.
As I mentioned, these determinations are based on epidemiological
evidence. But, "Show me the bodies" or "Show me more bodies" has been
another industry response to proposed regulatory policy.
How much should consumers be protected is a tough question. The judge
in his opinion for American Public Health Association v. Butz, 511
F.2d 331, 335 (D.C.Cir.1974), opined that "The American consumer is
not stupid and knows to cook food thoroughly" ergo, doesn't need a
warning label on raw poultry.
O.K. when you stop laughing and pick yourself of the floor. Consider
that the Feds don't have an easy job. They are criticized for wanting
to form a "Nanny State" and for letting industry run amok. It's not a
perfect system. But, neither is the "Precautionary Principle".
Food Act excerpts:
SEC. 402. [21 USC 342] Adulterated food.
A food shall be deemed to be adulterated
(1) If it bears or contains any poisonous or deleterious substance
which may render it injurious to health; but in case the substance is
not an added substance such food shall not be considered adulterated
under this clause if the quantity of such substance in such food does
not ordinarily render it injurious to health;
Sec 601 21 USC 21 12:
(m) The term "adulterated" shall apply to any carcass, part thereof,
meat or meat food product under one or more of the following
circumstances:
(1) if it bears or contains any poisonous or deleterious substance
which may render it injurious to health; but in case the substance is
not an added substance, such article shall not be considered
adulterated under this clause if the quantity of such substance in or
on such article does not ordinarily render it injurious to health;
FOODSAFE has impressed 'upon me':
**Perhaps as much as 55-75% of FBI are a result of consumers' poor Personal Hygiene, Cross Contamination Awareness & Prevention, and absence of T&T Controls(Guess Cooking)
**Restaurant Industry has "more control", education, training, Mgmt. Systems Approach, Active Managerial Control, Thermometers, SOP's for Food Flow, and "No Pets" permitted in the establishment??
Have I been mislead / failure to comprehend/process available data?
Thanks,
Chris Argento
----- Original Message -----
From: Roy Costa <roye...@hotmail.com>
Date: Tuesday, July 15, 2008 10:07 pm
Subject: [Foodsafe] Re: blog poll quesiton - Who is responsible?
>
> But David, where do these pathogens come from? They don't
> manufacture them at home, they come to the consumer in the food
> they purchase, excpet for a few notable exceptions. But if you
> consider Salmonella, Campy and E coli to be the most prevelant FBI
> agents, its all about raw food, and the reservoirs for infection
> start at the primary producer and are further spread and
> proliferate at manufacture. Also note we eat about 50% of our
> meals away from home. The numbers do not point to the consumer
> level as the problem. Consumers are an easy scapegoat for
> industry, and yes the data are weak so its easy to blame them.Roy
> E Costa, R.S., M.S./M.B.A.Public Health Sanitarian
> ConsultantEnviron Health Associates,
> Inc1.386.734.5187www.haccptrai...@cfl.rr.com
> From: dche...@foodlinkny.orgTo: tck...@gmail.com; Foodsafe-
> li...@googlegroups.comDate: Tue, 15 Jul 2008 20:22:55 +0000Subject:
> [Foodsafe] Re: blog poll quesiton - Who is responsible?As soon as
> I saw Consumer on the list, that was a given, but consumer ones
> don't make the news. Even if the consumer causes their own
> problems they are more likely to blame it on the last place they
> ate out, than their practices at home. Unless there is enough
> people who get sick, there is no way to track an illness anyway.
> David J. Cherelin Foodlink 936 Exchange Str. Rochester, NY 14608
> (585) 328-3380 x113 Fax (585) 328-9951
>
> -----Original Message-----From: Tom [tck...@gmail.com]Sent:
> Tuesday, July 15, 2008 03:16 PMTo: 'Foodsafe'Subject: [Foodsafe]
> blog poll quesiton - Who is responsible?I know blog poll questions
> can be tiresome, but the Fresh Talk poll question this week asks
> Who do you think is to blame for most cases of foodborne illness?
> Growers Retailers Foodservice Consumers Of course, I want you all
> to vote in the poll www.freshtalk.blogspot.com but more than that,
> I'm curious if we know the answer to this question. My guess, of
> course, would be that consumer actions lead to the most cases of
> illness from food. Anyone seen any stats - why doesn't industry
> trot out a statistic like this when it is under fire? Tom K
> _________________________________________________________________The i’m Talkaton. Can 30-days of conversation change the world?
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>
[Carl]:
1. That might be true for containers for raw produce. The Listeria
monocytogenes hazard has prompted responsible ready-to-eat processors
to implement ways to clean and sanitize the evaporator units in their
coolers.
2. Most food pathogens are obligate mesophiles (the psychrotrophic
capability of listeriae is what makes it such a PITA). The cooler and
cooling units are not lethal but they do favor psychrotrophs over most
pathogens. Your petri dishes will contain bacteria but few pathogens.
3. The root of the problem, is the food, carrying pathogens, going
through those coolers that contaminate the cooler surfaces, plus, the
conveyor belts, worker's hands, implements, crates, and every other
surface.
I agree.
Attempts to blame FBI illness on consumer behavior are typically pure
conjecture. And there is no scientific evidence to support these
conjectures, except a feeling that "it must be true".
Having said this, there are situations and pathogens where consumer
(and restaurant) behavior plays a key role. Backyard barbeques and E.
coli O157:H7 in ground beef are an obvious example. In this case,
however, the extreme carefulness to avoid cross-contamination and to
provide proper cooking are an unrealistic expectation (implied by
FSIS' rules) for consumer behavior.
================================================================
Robert A. LaBudde, PhD, PAS, Dpl. ACAFS e-mail: r...@lcfltd.com
Least Cost Formulations, Ltd. URL: http://lcfltd.com/
824 Timberlake Drive Tel: 757-467-0954
Virginia Beach, VA 23464-3239 Fax: 757-467-2947
"Vere scire est per causas scire"
================================================================
[Carl]: USDA ARS has published several papers on the effect
transportation and the spread of salmonellae during transport of food
animals. But, the Risk Assessment Committee probably has those and
the ones on fruit and produce.
At least produce doesn't lick and defecate during transport.