CU comments on FSIS’ testing policy for non-O157 Shiga toxin producing E. coli
United States Department of Agriculture (USDA) Food Safety Inspection Service (FSIS)
Final determination on Shiga Toxin-Producing Escherichia coli in Certain Raw Beef Products
Docket Number FSIS—2010—0023
Prepared by Michael Hansen, Ph.D.
December 21, 2011
Consumers Union (CU) welcomes the opportunity to comment on the US Department of Agriculture (USDA), Food Safety and Inspection Service’s (FSIS) policy to start sampling and testing raw beef and beef components (e.g. trim,) for six serogroups of Shiga toxin producing Escherichia coli (STEC) (O26, O45, O103, O111, O121, and O145) in addition to E. coli O157:H7. We commend FSIS for this sampling and testing policy,and strongly agree with thetm that these six non-O157 STEC should be classified as adulterants when found in non-intact raw beef products and product components, for the reasons outlined below. We also urge FSIS to begin the sampling and testing in March 2012 as scheduled and not to delay implementation. Further, we urge FSIS not to switch to a less sensitive sampling method (collecting one 325-gm sample rather than collecting five 65-gm sub-samples) until they have released the Agency study that supported making the switch for comment by the public. In addition, we urge FSIS to go further and to declare these 6 non-O157 STECs adulterants when they appear on any beef ingredients, and not just when found on non-intact raw beef product and product components. Next, FSIS should expand the testing and sampling policy to include other non-O157 STECs as well.
For the full comments, click here (PDF format)