Is the USDA's E. coli policy undercooked?
One early morning in August 1998, Frank Bauer arrived at his Ocala, Florida meat packing plant to find some 30 government agents from the U.S. Department of Agriculture (USDA) scouring every corner of the family-owned company. Investigators seized all the office computers and documents, and all the company's meat was considered "government evidence," according to a search warrant.
Bauer Meat was an unlikely target for such a huge government raid. The 50-year-old company had faithfully followed all current government regulations, monitored by two on-site USDA inspectors, and it had never been cited for violations of meat handling regulations. In the mid-'70s, Frank Bauer had actually made national headlines for exposing corruption among government meat inspectors.
But two months earlier in Atlanta, an outbreak of illness from the deadly bacteria E. coli O157:H7 was indirectly linked to beef sold by Bauer Meats, and the USDA was hell-bent on a crackdown. After the raid, the USDA informed Bauer that it was withdrawing its two inspectors from his plant. Without inspectors, a plant cannot legally sell food in interstate commerce. The move essentially shut down the Bauer Meat Company. After receiving the news, Frank Bauer retreated to the ranch where he kept his prized Angus herd. He placed his own 40 mm semiautomatic handgun to his right temple and pulled the trigger.
Despite its tragic ending, the USDA's move to close Bauer Meats represented a victory for food-safety activists. Ever since the famous 1993 Jack-in-the-Box debacle, in which burgers contaminated with E. coli O157:H7 sickened 732 people and killed four children, activists have been demanding greater action from the government to prevent food-born illnesses.
But the events leading up to Frank Bauer's suicide illustrate how consumer activists' well-intentioned demands for safer food have driven the USDA to take extreme measures that punish business but do little to actually improve the safety of the food supply. The USDA's "zero tolerance" policy for policing the American beef supply for E. coli ignores basic science, and it has led the agency to recall millions of pounds of beef and shutter dozens of plants while neglecting the effective--and sometimes simple--measures that it can take to protect public health.
The Other White Water
Bauer's tragic story started a few months earlier, back in Georgia. On June 11, 1998, the temperature in Atlanta was over 90 degrees, but the chlorine reading taken from "Captain Kid's Cove" pool at Atlanta's White Water Park was as low as the instrument would measure. The pool's chlorinator was on the fritz, and several parents would report later that they had seen signs of fecal matter in the pool and on a water slide.
Five days later, six Atlanta metro-area children, including the son of Atlanta Braves baseball player Walt Weiss, were hospitalized, suffering from kidney failure, bloody diarrhea, and other symptoms of a deadly E. coli 0157:H7 infection. The bacteria are usually spread to humans through undercooked beef and other food sources, but fecal matter is also a common vector. In all, 26 cases of E. coli O157:H7 would be traced to the water park. One two-year-old girl would die and another toddler would remain in a coma for months to come. (Full disclosure: Dr. Weinberg served briefly as a scientific consultant to White Water Park's owners.)
The E. coli outbreak became a national story, driven by public interest organizations, such as Safe Tables Our Priority (STOP), and panicked parents who demanded government action. Bill Marler, a renowned food-safety lawyer who had won record judgments against Jack-in-the-Box, showed up in Atlanta ready to sign up clients. As part of the investigation, health officials performed a rapid "DNA fingerprinting" to try to identify the source of the infection.
The bacteria were initially tied to a beef lot that had sickened 11-year-old Stephen Tyler Roberts, who had nearly died from kidney failure after eating an undercooked hamburger in the cafeteria of Danielsville Elementary School in North Georgia two months earlier. The beef had come from the Bauer Meat Company. After Roberts' illness was reported to state health officials, Bauer had voluntarily recalled 37,500 pounds of beef--its first recall ever.
No other illnesses were directly ascribed to the lot of beef, and health investigators were reluctant to blame Bauer for the water-park outbreak because of some ambiguity in the lab tests, but the press had no such qualms. It wasn't long before reporters were holding Bauer Meat responsible for killing children. Consumer activists and members of STOP were furious that health officials had not warned parents earlier about the possible burger link.
"They've given them a false sense of security," Nancy Donley told the Atlanta Journal and Constitution. Donley, whose 6-year-old son died of E. coli poisoning in 1993, complained that public health officials were more interested in protecting a meat manufacturer and the water park than in protecting the public. The news clips found their way into the hands of the USDA. Under relentless criticism to do something about the E. coli threat, the USDA staged a midnight raid on Bauer Meat a few weeks later.
The raid, however, was premature. Dr. Paul Blake, an epidemiologist with the Georgia Division of Public Health who was involved in the investigation of the White Water Park outbreak, could identify no one from the Danielsville Elementary School who visited White Water Park during the transmission period. For this reason, he became unsatisfied with the lab work on the White Water E. coli isolates that had been the basis for the Bauer Meat raid. Blake shipped all of the isolates, each with a randomly assigned code number, to Dr. Mansour Samadpour at the University of Washington.
Samadpour performed a much more sensitive test on the bacteria, and the data showed no link at all between the E. coli from the recalled Bauer beef and that from White Water Park. Unfortunately, the finding came too late to save Frank Bauer.
It's easy to understand why E. coli scares people. The resilient bacterium can double itself every 20 minutes; manufacture a deadly toxin while growing within the human gut; shut down kidneys; puncture the intestines; cause seizures, comas, and, eventually, death. Children are the most common victims of the microbe which can arrive innocently packaged in the contents of a school lunch cheeseburger.
That's why, after the 1993 Jack-in-the-Box catastrophe in Seattle, parents of the young victims created the lobbying group STOP to force the government to clean up the beef industry. The group wielded tremendous political clout with their tragic stories; no government official wanted to be seen as sympathizing with food suppliers who killed innocent children.
A year later, the USDA declared E. coli O157:H7 an adulterant in raw ground beef under the Federal Meat Inspection Act. Lots identified as containing the organism would have their meat recalled. A sampling program was initiated to test for the organism in beef prepared in federally-inspected plants and in retail stores. The agency would at least withhold its mark of inspection if any bacteria were detected, and it had the discretion to withdraw inspection if it felt the adulteration was severe.
In the first year of the program, the USDA's Food Safety Inspection Service (FSIS) temporarily suspended operations at 20 plants and moved to shut one other. By 1998, the year of the White Water outbreak, recalls were a regular part of FSIS operation. That year, the Bauer Meat recall was one of 44 originated by the agency, totaling 46,030,470 pounds of meat. Last year, the figure was up to 62 recalls.
The record for annual meat recalls was set in 1997, when FSIS recalled 25 million pounds of ground beef--enough to make one hundred million quarter-pound burgers. The episode began the night of July 9 in the home of a 22-year-old Safeway employee from Pueblo, Colorado. He hosted a barbecue for two friends and ate two burgers. Within a week he had a confirmed case of E. coli O157:H7 infection. The lot was traced to the Columbus, Nebraska plant of Hudson Foods, a large meat-packing operation. More than a dozen people fell ill from the tainted meat, and the USDA demanded the huge recall.
But, despite the explosion in the number of recalls, the bacterium remains in the nation's food supply. There are 25,000 cases of E. coli O157:H7 infection each year in the U.S.--a number that has not gone down in relation to the increased enforcement by the USDA. The CDC reports that the rate of O157 cases in the country has not really budged:
Year: 1996 1997 1998 1999
Cases*: 2.7 2.3 2.8 2.1
*(per 100,000 persons)
The numbers shouldn't come as much of a surprise. As much as the government would like to be able to tell the public and food activists that it can eradicate E. coli from the food supply, it is well aware that it can not. That's what makes Frank Bauer's death all the more tragic.
Even if Bauer's operation had been perfectly clean, E. coli would still come right in one door of the plant and back out another. E. coli's normal habitat is in the intestines of mammals, and for O157:H7, it is in the intestines of cattle. It is also found on the hides of the animals, which often become caked with manure (hence the recent E. coli outbreak stemming from the Pennsylvania petting zoo). If mistakes are made in the processing of cattle, the bacteria can end up on the meat at the time of slaughter.
As the entrails of the animal are dislodged, microscopic spray may contaminate the product. With some slaughterhouses processing five hundred steers per hour, there is ample opportunity for cross-contamination. It is even more difficult to keep a contaminated hide from adulterating the meat as a large animal's skin is peeled off.
Bauer did not run a slaughterhouse. He received carcasses from the Central Beef Corporation and from other abattoirs. If E. coli contaminated the caracasses, this occurred before they arrived at Bauer Meat. When Bauer sent a sirloin cut to his grinding machine, even the USDA wouldn't be able to tell whether he was putting bacteria into the hopper along with the beef. Indeed, Bauer had two on-site inspectors at the plant when it packed up the burgers for Tyler Roberts' school lunch. Closing down Bauer's plant, in effect, was nothing more than a PR stunt, not good public-health policy.
Dr. James Jay, a widely recognized expert in the field of food microbiology and safety and professor emeritus at the University of Nevada, sees the massive beef recalls and plant closings like Bauer's as "a virtual disaster and a misuse of the scientific discipline of microbiology."
According to Jay, "There's not much science in the zero-tolerance policy. In fact, it was instituted to appease consumer activists. There is no test that can produce results within minutes to show whether bacteria are present on a carcass. So what does it mean if you find a positive? Does it mean other carcasses have the same bacteria? No. Does a negative finding mean none of the other carcasses have E. coli? No, it does not."
That doesn't mean, of course, that the government should just abandon testing. It should mandate rigorous testing all along the beef production line for any number of hazards, not just E. coli. According to FSIS spokeswoman Carol Blake, the agency does do some generic E. coli testing at the slaughterhouse level, and it encourages plants to set up controls and requirements for their suppliers. "A processing plant certainly has the right to require its supplier to do testing prior to receiving the product," she said. "They can implement some controls to give them an additional safeguard."
The problem, of course, is just as FSIS has been unable to prevent E. coli from finding its way into the supply, so have the suppliers and the processing plants. And it's not because FSIS hasn't tried.
The USDA began a new testing system in 1998 designed to improve on the old "poke and sniff" method of meat inspection. Known as HACCP (Hazard Analysis and Critical Control Points), the system is designed to force meat companies to monitor bacteria levels in their plants and to keep contaminated products from reaching the public. HACCP is credited with reducing the incidence of salmonella in ground beef from 7.5 percent in 1996 to 5 percent last year--clear evidence of the value of better regulation. Unfortunately, there has been no such reduction in E. coli.
The reason lies partly with the bacterium itself. E. coli O157:H7, unlike salmonella, is highly toxic in tiny doses. Consuming fewer than 10 E. coli O157:H7 bacteria can make people deathly ill; by comparison, you would have to eat 1,000 salmonella bacteria before getting sick. Essentially, to achieve zero tolerance, meat producers would have to culture every piece of beef and hold it for a couple of days until the test results came back to ensure that meat leaving the plant were clean. Such a system would be wildly expensive, not to mention inefficient, and even then, it still wouldn't be foolproof.
Burgers Well Done
The scientific problems that plague the government's E. coli policy haven't stopped consumer activists from demanding more plant closings and legislation empowering the USDA to conduct mandatory recalls (the current recalls are voluntary) and impose civil fines on companies that distribute tainted meat. And the government should have strong enforcement power to shut down dirty plants and slaughterhouses and it should exercise it fairly. But again, even those measures won't completely banish the deadly E. coli bacteria from beef.
According to Dr. Mike Doyle, director of the Center for Food Safety and Quality Enhancement at the University of Georgia, eliminating E. coli from beef can only be done "post-processing," or after cows have been turned into hamburger patties and steaks. One possible post-processing solution is irradiation, which is the only known method to eliminate E. coli in raw meat.
Irradiation has already been employed in 39 countries, and in December 1999 the USDA finally approved rules for meat irradiation in the United States. Health and safety authorities had already approved irradiation for some 40 different foods, ranging from spices to grains, chicken, fruits, and vegetables. Even apple juice and chewing tobacco are candidates for radiation treatment. But for ground beef, irradiation may not be the silver bullet some would hope for.
"Irradiation sounds good when you say it fast," says Doyle, "but the right way to do it is not at all clear." The biggest hurdle for irradiation, according to Doyle, is that flavor may be altered. After large doses of radiation, ground beef can take on the smell of a wet dog. Very high doses may also denature the myoglobin in the meat, rendering it pale and less attractive at the market.
The beef industry is currently studying other strategies for combating E. coli at the slaughterhouse level. These include steaming beef carcasses at 160 degrees before processing, organic acid washes, and different methods of removing entrails. If those measures prove effective, they should be adopted immediately. But it's likely those options won't be in widespread use for some time and, like testing, they aren't foolproof: The bacterium can hide in the miniscule crevices that steam and acid can miss.
With such imperfect options for controlling E. coli, the most rational choice to avoid getting sick from beef might be to quit eating it. But red meat lovers shouldn't despair. There are some other, simple ways to eliminate the majority of cases of E. coli infection almost immediately.
The spread of E. coli infection almost always involves human error in food preparation. Nearly every case of E. coli poisoning involving beef, from Jack-in-the-Box to the Danielsville Elementary School cafeteria to the Safeway employee in Colorado, stemmed from improperly cooked meat. At the time of the Jack-in-the-Box outbreak, the company was using the lowest acceptable standard in the industry for cooking its burgers: 140 degrees. Some reports indicated that sometimes burgers cooked at only 108 degrees in the center were making their way across the counter.
Food and consumer activists hate this kind of analysis, which places some responsibility on the people who prepare food, rather than the beef suppliers themselves. They believe it relieves the government and industry of responsibility for monitoring the food supply. Those criticisms have some merit, but food safety doesn't have to be an either/or proposition.
Unquestionably, the packing industry and the slaughterhouses should be taken to task to ensure that they are doing everything in their power to make sure that meat is contaminant-free. The government should also strictly inspect the beef industry at every level and take reasonable and fair steps to maintain the safety of the food supply--including punishing those companies who fail to live up to government standards. However, activists should not minimize the real value of public education. That's because, unlike recalls or plant closings, teaching people to cook their burgers until well-done is actually proven to reduce disease. Just ask the people at McDonald's.
While the Jack-in-the-Box outbreak is the most famous E. coli story, it wasn't the first time that numerous people had gotten sick from eating undercooked burgers. That honor goes to Mickey D's, which was responsible for the first E. coli O157:H7 outbreak ever, in 1982.
This initial outbreak didn't get much play in the newspapers--mostly because the day the news broke about this new scourge, headlines coincidentally read: "Tylenol Laced with Cyanide: Seven Dead in Chicago." Still, the incident prompted McDonald's to start frying hamburgers to a bacteria-curdling 155 degrees, and they have had few problems since then.
A few other simple precautions could produce measurable results in public health. A 1997 CDC study found that E. coli cases could be reduced by a whopping 34 percent with adequate hand washing by food preparers. With 25,000 cases per year, that's a significant reduction in E. coli poisoning. Add to that the use of adequate cooking temperatures and pool chlorination, and you've gone a long way toward solving the problem.
Yet the amount of time and resources the USDA uses to educate the public on these simple facts is just a drop in the bucket compared to the resources applied to its huge recall and closure program. Of course, educating the public about proper food handling isn't especially glamorous. Unlike millions of pounds of recalled beef, public service announcements don't give the USDA much to point to when kids are getting sick and their parents are demanding action. And it certainly doesn't win big budget increases from Congress. But until science catches up with our demands for safer food, education is the best weapon we've got.
Winkler G. Weinberg is chief of infectious diseases for the Southeast Permanente Medical Group and author of No Germs Allowed!: How to Avoid Infectious Diseases at Home and on the Road. Ted Geltner is staff writer for the Ocala Star Banner.