The Debate over Samonella Testing
"Test to Punish" or "Test to Find," That is the Question!
By Phil Olsson, Olsson, Frank & Weeda, NMA Legal Counsel - September 5, 2000
USDA is requiring a Salmonella test on each lot of ground beef which it purchases. Where a sample tests positive for Salmonella, the entire 40,000 pound lot is rejected. When USDA first announced this new specification, most of the traditional bidders for USDA's school lunch business withdrew from offering product. Gradually bidders have returned to the market, however bid prices have risen almost 50 cents per pound, so that USDA is now paying $1.46 to $1.60 under the new specifications for product which cost $1.00 to $1.10 under the old specifications. Since announcing its new standards on June 23, 2000 USDA has spent $42,472,000 for ground beef products for schools. This amounts to a premium of approximately $14,000,000 for compliance with the new Salmonella testing specification.
The purpose of the new specification is to reduce the risk that patties will contain the Salmonella pathogen, a bacteria which is killed when beef patties are properly cooked, but which may be transferred to other foods when the raw beef patties are not properly handled. But taking a single sample from a 40,000 pound lot provides no statistical confidence that the lot is free from Salmonella. Baseline data from government testing shows that the average incidence of Salmonella in ground beef is about 7.5 percent. USDA's expenditure of an extra $14,000, 000 to acquire ground beef which complies with its new Salmonella specification has probably only reduced the likelihood that USDA's ground beef purchases are Salmonella free from 7.5 percent to 7.2 percent. As a food safety program or a consumer protection program, this Salmonella testing program is a sham. It is anecdotal testing, not effective testing. In order to have 90 or 95 percent confidence that a 40,000, lot of ground beef is Salmonella free, the government would need to test more than 300 samples drawn from the 40,000 pounds.
Since the government seems to be getting so little additional value for this expenditure of substantial additional money, it is fair to ask why does this modest benefit cost so much. When a processor bids on the new school lunch specification there is a 1 in 14 chance that its product will test positive for Salmonella and have to be diverted to some other use, probably to a cooked product such as chili or taco filling. By the time the product is tested it will have been specially packaged and frozen for delivery to schools designated by USDA. If product is rejected, it will either have to be repackaged and reprocessed, either of which is expensive, or delivered with the USDA labeling to a commercial customer, who will know that this is product without a home and therefore will seek a sharp discount. When the processor makes a bid under the new specifications, it will also be concerned that in the event of a Salmonella test positive, the processor and its suppliers will face intensified regulatory scrutiny by USDA. All of these factors add up so that a 7.5 percent chance of failure results in a 50 percent increase in offering price.
Adding further interest to the new ground beef specifications is the fact that USDA has yet to purchase any ground poultry or ground pork for the current school year. The Department recognizes that it will have to apply the same zero tolerance for Salmonella to purchases of these products, which have a higher incidence of Salmonella then does beef. If this zero tolerance doesn't work for ground beef, it is not going to work for other fresh meats.
The major problem with this kind of end product testing is test results can only be used to take action against the tested product or the processor, and provide no basis for tracing the origin of the Salmonella back to its source. This testing is very effective in imposing a punitive burden on a processor, but not effective at all in stopping Salmonella from getting into the product in the first place.
With this type of "test to punish" program the processor will make every effort within its control not to find the microorganism. A processor will try to use only suppliers which are less likely to have Salmonella on their meat, and doing this may actually help to reduce the Salmonella level. But no supplier can provide an absolute guarantee of Salmonella-free meat, except through the use of irradiation. In addition the processor's other likely response will be to minimize its own testing program, knowing that any positive test result may have costly regulatory consequences. There is a better way to use the millions of dollars which provide so little food safety benefit in USDA's current testing program.
The alternative to "test to punish" is "test to find." In a "test to find" program, the processor is encouraged to test for total bacterial levels, to take environmental samples for pathogens, and to trace pathogens back to their sources.
An effective "test to find" program requires testing product when it comes into the packing plant, so that individual carcasses can be tested and held until test results are back. A "test to find" program helps the packer and USDA learn where pathogens are coming from, unlike testing after meat has been boned and commingled into ground beef so that it is virtually untraceable. In addition "test to find" allows the use of sophisticated quantitative testing to differentiate and deal with the hottest sources of pathogens. As a general policy USDA does not use testing methods which provide quantitative results.
Tracing back pathogens and trying to reduce them at the farm level has been a low budget priority at USDA. For Fiscal Year 2001, USDA will spend approximately $7 million on what is termed "pre-harvest" food safety, much less than the premiums spent during the past six weeks to purchase Salmonella tested ground beef. Obviously farmers do not want USDA's "test to punish" approach extended to their facilities. They see how packers have been subjected to criticism, closures and recalls, even where there has been no reported illness attributed to that product... Perhaps this reluctance to spend money on" pre-harvest" food safety confirms the critics who charge that USDA has a conflict of interest in enforcing food safety laws. Whatever the reason for this reluctance, it needs to change, and the best way to change would be to adopt a prevention-oriented "test to find" food safety program starting at the farm and covering all of the subsequent processing in distribution steps.
It is ludicrous to spend more money on anecdotal testing of school lunch ground beef than on all of the pre-harvest food safety activities. It is time to move away from a testing program which has minimum benefits for students and maximum costs for packers and to adopt a prevention oriented program that will make HACCP a working reality in production activities and eliminate or reduce pathogens to an acceptable level at the source. Not only will a prevention oriented program provide the greatest benefit to consumers. It will also provide the greatest benefit to producers because it will restore confidence in the safety of the great American hamburger.
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