In turn, FSIS will continue sampling finished product from grinding establishments, in some cases at retail and also in the regular course of foodborne illness and outbreak investigations. Under the new policy, if a sample tests positive, even if only presumptively, a swift investigation will be triggered.

If FSIS discovers that the source materials for a specific product testing positive for E. coli O157:H7 (or other non-O157:H7 STECs) originated from a single establishment, then FSIS will conduct an inspection at that facility to determine the cause of the contamination. FSIS Enforcement Investigations and Analysis Officers will visit the suppliers at issue to review their HACCP and microbiological testing records. If FSIS uncovers any evidence of insanitary operations or widespread contamination (such as a local or systemic High Event Period), the agency may conclude that a recall of beef trim (or, in some cases, beef primals) is needed.

In the event the source materials for a specific grind that tests positive originate from multiple establishments, then FSIS will conduct a similar investigation of all establishments involved. Based upon this investigation, if it appears using the same methodology that the source materials originating from one establishment are more likely the cause of the contamination than the others, then FSIS may require a recall of other products from that establishment that may also have become contaminated.

FSIS will begin enforcing the new rules this month. In turn, FSIS anticipates that the new policy will result in about another 12 ground beef recalls each year. Thus, to avoid being targeted by FSIS, make sure you focus on your own process controls, and respond quickly and appropriately to any High Event Periods, as the battle to eradicate E. coli and other harmful pathogens continues to grind on.