It’s no secret that if we really want to further reduce pathogens from meat products, we need to develop and employ new and improved interventions. The struggle, however, is identifying which interventions the government will let us use to hit our targets.

Carcass irradiation has often been cited as a viable way forward in the fight against E. coli O157:H7. In 2004, the American Meat Institute (AMI) submitted a petition to FSIS asking the agency to approve the use of carcass e-beam irradiation technology in meat plants. AMI requested that the petition be granted so that low levels of irradiation could be applied to the surface of chilled beef carcasses.

Notably, when AMI petitioned FSIS, it also requested that the technology be approved as a “processing aid.” This would allow processors to use the technology without having to place special labels on meat processed with the intervention.

Despite the obvious food-safety benefits, however, FSIS has for five years refused to approve the use of this promising new technology. And, to the surprise of many, agency officials announced earlier this year that no decision would be forthcoming soon.

Although FSIS currently allows processors to irradiate ground beef, the technology has not significantly impacted food safety. For starters, irradiation is only applied at levels designed to reduce (and not guarantee the removal of) harmful pathogens. Additionally, the technology when used is being employed at the final stage of processing (on finished product), as opposed to the source (the carcass). And, finally, the public has remained apprehensive about irradiated beef, in part, because FSIS has mandated that processors affix a less-than-enticing radura symbol on treated products. The use of irradiation as a “processing aid” on carcasses, however, would solve most if not all of these problems.

Frustrated by the lack of progress on its long-standing request, AMI recently sent a letter to FSIS urging the agency to take action on the outstanding petition.

Although FSIS asserted when asked that it was still waiting for AMI to address various outstanding concerns about the petition, AMI has consistently reported that it has never received any formal inquiries or concerns from the agency.

According to AMI, there is no justification for FSIS to delay action on the petition. If FSIS were to publish a proposed rule, any outstanding questions regarding the technology, says AMI, could be effectively addressed through the rule-making process which would follow.

Having worked with well-intentioned meat processors for nearly 10 years, and having witnessed the significant criticism industry has received recently from regulators, trial lawyers, media and Congress for “failing to do more,” I too remain concerned by the lack of action by FSIS. Thus, I would also urge the agency to take action on the outstanding petition.

If we truly want to advance food safety, and better target harmful pathogens, we should start by convincing our government to let us use those silver bullets that can help make it possible.

Shawn K. Stevens defends and counsels meat companies in foodborne illness matters throughout the United States. Mr. Stevens also assists industry clients with regulatory compliance, recall planning, crisis management and other issues in advance of and following major food-product recalls. Additional information about his practice can be found at