There have been recent examples of recalls for pathogens in raw products, even if the pathogen is not generally an adulterant in such products. These recalls have involved raw ground products bearing Salmonella and E. coli O26. One can expect such recalls will become even more common and establishments should understand why.
By definition, a pathogen can cause illness. However, for the pathogen to be an adulterant under the Inspection Acts, where the presence of the organism will trigger regulatory action, FSIS must demonstrate either: (1) under ordinary conditions of use, the pathogen could cause illnesses; or, (2) in a specific situation, the presence of the pathogen in the production of one particular product has directly caused illnesses.

The first class of adulterants, those causing illness under ordinary conditions of use, is much more familiar. There is no dispute that the presence of pathogens, such as Salmonella, E. coli O157:H7 and Listeria monocytogenes, in a ready-to-eat product can cause illness because the product will not receive an additional lethality treatment under ordinary conditions of use.