It has been over a year since the Food Safety and Inspection Service (FSIS) declared six non-O157 STECs as adulterants on raw non-intact beef, and almost five months since the agency started testing beef trimmings for these pathogens. Now, FSIS will conduct for-cause Food Safety Assessments (FSAs) following an agency or establishment positive non-O157 test. In addition, FSIS will verify that establishments producing trimmings have considered non-O157 in their hazard analysis during routine FSAs.

For slaughter establishments, this means a prudent establishment would review its food-safety system to determine if the system effectively addresses non-O157 STECs. Interestingly, FSIS does not expressly require a HACCP reassessment unless the agency or the establishment has a positive non-O157 test result. Nevertheless, in practical terms, the most effective way to consider non-O157 STECs is to conduct a reassessment (and, as required by 9 CFR 417.4 (a)(3)(i), document it).

FSIS has stated repeatedly that interventions which are effective for E. coli O157:H7 are equally effective for the non-O157. This position makes sense since virtually all the interventions are designed to address pathogens generally and are not targeted to E. coli O157:H7 specifically.

Beyond asserting the effectiveness of the intervention, a slaughter establishment would be well-advised to conduct some degree of non-O157 testing. At this point, we do not have hard data on whether incoming cattle at a specific establishment can harbor non-O157 and not E. coli O157:H7. So testing for only E. coli O157:H7 may not provide a true indication that the interventions are being operated effectively. There has been no guidance from FSIS on the degree of sampling expected, but establishments who have conducted this testing have taken at least 100 samples per plant. Even if these results demonstrate the effectiveness of the system, some ongoing non-O157 sampling, as a verification, should still be conducted. This will establish more plant specific information relative to the type of cattle slaughtered, seasonality, changes in employees, etc.

With FSIS non-O157 sampling of trim implemented, the question is, where FSIS will go next? The agency has two options: initiate non-O157 sampling of other raw ground-beef components (e.g., head/cheek meat, weasand meat, and bench trim), or start testing ground. Based on the data showing that E. coli O157:H7 is more likely found in components than in finished ground, we anticipate FSIS would move to the other raw ground components first. Given this, slaughter establishments should review the effectiveness of their food-safety programs for these products.

For the grinder, merely because FSIS has focused on components and not finished ground does not mean grinders should sit back. Non-O157 STECs are currently adulterants on all raw non-intact product including ground. Testing by customers or having a ground product implicated in a non-O157 outbreak can change the regulatory landscape in a flash.

Communication now can minimize problems later. Grinders and other purchasers of raw beef for use in non-intact products (such as needle-tenderized steaks) should reach out to their suppliers.

• Have the suppliers considered the hazard of non-O157?
• Have the suppliers conducted any non-O157 testing to support a determination that non-O157 is addressed with existing controls?
• Are the suppliers conducting on-going testing to support their hazard analysis?

A grinder could consider modifying its purchase specifications to request the Letter of Guarantee specifically provide that the interventions are validated for all STECs. Also, grinders should ensure suppliers conduct some ongoing check sampling for non-O157 STECs as a means to verify the interventions are continuing to be effective.

Whether the suppliers respond to their customers individually or make the information available on the Web or otherwise, customers need and have a right to know whether non-O157 STECs have been addressed.

To be sure, there are no requirements currently applicable to grinders, but taking action now could minimize the potential for illnesses and that is the ultimate goal.