Should all raw foods have warning labels?

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– Opinion –

I am writing this in response to Dan Flynn’s article on raw milk in Food Safety News on April 28. Flynn’s article reported on raw milk legislation currently being considered in Georgia, Missouri and Iowa.

The article reports that Georgia’s proposed Raw Milk Dairy Act, not signed by Governor Kemp, includes several requirements. One is a warning label on the packaging of raw milk which must state: Warning: It is a raw milk product that is not pasteurized and may increase the risk of foodborne illness.

Missouri’s proposed 1977 bill would legalize the retail sale of Missouri-made “Grade A” raw milk and raw cream in grocery stores, restaurants, soda fountains and similar establishments. Raw milk products would also be required to display and carry warning labels indicating “WARNING: This product has not been pasteurized and therefore may contain harmful bacteria which can cause serious illness in children, the elderly and people with weakened immune systems.

The conclusion of the article is as follows: “Pasteurization has prevented millions of people from getting sick. Most public health professionals and health care providers consider pasteurization to be one of the most effective food safety interventions ever performed in public health. So true!

Quoting from Dr. Flynn’s article, pasteurization is the process of rapidly heating milk to a high enough temperature for a short time to kill disease-causing germs. The milk heating process is considered a critical control point, the CCP in HACCP that the USDA Food Safety Inspection Service requires in federally and publicly inspected meat and poultry establishments. ‘State. A CCP is defined as a point in food production where controls can be implemented to prevent, eliminate and reduce pathogens to a non-detectable level. Interventions such as full cooking and irradiation are referred to as CCPs. Other useful interventions, such as temperature control, are checkpoints but are clearly not eligible for critical checkpoints in the absence of a kill or lethality step.

By the way, the HA in HACCP stands for hazard analysis. A thorough risk analysis is of extreme importance and value for all production lines, fully cooked or raw, even for non-food items.

This is precisely why the USDA frequently issues educational warning missives to the public, reminding consumers to properly handle and fully cook raw products that have not been subjected to critical control point intervention prior to sale. to the public. Frankly, the critical control point step in raw foods must be performed by the end consumer, such as restaurants or in home kitchens, where a lethality step can be implemented.

From a public health perspective, the focus is on the word “RAW”, requiring due diligence on the part of the end user to safely prepare raw foods before consumption. The same reasoning is used by the state legislatures of Georgia and Missouri, as noted in Mr. Flynn’s article on legalizing the sale of raw milk in those states.

My goal is not to take a position on allowing or banning the sale of raw milk. I can buy raw milk, but I don’t. Rather, my goal is to ask myself if other raw products, including vegetables, meat and poultry, etc. should bear a warning, similar to the warning labels required on raw milk.

The packages of ground beef in my home freezer all include a label that says “SAFE HANDLING INSTRUCTIONS. In small print are the following instructions: This product has been prepared from inspected and approved meat and/or poultry. Some food products may contain bacteria that could cause illness if the product is mishandled or improperly cooked. For your protection, follow these safe handling instructions. These instructions include warnings to COOK WELL (emphasis mine), keep foods hot and cold, and keep them separate from other foods.

An important point : how can the product be inspected and adopted [under HACCP inspection] may contain bacteria? If the raw meat was produced under HACCP, the meat, per the USDA mandate, cannot contain pathogens!

Mandatory raw ground beef safe handling instructions are a tacit admission that the USDA recognizes that raw meat poses food safety risks. Such instructions should not be necessary, because ground beef—and all raw meats and poultry—processed in FSIS-inspected plants have (1) raw, ground, and/or (2) raw, unground HACCP plans. which would have critical control points to reduce pathogens to less than detectable levels. Since all raw meats and poultry from FSIS-inspected establishments have ostensibly killed off all harmful pathogens, there should be no need to affix safe-handling labels later.

It bears repeating that the true, original, and scientific HACCP was specifically designed to produce consistently safe food for the military and NASA. So, the true HACCP specifically negated the HACCP label for raw food, because raw food does not have a kill step and therefore can easily harbor invisible pathogens. Astronaut food and battlefield rations are all ready-to-eat and definitely not raw. But after the Jack in the Box hamburger epidemic of 1993, the embarrassed USDA Food Safety Inspection Service was desperate to introduce a new system that would ensure safe food was produced. Voila, HACCP was the answer! FSIS intentionally mandated a bastardized version of pseudo HACCP, which included raw meat and poultry under the HACCP umbrella, knowingly in the complete absence of a valid and legitimate critical control point.

Let’s go back to raw milk, the production of which also imposes valuable warning labels for consumers. Since raw milk must carry warning labels, a laudable safety measure, should all raw foods display similar warning labels?

Mr Flynn’s article said: ‘From 1993 to 2012 (19 years), 127 outbreaks were reported to the CDC with links to raw milk. These outbreaks included 1,909 illnesses and 144 hospitalizations. » These 1,909 illnesses are truly unfortunate, causing untold sorrow and pain to many families. I’m surprised the yearly average was only 100, thinking the yearly average was much higher. I would like to know the annual average of illnesses attributed to the consumption of other raw foods, such as leafy green vegetables, cantaloupe, eggs, sprouts, etc. Despite the much-lauded, but unscientific, HACCP mandate for raw meat and poultry, the industry is making no progress in eliminating salmonella from raw foods. At some point, FSIS must realize that without a legitimate critical control point destruction step, Salmonella will continue to persist in raw foods, spawning countless other illnesses and recalls.

For this reason, shouldn’t all raw foods be labeled with warning instructions? If not, why are raw milk and ground beef distinguished and must they be properly labelled?

We must remember that the end user must do their part in preparing food that is always safe for the consumer. Only when all food undergoes a valid killing stage before sale to the public and sold “ready to eat” will consumers be off the hook for their share of the farm-to-fork continuum in food security. This will never happen, because we all buy raw foods such as ground beef, chicken breasts, turkey and lettuce, which we will prepare at home. Thus, end users simply have to accept some responsibility for handling and cooking raw products properly.

Finally, we have to admit that the USDA Food Safety and Inspection Service will totally oppose my recommendations. Why? Because their “version” of HACCP would prevent, eliminate and reduce pathogens to an undetectable level in raw meat. Thus, no need for warning labels on any raw meat produced according to its HACCP protocol.

The USDA’s implementation of its intentionally flawed HACCP protocol has put American consumers to sleep, discouraging us from practicing safe handling practices.

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