http://www.salmonellablog.com/ Food Poisoning Lawyer & Attorney : Bill Marler : Marler Clark en Copyright 2011 Thu, 08 Dec 2011 15:05:06 -0800 Thu, 08 Dec 2011 15:05:06 -0800 http://www.sixapart.com/movabletype/?v=4.32-en http://blogs.law.harvard.edu/tech/rss The determination of what constitutes one "LOT" of meat products, and thereby subject to a recall, is made by the meat plant involved, but subject to USDA review. Let me give you an example: the biggest beef plants kill thousands of animals daily. Such plants can easily produce around 1 million pounds of boneless trimmings and fat daily, according to the OIG report subsequent to ConAgra's 2002 recall. Grindable trimmings are typically placed into 2,000 lb combos, and five of these combos constitute a "LOT", for a total of 10,000 lbs of trimmings in one lot. The big packers then collect samples of such trimmings, strictly from the top layer of each combo, until they have 1 - 2 lbs of trimmings for laboratory analysis for E.coli 0157:H7. Although many industry analysts state that testing 1 - 2 lbs out of 10,000 lbs is statistically irrelevent, USDA does not challenge the big packers' definition of a "LOT". Ironically, this definition of a "LOT" totally ignores the potential for cross contamination which likely impacted meat produced before or after the 10,000 lbs. Meat production equipment (conveyor belts, saws, knives, etc) in all likelihood harbored residual bacteria AFTER the 10,000 lbs of trim were produced. Also, if the 10,000 lb lot tests positive, the bacteria may itself have been residual bacteria from earlier production lots. USDA blithely ignores these very real possibilities, and quietly acquiesces to the big packer contentions that testing 1 - 2 pounds out of 10,000 lbs is scientifically defendable. As such, the agency turns a blind eye to cross contamination, as if the fecal bacteria could NOT have been present just prior to the lot, or residual bacteria could not linger on equipment in meat subsequent to the 10,000 lb lot. USDA & FDA frequently state they act out of an "Abundance of Caution". Well, this example proves that our regulatory agencies frequently operate under an "Abandance of Caution". John Munsell

]]> http://www.salmonellablog.com/salmonella-recalls/walmart-cantaloupes-in-carolinas-and-south-hill-virginia-recalled-after-testing-positive-for-salmonella/#13188 http://www.salmonellablog.com/salmonella-recalls/walmart-cantaloupes-in-carolinas-and-south-hill-virginia-recalled-after-testing-positive-for-salmonella/#13188 Salmonella Recalls Sat, 16 May 2009 20:27:46 -0800 marler@marlerclark.com (Salmonella Lawyer)