Comment from Daniel Cahalan, Ph.D.

Document ID: FSIS-2010-0023-0005
Document Type: Public Submission
Agency: Food Safety And Inspection Service
Received Date: November 14 2011, at 04:53 PM Eastern Standard Time
Date Posted: November 15 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: September 20 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: November 21 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80f6c374
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This is comment on Proposed Rule

Shiga Toxin-Producing Escherichia coli in Certain Raw Beef

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Not only should USDA drop its proposed regulation for zero tolerance of six non-O157 serotypes of Shiga-toxin Escherichia coli, but it should actually loosen the 1994 regulation by getting rid of zero tolerance for O157 STEC. (Zero in multiple 375g samples is still zero tolerance.) By now, in 2011, people should know that ground beef must always be cooked well-done, as they have long known for all pork. This would be a costly regulation for consumers and taxpayers due to complicated testing by USDA and companies and due to needless destruction or diversion of meat. Most foodborne illnesses from non-O157 STEC are from uncooked, unpeeled produce, such as lettuce, berries, and sprouts. By the way, USDA's six serotypes don't include O104, which caused the recent large problem in Europe. This would be another costly, needless regulation from the Obama administration.