I read with interest your editorial entitled "USDA wants to tell you a story" on page 6 of the September edition of MMT.  As Paul Harvey says, I'd like to tell you "the rest of the story".

An introduction is necessary.  My firm, Montana Quality Foods & Processing, experienced four e.coli positive ground beef tests in January and February of 2002.  USDA's coverup of the source of this contaminated meat has been the subject of several articles, including one written by Daniel Yovich in the April, 2003 edition of MMT, on page 14.

FSIS has milked for all it's worth a reputed diminished incidence of e.coli between the years 2002 and 2003, which I'd like to address.  The same scintillating evidence was presented on page 24 of "The National Provisioner" in its March, 2004 publication, which quoted ".....FSIS saw a significant drop in the number of positive samples in ground beef.  In 2003. of the E.coli 0157:H7 samples collected and analyzed, 0.31 percent tested positive, compared to 0.78 percent in 2002 or a 60 percent reduction (italics and emphasis added) ,  Murano reports.  [This is a definite improvement - and the strongest signal that science can drive down the threat from pathogens"].  End quote.  Let's indeed compare the marvels of science, versus the devious sampling regimens concocted by FSIS.

Back in 2002, USDA/FSIS had in place a "15 Sample Protocol", a policy which indisputably protected public health and furthered the concept of safe food.  Whenever a plant experienced a positive e.coli lab test, the agency immediately followed it up with an additional 15 consecutive lab tests, the results of which indicated if the plant was a problem plant with recurring sanitation problems, or the results could indicate that the one positive was merely a blip on the radar screen.  Three of the subsequent 15 samples taken at my plant were positive, and the origin of all three was copiously documented by both the USDA inspector and plant personnel as having emanated from ConAgra.  As history has shown, the agency rejected all the documentation, and took no enforcement action against ConAgra.

A mere four months later, an exact replica of our dilemma recurred at another very small plant, Galligans Wholesale Meats in Denver, a plant which does not slaughter.  The agency's "15 Sample Protocol" again produced an additional three subsequent positive samples.  Fortunately, Galligans' plant management as well as the local inspection team documented the origin of all 3 subsequent positives to have emanated from ConAgra. In this case, the agency was finally willing to perform a traceback, and the news-breaking ConAgra 19 million pound recall immediately ensued.

The value of the agency's "15 Sample Protocol" proved itself in grandiose form in these two incidents.  Understandably, the ConAgra recall was publicly embarrassing not only to ConAgra, but especially to FSIS.  The OIG report of the ConAgra fiasco was highly scathing of the agency's mishandling of ConAgra's recurring pathogen problems.  This OIG report would not have transpired if the "15 Sample Protocol" had not been in existence.

So, how has the agency improved on this protocol?  The public would be shocked to find out that the "15 Sample Protocol" has been rescinded by the agency!

Think of the long-term advantages to the agency of rescinding this protocol.  If the protocol would not have been in existence in 2002, the six subsequent positives at my firm and Galligans would not have been recorded.  Multiply this by how many dozens of other firms which experienced the same dilemma, and you can see how the agency has concocted a biased, procrustean sampling procedure which resulted in a substantial reduction in e.coli positive samples in 2003 (in the absence of the protocol), as compared to 2002 (which utilized the protocol).  The previously-mentioned quote by Elsa Murano in the National Provisioner did not mention this evolutionary change in agency policies, for obvious reasons.

Similarly, I have a report which describes how the agency has rewritten its Salmonella testing program, with the same goal in mind.  I have yet to read it in detail, so I cannot comment on it.  If you are interested, I'll gladly send you a copy.  To date, I have yet seen no report dissecting the agency's listeria sampling policy.

In a directly related subject, did you know that when a FSIS inspector takes a ground beef sample for agency E.coli analysis, the inspector is prohibited from documenting the origin of the meat?  Shocking, but Rev. 1 of FSIS Dir. 10,010.1 specifies that such documentation is not to commence until 3 or 4 days after the sample was taken, when the USDA lab declares the sample to be presumptive positive.  By this late date, the trail has turned cold, and the validity of plant-reported source origination evidence cannot be verified.

FSIS sampling policies have been specifically designed to obfuscate the origin of contaminated meat, virtually eliminating the possibility of a traceback to the true origin of contamination.  Instead, a close examination of recalls in recent years proves that the agency places all responsibility for contaminated meat on the down-line further processors which are guilty of innocently and legally purchasing previously-contaminated meat.  It is also ironic that all such meat arrives at their docks in containers bearing the official USDA mark of inspection, a direct benefit of deregulated meat inspection to the big packers.

I noticed that the title of your article did not say "USDA wants to tell you the truth", but said "USDA wants to tell you a story".  While the agency hides behind the statement that HACCP is science based, the "true story" is that some of the agency's policies are based in political science which cannot withstand cross examination by the scientific community.

Next time you hear the agency piously proclaim victory in its battle against food-borne pathogens, study the details of their sampling protocol.  USDA is cooking the books, just like Enron did.