E. coli O157:H7 Just One Among Many Shiga Toxin-Making Bacteria (Part 2)

Part 1: Shiga Toxin: One Of Man's Most Lethal Poisons
Part 3: Shiga Travels To Kidney. Commits Lethal Deed.
Part 4: Marler Clark Holds USDA To Their Food Safety Mission, Legally
________
Shiga toxin is so formidable that in 1994 the USDA/FSIS* declared one bacteria which makes shiga, E. coli O157:H7, to be an adulterant. That was soon after a 1993 outbreak (from Jack in the Box hamburgers) that left over 600 people sick and 4 dead - all from shiga-making E. coli. It was the largest and deadliest E. coli outbreak ever recorded. Since USDA/FSIS can seek the recall of food that is "adulterated," this led to increased surveillance for E. coli 0157:H7.

* FSIS: Food Safety and Inspection Service. It's the food safety arm of the USDA.

But E. coli O157:H7 aren't the only bacteria that make shiga. There are E. coli O146:H21, E. coli O121:H19, and E. coli O111, which were responsible for the illnesses of June Dunning, Megan Richards, and Shiloh Johnson, respectively. Ms. Dunning died from her illness.¹

There are also:²

• E. coli O83:H8
  
• E. coli O8:H16
  
• E. coli O15:H16
  
• E. coli O15:H17
  
• E. coli O88:H38
  
• E. coli ONT:H51
  
• E. coli ONT:H2
  
• E. coli ONT:H10
  
• E. coli ONT:H7
  
• E. coli ONT:H46

And:³

• E. coli O26
  
• E. coli O103
  
• E. coli O121
  
• E. coli O145

They're all shiga toxin-producing E. coli (STEC).

The CDC says there are "at least 150 STEC serotypes ... associated with outbreaks and sporadic illness."⁴ Some STECs are more virulent than others.

150 types, but the USDA won't declare any other STECs to be adulterants except for one: E. coli O157:H7. Why? Bill Marler says: ⁵

"The declaration of E. coli O157:H7 as an adulterant was met with strong opposition from the meat industry. In a lawsuit filed soon after the 1994 declaration, the industry accused the USDA of not following proper rulemaking procedures and of acting in an arbitrary and capricious manner beyond its legal authority. The United States District Court held, however, that the USDA was allowed to interpret the FMIA* and that the USDA has the power to declare substances to be adulterants with the intended purpose of spurring the meat industry to create and implement preventative measures."

* FMIA: Federal Meat Inspection Act

The USDA is tasked with assisting farmers, ranchers, and meat producers in the sale of their products. They're also tasked with ensuring that meat, poultry, and eggs are safe to eat. That's an interesting juxtapostion of tasks given that what's good for business isn't always good for the public. Imposing upon producers the need to implement prevention strategies for a range of shiga-toxin-making bacteria would be a hardship for business.

Continued...
Part 3: Shiga Travels To Kidney. Commits Lethal Deed.
________¹ USDA Should Declare non-O157 E. coli an Adulterant, Food Safety News, October 2009
² Presence and Characterization of Shiga Toxin-Producing Escherichia coli and Other Potentially Diarrheagenic E. coli in Retail Meats, Applied and Environmental Microbiology, January, 2010.

"This study demonstrated that retail meats, mainly ground beef, were contaminated with diverse STEC [Shiga toxin-producing Escherichia coli] strains."

³ Prevalence Of Non-O157 Enterohaemmorrhagic Escherichia Coli In Retail Ground Beef In The United States, Marler Blog, May 2009
⁴ Recommendations For Diagnosis Of Shiga Toxin-Producing Escherichia Coli Infections By Clinical Laboratories, Morbidity and Mortality Weekly Report, October 2009
⁵ Why Should the Food Safety and Inspection Service Declare Enterohemorrhagic non-O157 E. coli to be an Adulterant?, Bill Marler, October 2009