The first illness began on March 2, 2019. By April 8, 96 people from five states had been reported as ill from E. coli O103, with 11 hospitalized. With the outbreak being investigated by CDC, FDA, USDA/FSIS and several states, it was not until April 12 – now with 109 cases in six states – that CDC announced that “Preliminary information suggests that ground beef is the source of this outbreak.” So, it took almost six weeks from the first illness to the point that we got a preliminary association with ground beef, and there is still no indication of where in the supply chain the contamination occurred. CDC noted that the multistate investigation began on March 28 when officials in Kentucky and Georgia notified CDC of the outbreak – that is almost 4 weeks after the first case. Why so long to involve the CDC? Even if a definitive (or suspected) source is found soon, I have to ask: Why does it take so long to identify the source in so many outbreaks? Having been at this game for a long time, I do understand the complexity of the food supply chain; I realize the vastness of linkages up, down, and sideways; and, as most of you know – I have been an FDA official myself struggling with this issue and getting into some serious tongue lashing by Congress as to why it takes so long. Is this a lack of technology, a regulatory failure, or an unwillingness by industry to make the investment in product tracking systems due to a lack of ROI – or a combination of all of these? Today’s technology can provide us with insights that were not possible even a handful of years ago. FDA’s foods program has been utilizing whole genome sequencing (WGS) since 2008, but it has only been used for outbreak investigations through the GenomeTrakr Network since 2013. CDC’s PulseNet system has been around much longer, having originated in 1996, but only within the last few years has it begun switching its global standard from PFGE to WGS which gives a more detailed DNA fingerprint than PFGE, enabling genetic linkages of pathogens across time and space. But going even deeper than the DNA insights of an outbreak is the ability of today’s technology to trace a food forward, backward, and sideways. The technological ability is there, but with the regulatory requirement being only one-forward/one-back, the incentive is, unfortunately, a bit lacking. Blame it on cost. Blame it on the want of time to thoroughly investigate the options. Blame it on a lack of higher-up support. We can blame it on all sorts of things, but there’s no denying that the industry could, and can, do better. The CDC Investigation Notice of April 9 states that “State and local public health officials are interviewing ill people to determine what they ate and other exposures in the week before their illness started. Federal and state regulatory officials use that information to guide efforts to identify a contaminated food and trace it to its source.” Imagine if we could input the what and where these people ate into an industry-wide tracing system. Imagine if that technology could parse out the common denominator(s); trace that backward, forward, and sideways; and spit out not only the source ingredient/establishment, but every food that contained it, and retailer and restaurant that carried or used it. With what we’ve seen through blockchain and other such technologies, I sincerely believe that ability exists. And from that, simply imagine how far we could reduce foodborne illnesses and all its implications and effects. Besides the consumer health improvements … Think about recalls. It’s likely that these would increase in the short-term, but long-term – the sooner a source was identified, the sooner it could be pulled from the food chain, and the fewer foods it would likely be used in – reducing both recalls and outbreaks. Think about the cost and time savings for every business involved. Think about consumer trust. There is not currently a lot of trust in “big business” or in much of the food chain (watch this space – we’ll have an article on that coming up very soon). While there are a number of factors that go into trust, I’m quite sure that a reduction of recalls and outbreaks would play a significant part in regaining that. The E. coli O103 investigation is ongoing, but it now looks like it is going to be ground beef. But where did the contaminated ground beef come from, and what is the common source? We have to find a way to move faster in these types of outbreaks, and that will require a commitment and resources from the government at the state and federal levels, likely new regulations and, of course, industry at all levels – including retail and foodservice – using the technology that is already available. About The Acheson Group (TAG) – Led by Former FDA Associate Commissioner Dr. David Acheson, TAG is a food safety consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With in-depth industry knowledge combined with real-world experience, TAG’s team of food safety experts help companies more effectively mitigate risk, improve operational efficiencies, and ensure regulatory and standards compliance. Learn more at: www.AchesonGroup.com
