Following on from my previous post here about the UK’s-but-not-Scotland’s Food Standards Agency giving a qualified green light to the commercial preparation and sale of undercooked burgers, I’ve made a short video setting out my objections. Click here to go to the video on YouTube.
And for those who insist on reading my turgid prose instead of listening to my sparkling delivery, it’s below the fold.
What do unpasteurised milk and rare burgers have in common apart from the cow? They’re both eaten uncooked, therefore any bacteria in the food won’t be destroyed by heat and will present a risk to the health of the consumer. The risks from raw milk were so serious that it was one of the first applications of pasteurisation. When pasteurisation was made mandatory, the numbers of milk-related outbreaks of food poisoning and infant mortality plummeted. Raw milk was a food that killed.
But people forget the past. They forget that thousands of people have died from drinking raw milk, and with the rise of foodie fashions and the desire to get back to “natural” food, whatever that is, ill-informed consumers are now seeking out unpasteurised milk for what are very marginal perceived benefits. Fortunately, here in Scotland, there’s an absolute ban on placing raw milk on the market, even at the farm gate.
And recently we’ve seen the rise of the gourmet burger, artisan-crafted from only the prettiest and most consenting cattle, treated with love and respect throughout the food chain right up to the point the burger is slapped in a bun and you shove it in your face. Now it’s a wonderful thing that people are taking an interest in where their food comes from, because that can only help drive up standards of welfare and transparency in the food and farming industries. And we need the public to have a better understanding of the origins of their food and how animals, in particular, are treated on farm and up to the point of slaughter.
However, food faddists are not content with just sourcing the best quality food, they want to do something that will distinguish their offer to the market from every other burger-flipping Joe on the high street and appeal to the hipsters with money burning holes in their Apple Pay. And hence we see the rise of the rare burger because apparently it’s nicer to eat. Believe me, I like my steak rare, once it’s been seared on the outside. But rare burgers? Seriously? Haven’t these people heard of E. coli O157 or what happened to Mason Jones? Have they not learned the lessons of the John Barr outbreak in Wishaw? Of the burger outbreak in Glasgow last year? Do they really want to be the next set of headlines and have to stand up in a coroner’s court to explain themselves? Well, apparently they do and apparently the Food Standards Agency is happy for them to do so, provided the consumer takes all the responsibility.
So, how did the FSA get itself into such a fankle? It’s actually a confusion between its own founding principles. Before the FSA was established, there was a government white paper which set out the guiding principles for the FSA, which included:
- The essential aim of the Agency is the protection of public health in relation to food.
- The Agency’s assessments of food standards and safety will be unbiased and based on the best available scientific advice, provided by experts invited in their own right to give independent advice.
- The Agency will make decisions and take action on the basis that: the Agency’s decisions and actions should be proportionate to the risk; pay due regard to costs as well as benefits to those affected by them; and avoid over-regulation.
This paragraph from the white paper is highly relevant to this issue:
However, complete freedom from risk is an unattainable goal, and safety and wholesomeness are related to the level of risk that society regards as reasonable in the context of, and in comparison with, other risks in everyday life. In assessing and managing risks, the Agency will need to take very careful account of the expectations of the consumer, recognising that in many circumstances the public is unlikely to be willing to pay the cost of achieving the maximum theoretical level of safety (whether that cost is manifested in higher food prices or in restrictions on freedom of choice).
The end result is that the FSA are inevitably going to be, to some extent, tossed about by the currents of food fashion, or what are referred to as the “expectations of the consumer” and “freedom of choice”.
So let’s examine where the FSA actually arrived at on rare burgers. They say:
The long-standing advice to consumers that they should cook burgers thoroughly to kill any bugs that may be present is unchanged.
However, businesses that are serving rare burgers, should make sure they have a range of controls are in place. These include sourcing meat only from establishments which have specific controls in place to minimise the risk of contamination of meat intended to be eaten raw or lightly cooked and providing consumer advice on menus regarding the additional risk from burgers which aren’t thoroughly cooked. And businesses should provide prior notification to their local authority that they intend to serve rare burgers.
Well, that’s all well and good in the best of all possible worlds, but even in in that ideal world, there will still be a few people poisoned by pathogenic E. coli in those rare burgers, and some of those victims will suffer irreparable kidney damage or be killed.
But we don’t live in a world where such stringent controls are going to be in place all the time, and where all food business operators will be so scrupulous as to follow those controls or even understand how the controls work. This is not a snipe at caterers, but what is proposed is very complex, difficult and time-consuming to validate and verify. And it’s bit of a give-away that the FSA announce that they will be monitoring infection rates from rare burgers. North of the border, Food Standards Scotland are steering clear of this havering and are firmly on the side of the well-cooked burger.
My personal concerns about this approach are five-fold:
- The controls are too complex, time-consuming and expensive to be confident that they can be maintained by everyone throughout the food chain.
- The proposed controls do not eliminate the hazard of coli O157 and there will not, by definition, be a thorough cooking step to destroy the bacteria by heat.
- There are, unfortunately, enough fools and fraudsters out there who’ll have a go at getting away with serving rare burgers without all the controls in place. This policy gives a big flashing green light to everyone who fancies themselves as a gourmet burger-flipper to serve up undercooked burgers and get some of that hipster dough in their own pockets.
- The message about cooking foods such as burgers and sausages all the way through is seriously diluted.
- Finally, this approach effectively removes the protection of food safety law from the consumer and introduces a new rule of caveat emptor – businesses will be able to rely upon their FSA-approved signage, at least until the third Pennington enquiry.
Hugh Pennington, who knows more about the ecology of E. coli than anyone else in UK, considers that the next outbreak of E. coli O157 will be associated with this new fad. He has been quoted in EHN Online as saying that the only safe burgers are either thoroughly cooked or irradiated to kill bacteria. The controls the FSA suggest will reduce the risk if properly applied by careful and competent restauranteurs, but you can already count three assumptions in that sentence. Add to that the vast number of caterers who haven’t a clue what to do, won’t read or follow the guidance and just take it as carte blanche to sell rare burgers and we’ve got a serious public health problem on our hands.
As a reminder of what can happen, there was a recent news report of an outbreak of shiga toxin-producing E. coli at a Worthy Burgers restaurant in Vermont, USA. There, the business proudly marketed their burgers as “served pink in the middle”. And guess what? Six confirmed cases and three probable cases of E. coli food poisoning as of 1st October. The company’s chief executive said, “our customers are telling us what temperature they’d like their burgers”. Vermont Department of Health’s health surveillance epidemiologist had something else to say, “We want people to be cooking their meat to the appropriate temperature, and checking that the meat has reached the appropriate temperature. People go on colour … we would encourage people not to do that.”
E. coli O157 causes serious complications for people infected by it. At best, you’re in for a nasty bout of bloody diarrhoea, at worst you’re dead or lucky just to have irreversible kidney failure. Is that a price worth paying for a food fad?
The decision by the Food Standards Agency, not only to accept the service to the public of undercooked burgers, but also to promote practices which won’t, in reality, protect the consumer is folly indeed. It also firmly establishes the extent to which the FSA, whose remit fortunately no longer runs in Scotland, has allowed political and populist expediency to undermine the independent scientific purposes for which it was supposed to be founded.