The Complex Origins of Food Safety Rules--Yes, You Are Overcooking Your Food

U.S. agencies recommend temperatures and times far beyond those supported by science















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Where artisanal cheese producers have more public support, the laws allow raw milk cheese. Raw milk cheese is a product of small-time artisans. As of this writing, no large, politically connected producers are making these cheeses in the U.S., so no movement has emerged to make laws on raw milk cheese more consistent and reasonable.

Bureaucracy affects food safety rules in more subtle ways as well. Changing a regulation is always harder than keeping it intact, particularly if the change means sanctioning a new and strange food or liberalizing an old standard. No one will praise public health officials and organizations for moist pork chops, but plenty will heap blame should someone fall ill after regulators relax a safety standard.

Misconceptions About Chicken

The misconceptions surrounding chicken are in some ways similar to those that plague pork but are arguably even more confusing because of conflicting standards and widespread blurring between fact and fiction. First, the facts: chickens can indeed host asymptomatic Salmonella infections, and it is not uncommon for chicken feces to contain high levels of the pathogenic bacteria. Moreover, chickens are typically sold whole, which means that they may carry remnants of any fecal contamination of the skin or interior abdominal cavity that occurred during slaughter and processing. That’s why chicken and chicken-derived products are considered such common sources of foodborne Salmonella .

As with Trichinella and pork, however, the link between contaminant and food has been exaggerated. Many people believe, for example, that chicken is the predominant source of Salmonella . That’s not necessarily the case. In a 2009 analysis by the CDC, Salmonella was instead most closely associated with fruits and nuts, due in part to an outbreak linked to peanut butter in 2006. Indeed, the tally of outbreak-linked foodborne illnesses attributable to produce was nearly double the tally of such illnesses associated with poultry, and the foodborne pathogen most commonly linked with poultry was not Salmonella but the bacterium Clostridium perfringens.

For ready-to-eat food products, including rotisserie and fast-food chicken, the FSIS calls for a 7D reduction in Salmonella levels. In 2001, the FSIS developed a corresponding set of time-and-­temperature tables for chicken and turkey products according to their fat content. The tables, based on the research of microbiologist Vijay K. Juneja, Ph.D. and colleagues at the USDA Agricultural Research Service, include fat contents as high as 12 percent and recommended temperatures as low as 58 degreesC / 136 degrees F . As we’ve previously discussed, that set of standards has been challenged as overly conservative by an advisory panel, which instead suggested a 4.5D reduction, allowing a 36 percent decrease in cooking times from the FSIS 7D standard.

In 2007 Juneja’s team published the results of a study directly examining Salmonella growth in ground chicken breast and thigh meat. The data show that cooking chicken meat at temperatures as low as 55 degrees C / 131 degrees F for much shorter times produces a 6.5D reduction. The researchers’ curve is quite similar to the FDA’s 6.5D reduction curve for whole-meat roasts, except for a sizeable divergence in time at the 60 degrees C / 140 degrees F temperature point.

So who’s right? Technically, destruction of Salmonella can take place at temperatures as low as 48  degrees C / 120 degreesF given enough time. There is no scientific reason to prefer any one point on the reduction curve, but the experts who formulated the FSIS ready-to-eat standards arbitrarily decided to go no lower than 58  degrees C / 136  degrees F . Likewise, officials preparing the FDA Food Code and other reports chose 74  degrees C / 165  degrees F as an arbitrary cut-off. The choice seems to have been based not on science but on politics, tradition, and subjective judgment.



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  1. 1. vmfenimore 12:20 PM 3/13/11

    Well that explains why the time i accidentally cooked my pork roast to the internal temperature of rare/medium rare beef (140 F) it was so good !

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  2. 2. Soccerdad 07:43 PM 3/13/11

    Fantastic article - thanks.

    Personally, I love a rare hamburger (red, not pink). And I'm frustrated by the refusal of most restaraunts to cook it that way. Generally, even if they say they cook to order and will cook it rare, it comes out medium or worse.

    I even had a T bone steak recently which I ordered rare come out more like medium. Nothing unusual there, except the cook claimed that the local health inspector was requiring that steaks need to be cooked to 125 internal temperature!

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  3. 3. skybluskyblue 11:40 PM 3/13/11

    I believe that these over-cautious public health recommendations are also applied to handling pets. This in turn causes some people to consider pets necessarily "dirty". This is untrue for well cared for pets [there should be no other standards really]. Thus many people who own pets are at a disadvantage in many parts of their lives such as finding housing and in court disputes.

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  4. 4. wayt in reply to Soccerdad 04:48 PM 3/14/11

    As the authors point out in the book, it's important to keep in mind that ground meat (or meat tenderized by puncturing) is more susceptible to contamination because external surfaces are mixed into the interior of the food. Any bacteria that get onto the outside of the meat during handling can thus be spread throughout the meat, which doesn't happen in intact muscle meats like well-butchered steaks.

    It is thus riskier to eat ground beef that is rare, and if you don't have complete confidence in the hygiene of the butchering and handling that went into the preparation of the ground meat, the safest course is to cook the meat longer or to a higher temperature.

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  5. 5. oldfartfox 05:22 PM 3/14/11

    I plan to grill a steak for dinner tonight. Seared on the outside and running red when cut. If it don't bleed it's burnt! As for pork, pink inside running clear juices on the plate is just fine. I also prefer limp bacon. Runny eggs go great with it. Sushi is also a part of my diet. If Big Brother doesn't like it, he can shove it.

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  6. 6. FlashRiot in reply to oldfartfox 01:13 PM 3/17/11

    Big Brother isn't forcing your hand in your own kitchen. You are free to take your own risks there, this article discuses regulations for food manufacturers and restaurants.

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  7. 7. FlashRiot 01:19 PM 3/17/11

    While I agree that many of the regulations are arbitrarily assigned and influenced by factors other than safety, I can't help but think that I'd rather not risk a food-borne illness (especially for someone who's immunocompromised) just for the sake of a slightly more delicious pork chop.

    I'd rather be overcooking food than risking undercooking (due to faulty thermometers, cooks who don't know any better, etc.) because the food safety guidelines are right on the cusp of safety.

    I think the bigger issue is how food manufacturers may be taking advantage of these extreme cooking guidelines to be more slack with their microbial control. If they know it'll be cooked to a 12D level of destruction, what's the incentive to use good manufacturing processes?

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  8. 8. thixotropic in reply to wayt 12:25 AM 3/24/11

    I am grateful that this article is here because I too love a rare steak, carpaccio, and sushi, but as wayt pointed out, ground beef is an exception.

    Ground beef is probably not safe unless you see it ground for yourself by a butcher you trust. Any given pound of commercially-produced ground beef can and does contain pathogens from literally thousands of cows, usually dairy cattle worn out by several years of filthy conditions, rBGH, antibiotics, and chronic low-level infection. To that, add scrap meat from all over the country, and grind. It's a food safety nightmare.

    Because of this the meat packing industry has (once again!) started to use ammonia gas to "disinfect" ground beef, a practice exposed by Upton Sinclair's The Jungle, which detailed the horrific conditions for humans, animals, and our food in the meatpacking industry of the time. Legislation ensued, and for perhaps 50 years we had reasonable standards for meatpackers. This has since been undone, and now we're back (once again!) to having immigrants paid in dirt perform this work, on lines whose speed has been increased again and again, rendering it impossible for even the most conscientious gutter to ensure that there isn't shit in the meat. We're right back where we were at the start of the 20th Century in terms of labor and animal abuse, and right back where we were in terms of food safety.

    I encourage all readers to purchase their meat from smaller, more local vendors -- the reward in taste, nutrition (e.g. grass-fed meat), and safety is more than worth it. If you are reading this article to begin with, you are likely to notice and appreciate the difference!

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  9. 9. dschaffner 03:56 PM 4/7/11

    Readers of this article might be interested in my response to this excerpt posted here: http://barfblog.foodsafety.ksu.edu/blog/147413/11/03/27/more-modernist-cuisine-and-bad-microbial-food-safety-colbert-careful-clostridiu

    In short, while I agree that some standards today are inconsistent, the authors do make some microbiological errors that would lead to food safety problems.

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