Why isn’t the USDA declaring the invisible feces in our meat?

No, that wasn’t a typo. Today I came across this petition for rulemaking to FSIS from the Physicians Committee for Responsible Medicine.

First off: PCRM has some great programs that promote research, animal welfare, and better medicine. The overall merit of their organization cannot be judged by a single program or campaign they have in place.

Now let’s tear this petition apart, because I actually had to check their website to make sure it was real, and not an over-the-top satire from The Onion.

The concern the committee wishes to correct via this petition is thus:

“Inconsistent with its statutory mandate, USDA regularly passes at inspection meat and poultry that is  contaminated with feces. Although USDA implements a “zero tolerance” policy for fecal contamination, this policy applies to visible fecal contamination only. The result is that fecally contaminated meat and poultry products pass inspection as long as the feces on them are not “visible” to the naked eye.

This inspection policy conveys a misleading promise of “wholesomeness.” Feces may contain round worms, hair worms, tape worms, and leftover bits of whatever the animal excreting the feces may have eaten, not to mention the usual fecal components of digestive juices and various chemicals that the animal was in the process of excreting. Americans deserve fair notice that food products deemed “wholesome” by USDA would be deemed disgusting by the average consumer and adulterated under any reasonable reading of federal law.”

Not to quote without context, the petition goes on to list the ways in which non-obvious feces may be introduced to meat product, the most valid being shared scald/chill tanks in processing operations.

Ultimately, the corrections the committee is seeking are removal of the “wholesome” description from USDA inspected meats, begin treating feces as an adulterant, and:

“USDA should amend sections 317.2(l)(2) and 381.125(b)(2)(i) of the Code of Federal Regulations to exclude from the current mandatory label the sentence that reads, “This product was prepared from inspected and passed meat
and/or poultry.” USDA should amend sections 317.2(l)(2), 381.125(b)(2)(i), and 381.125(b)(2)(ii) of Title 9 to include in the mandatory label the following as the second-to-last sentence: “This product may be permeated with feces, which cooking does not remove.”

That’s some pretty heavy language, perfectly stated to play on the fears and squeamishness of your average consumer. However, I see nothing written there about food safety, so the intention of the change is obvious: prevent people from eating meat.

While the about page for PCRM mentions nothing about being proponents of animal rights, the amount of articles devoted to encouraging a purely vegan diet clearly shows that they have an anti-meat agenda. While they correctly advertize the health benefits of vegan foods, a quick search of their website saturates any visitor with the message “meat is bad, and animal agriculture is always cruel”.

The petition shines a light on a group that is ready to intentionally scare and mislead consumers into changing their lifestyle. As part of their justification that feces is everywhere, they cite one of their own studies, “Fecal Contamination in Retail Chicken Products“. In this study, the committee proved that invisible fecal contamination is everywhere by “testing for the presence of feces.”

No such test exists.

What they actually did was test for generic E. coli, which can act as an indicator organism for fecal contamination.  HACCP programs in slaughter facilities use on-line enumeration of E. coli and other coliforms to validate critical control points for just that purpose. But in this case, rather than setting limits and using a statistical rationale to make a conclusion about the level of contamination, it appears that any evidence of the presence of E. coli  led to the determination that the sample was contaminated with feces. Because there are no methods declared, this evidence could be as mundane as RNA fragments from a non-pathogenic strain recovered in an enriched sample.

The study is absolutely meaningless. There is no available data to review in terms of the levels of contamination, no methods listed for how the E. coli was enumerated, and finally no legitimate publication, suggesting that the construction of the study and its conclusions would not have passed peer review.

As part of the rule change, PCRM would like feces to be declared as an adulterant. Generally, USDA inspectors cannot allow adulterated products to enter commerce, adding to the ludicrosity of this proposal. By the PCRM’s definition, all meat products are covered in invisible feces, and the presence of invisible feces should prevent any product from entering commerce. In one swift move, PCRM will ensure that only clean, wholesome meats will be sold, i.e. none.

But have things changed over the years to make eating meat less safe? The PCRM thinks so. I have no data to argue whether or not Americans are cooking less (PCRM also neglected to provide data), and eating more RTE products, but I did think it was funny that when I read this:

“Americans today consume far more meat and poultry than ever before, thereby increasing their potential exposure to fecal contamination in these products”

When the first link I read on their website contained this graph…
Which is it PCRM? Whichever is more convenient for the ad campaign at the time?
(side note: if people indeed are eating out more in restaurants, that would mean they are eating at inspected restaurants where county health inspectors ensure adequate cooking temperatures, rather than at home where people rarely if ever have proper process control)

Finally, the idea that the USDA needs to declare the presence of invisible feces on every product that passes inspection makes no logical sense,  and does nothing but mislead the consumer, not only by implying that the product isn’t safe in general, but that fully cooking the product makes no difference. If it wasn’t obvious by now that this proposed rule change isn’t solely to earn points with vegans, look closely the wording. In order to turn consumers off meat, PCRM would risk undoing years of public education and trust in proper cooking temperatures.

Clearly I took this proposal too literally, but because FSIS will actually have to review the proposal, and PCRM wants to brag about how these changes might occur, I offer one last piece of evidence to support my view that this proposal belongs on a tabloid.
Proposed legends

…one of their proposed inspection marks literally contains a DO NOT EAT symbol.


Physicians Committee for Responsible Medicine (2013). Re: Fecal Contamination of Poultry and Meat USDA Petition for Rulemaking


New Research: Do organic animal operations encourage management decisions that negatively impact animal welfare? Part 1

For my senior ethics class, I chose to write about an issue everyone has an opinion on, from granola folks at the co-op telling me to watch Food Inc. to farmers complaining about the outbreak of upper respiratory disease from those untreated organic herds sneezing over the fence. I actually ended up changing my own views quite a bit following the extensive research I did, and I really enjoyed writing the paper. I wanted to evaluate the claims often made to me by professors in my land grant school (Oregon State) about the misleading advertizing and hidden evils of organic production, and I wanted to see if there was anything to back up the fanaticism and devotion sometimes projected by organic devotees. This paper is by NO MEANS an exhaustive review of the literature, and I am not qualified to make any official judgement, and is simply meant to be a personal commentary from a recent graduate.

So rather than sit here blathering, the first portion is below, and you can read the full paper here.


Few agricultural debates come close to generating the same passionate and heated responses that organic farming seems to elicit. The discussion surpasses the interests of producers with conflicting ideologies to be hotly debated by assertive consumers as well; people who highlight the paradox created by their interest in the safe and responsible production of their food, while avoiding all involvement in its creation. The originally proposed Organic Foods Production Act of 1990 received nearly 300,000 comments on the proposed requirements, more than any other piece of legislation in history (Vos, 2000). Clearly this indicated that the role organic farming played in food production was extremely important to U.S. citizens then, and continues to be a relevant topic as organic operations have grown by 40-50% every five years since 1992 (USDA, 2010).

The general public also has a strong interest in the way animals are managed, especially when management techniques play a role in the health or well-being of the animals prior to their use for meat, milk, or eggs. Humane management is often brought up when discussing the merits or flaws of organic operations, and is extremely important to producers due to the important role animal welfare plays when consumers make purchasing decisions. Prickett et al. (2010) found through the use of a telephone survey that 49% of consumers consider the well-being of farm animals when purchasing meat, and 83% of consumers disagree that lower prices are more important than the well-being of the animals used. These numbers become critical when organic producers need to justify the increased cost of their products and conventional producers are forced to avoid the alternate impression that their animals are treated poorly.
Marketing pressure placed on both groups leads to a vicious back and forth of both valid questions and vague accusations, among which is the suggestion that organic farms can act as reservoirs of disease (Kijlstra and Eijck, 2006). One mechanism for this accusation could be the avoidance of chemical or synthetic intervention for pest control and treatment of disease. This paper seeks to evaluate organic farming ideologies and legal constraints that create ethical dilemmas surrounding animal welfare, and determine whether organic management encourages decisions that are detrimental to the animals involved.

Animal Welfare and the Organic Movement
Early organic movements were created with the goal that a more sustainable and environmentally friendly farming system could be created that would benefit not only farmers and consumers of organic products, but also the animals within this system (Lund, 2006). These ideals have persevered and are a common talking point in promotional materials that market organically raised animals as drug and chemical free, and much closer to a “natural” condition (Riddle, 2005). This concept of “natural” is commonly used to differentiate organically produced animal products from conventional ones.

Utilizing the word “natural” creates an issue of perception; while the public widely accepts “natural” as a product descriptor, the word itself has no legal definition when used in food advertizing or packaging in the U.S. However, consumers have been shown to associate descriptions of “naturalness” not only with animal welfare but sustainability and care for the environment (Verhoog et al., 2003). While this may imply a scheme to sway consumer loyalty, the word is widely accepted by organic producers as an accurate descriptor to differentiate organic methods from conventional. While “natural” can have broad definitions like including the entire universe or everything untouched by man (thus either removing agriculture or providing no distinctions in practice), Verhoog et al. (2004) were able to show that organic producers feel organic can be classified as more natural than conventional agriculture as its aim is to be harmoniously integrated into nature. In this way nature is seen as a teacher or model for sustainable and humane agriculture. This ethos pushes organic farmers into an ecocentric approach when making management decisions. From this perspective, we begin to see how organic farmers may view welfare differently than conventional farmers or veterinarians.

Read the rest of the paper here.


Vonne Lund, & Bo Algers (2003). Research on animal health and welfare in organic farming—a literature review Livestock Production Science, 80 (1-2), 55-68 : 10.1016/S0301-6226(02)00321-4