Towards a Safer Food Supply

Volume 137, No. 49 - Friday, May 31, 2013

I will summarize what I found in my research, and make what I think are reasonable and effective suggestions to focus resources on and find real solutions. If only government agencies and special interests had learned about pragmatic statistics, we might accomplish so much more, with so much less unnecessary tampering.

It will help if you have read the previous two columns in this series, which include the data and analysis. You can find copies here:

A handful of epidemiologists applied probability theory to a hodgepodge of data to come up with a number of cases of foodborne illness annually in the United States. The number they come up with is over 9 million illnesses and 2,000 dead a year.

They provide no empirical evidence to back this rather drastic assertion. By empirical I mean verifiable by observation or experience rather than just theory or pure logic. Are we supposed to accept it at face value, and make major changes in public policy?

Sadly, that is what happens in society, and in businesses all the time. The boss says I want 10 percent more without ever understanding what would really be required to make that 10 percent; what Lee Iacocca once called the mushroom school of management: make absurd demands, keep them in the dark and scare them into growing!

Mental Gymnastics
Mental gymnastics done to try to help decide where to apply limited resources in order to proactively confront the problems the US “may” face in the future may seem laudable, but the road to perdition is paved with good intentions.

The solutions people come up with, based on untested, unproven theories include, surprise …surprise, more inspection, placing a greater financial burden on industry to maintain arbitrary standards that most likely will not make a difference, based on the real evidence.

These ill wrought solutions will take eyes off what really makes a difference, process improvement, leading to calls, within some government agencies, for banning whole classes of products, and sectors of our industry. But without understanding the real causes of the unwanted results, we risk a huge expenditure of already limited resources to accomplish little more than the destruction of one of the last great hopes for the survival of American
Family Farming.

It doesn’t have to be this way. Valuable things can be gained from looking at data analytically, even when incomplete, then testing pragmatically. Rather than make grand guesses, find the meaning buried within what reliable data there is.

The probability calculations the study authors used were based on counts of what has happened, and guesses, with little to no context provided. To understand, to find concrete actions that can be taken to improve a situation, context needs to be provided.

With context, the meaning buried in the data can be found. Some of what has happened in the past will be useful for prediction, and some just plain wacky. You first have to separate the signals from the noise. Otherwise all we end up doing is making logical connections that have nothing to do with reality: stuff and nonsense.

Even that is not enough. Understanding generated from analysis can build a theory, but that theory must predict changes in the real world to be Science. Otherwise, at best, all you have is philosophy, at worst, fiction. We know Nate Silver nailed it because he nailed it! Reality is still the only place to get a good steak.1

The solutions being called for are logical: ban raw fluid milk, and some raw milk products and increase the time of aging for aged raw milk cheese from 60 to 90 days before it can be sold, but will that solve the problem? Not based on the data.

The data, which we looked at in detail last month, points to the need to separate non-commercial from commercial, take a closer look at post processing food handling, particularly in restaurants, schools, and camps; and the dominance of campylobacter and salmonella as where to look to solve the vast majority of the things that have actually happened.

Neither of these have been a problem with aged raw milk cheese except where the evidence points to post process handling. Do we start a war on raw milk, like the less than spectacular war on drugs, or do we dig deeper, and solve the real problem, through understanding and better process?

The same or similar problems happen with post processing with pasteurized milk, and in fact, the only fully confirmed death from a commercially approved dairy product was from listeria in a pasteurized cheese. Vague threats of potential under-reporting miss the point. What is is what matters, not what “could” be, at least if you really want to solve a problem.

The National Institute of Health of England has taken a better path, a pragmatic one. They have called for the investment of resources in finding a rapid test for Campylobacter in animal and in the milk.2 Resources squandered on more inspection and policing bans would be better spent on working with the English to develop this test.

Any smart supplier of Raw Fluid Milk would want to put a label on their milk ensuring its safety through rigorous testing and continual process improvement. It would be a huge commercial advantage.

Another short term solution could be to limit sales of raw fluid milk to private homes, not institutions, so if there is a problem, the number of illnesses remains small, a matter of personal choice, personal liberty.

Real Safety
I feel confident in saying that Campylobacter, and E. coli could be minimized or eliminated from the milk and the herds through better process on the dairy farm. In fact, it is the only way. Inspecting does nothing to eliminate the cause, as it comes after the fact, when it is too late, and standards forced on people without their involvement are not effective, and are not followed.

E. coli and Campylobacter get into milk from contact with feces from infected animals, who most likely get it from eating feed contaminated with the feces from other infected animals.

Ensuring that feed is not cut too close to the ground, along with careful monitoring of the animals, good manufacturing and agricultural processes, and fore-stripping teats before milking has the potential to greatly diminish their impact, if not eliminate them.

Increasing the economic burden on producers by requiring a longer aging period, or an outright ban, based not on what really happens, but on imperfect probability calculations, would devastate family farms for which raw milk cheese production has been a godsend.

Banning the sale of raw milk to those who have already chosen an alternative lifestyle, might simply force the industry underground, where illness would occur, but go undetected.

Unhygienic conditions that allow pathogens to develop, may one day produce resistant strains like 0157. The only solution is continually improving processes.

If the Dairy Industry wants to do something positive, something with vision, rather than merely point the finger at raw milk, which according to the data, is not the major culprit; it should invest in and lobby for real resources to develop a rapid test for Campylobacter, and an industry wide effort to continually improve milking parlors, holding tanks, and feed cutting practices.

While some of the milk used in commercial operations is listed as “unspecified,” it is reasonable to assume that the product was pasteurized during manufacture, given the type of products listed (see the database link in the previous article), and therefore, was contaminated after leaving the processing plant.

The industry should invest in, and support educating consumers about better food handling practices, and work with their foodservice customers to ensure safer food through better handling after manufacture, as many of the outbreaks reported involve post-plant secondary processing.

If I could, I would require the study of analytic pragmatic statistics in Government, Private Business, and Business Schools, so we could start to make a real difference in how our world is really run. We may not get definitive answers, but we get a good hint of where to really look. DS

1 Woody Allen

Dan Strongin is managing partner and owner of Edible Solutions, a consulting company focused on helping companies making great food make a profit. He encourages your comments regarding this column. Comments can be made anonymously to For previous Strongin columns, visit:

Dan Strongin is managing partner and owner of Edible Solutions, a consulting company focused on helping companies making great food make a profit. He will be writing a monthly column in Cheese Reporter. Strongin can be reached via phone at (510) 224-0493, or via e-mail at You can visit and blog with Dan at

Other Strongin Articles written for Cheese Reporter

dot Lies, Damned Lies and Dairy Safety: How Poorly Applied Statistics Could Lead to the Worse Public Policy

dot Is Dairy Safe Is The Wrong Question, Part 1
dot Not All Data Is Information
dot Start From Where You Are
dot Learning About Your Customer
dot The Vision Thing
dot Customer Service? NOT!
dot Collaboration: The Road To A Better Future
dot Resolution
dot Water

dot In Memoriam: Ignazio Vella 1928-2011
dot Of Cheese, Seals, And Deming
dot In Their Own Words: Lettie Kilmoyer
dot In Their Own Words: Fritz Maytag
dot In Their Own Words: Paula Lambert
dot Show Me the Money: Cost Accounting
dot Cost Accounting Chokes, Part 2: Inventory

dot Cost Accounting Is Choking Your Business, Part 1
dot It Ain’t Over ‘til It’s Over
dot Raw Reason
dot A Story For The Holiday Season, Part II
dot A Story For The Holiday Season
dot Truth In Labeling
dot This Too Shall Pass or "What were we thinking?"
dot Marketing Language That Resonates
dot When Will We Ever Learn?
dot Cheese Competitions In The Context Of Marketing

dot Economy
dot Even The Best Laid Plans Go Astray
dot Root Causes: Communication
dot Partners
dot Diamond Cutting:
It's What You Don't Know That Can Hurt You
dot Integrity and Ethics
dot Pricing:  The Perceived Value
Designing the Effective Sell Sheet
Common Sense
It All Begins in The Mouth
Of Cars...

The Gathering Storm
As Our Industry Evolves, So Should Our Terminology:

Other Cheese Reporter Guest Columnists
Visit John Umhoefer
Visit Neville McNaughton

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