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experience:
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Environmental Health
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summary:
As regards health and safety matters, I am prepared to comment on
these and, from the evidence so far presented to me, am prepared to
say that the number of irregularities so presented - including the
prosecution records - do not suggest to me that McDonalds is a company
which can entirely claim to take its health and safety duties as
seriously as would be expected of a UK-based company.
cv:
Richard North is an independent environmental health officer who has
worked in industry for the last 15 years, mainly with the hotel and
catering trades. He was heavily involved with cook-chill, being
responsible of the design of a number of major hospital kitchen
installations. After the Edwina Currie salmonella scare, he
represented the United Kingdom Egg Producers Association and has been
largely credited with ending the government's compulsory slaughter
policy for laying hens.
For the last three years. he has been researching the quality of
public sector food- poisoning surveillance for his PhD at Leeds
Metropolitan University. His studies have involved an in-depth
examination of food-poisoning outbreak investigations on which data
much of this seminar is based. Richard submitted 131,000 words of
written evidence, and oral evidence to the Advisory Committee on the
Microbiological Safety of Food, much of it on standards of
food-poisoning investigation, from which the Committee concluded that
investigation procedures needed improvement.
He is a frequent lecturer, writer and broadcaster, and is heavily
involved in the current deregulation debate, having addressed the DTI
"Scrutiny" Committee on EHO activities, as well as the
Deregulation Committee and the No. 10 Downing Street Policy Unit on
the same subject. His main stance is that more time should be spent
on effective investigation of food-poisoning, producing data which
will enable the food industries to improve the targeting of
food-poisoning controls. The campaign for the restoration of local
authority control of meat inspection and the removal of veterinary
inspection, is also taking much of his time, whilst he is also
co-authoring a book with Christopher Booker of the Sunday Telegraph,
entitled "The Mad Officials", due for publication in the
Autumn.
Full cv:
Available for this witness
full statement:
- I am a qualified environmental health officer specialising in food
hygiene and safety and am currently registered with Leeds Metropolitan
University, undertaking a PhD in aspects of food-poisoning, this work
specially qualifying me to comment on matters relating to food safety
risks. I am also experienced in safety at work matters. My full
curriculum vitae is attached.
- I have read the publication which I understand to have been
produced by London Greenpeace, to which this case relates, and in
particular the boxed section headed "What's your poison"
which covers my area of speciality.
- As to the claim that "meat is responsible for 70% of all
food-poisoning incidents", I would agree that this is essentially
in accordance with my understanding of the situation as it was
then in 1986, when the article was published, although slightly
exaggerated.
- Such understanding arises from the Public Health Laborotory Service Communicable Diseases surveillance Centre, which is the national reporting centre for food poisoning. In 1985, of the 72 salmonella food poisoning outbreaks (the most common form of food- poisoning) in which the food vehicle was identified, 57% were associated with meats of different kinds.
- It is true to say that, since that information had not been
published in 1986 (it was published in 1988) Greenpeace could not
have known this information. The most recent information they
could have relied upon was the 1984 figures where, of the 109
outbreaks in which the food vehicle was reported, the figure was 59%
for salmonella. The equivalent figure for all types of food poisoning
was 198 incidents, of which 68% were associated with the
consumption of meat. Rounded up, this becomes 70%, on which basis
it would be valid to say that the consumption of meat (or products
made with meat) is associated (or was then) with 70% of food-poisoning outbreaks, in which the vehicle of infection (i.e. the food consumed) was identified.
- Nevertheless, it is not entirely true to say, from a strictly
technical viewpoint, that "meat is responsible for 70% of all
food-poisoning incidents". In the majority of incidents, the food
vehicle involved is not reported. For instance, in 1984, 639
outbreaks, the food vehicle was identified in only 198
(30%). Furthermore, the definition of "incident" includes
individual cases. With outbreaks, the total number of
"incidents" reported was nearly 11,000, of which the 198
outbreaks comprise our total knowledge of the food- vehicles
reported.
- However, it may be the case, although there has been no research to
that effect, that the proportions of food vehicles in incidents where
the food vehicles are not known may be similar to those where the food
vehicle is not known.
I believe, for the purpose of a general
discussion, that many authorities of food poisoning would accept this
as a working hypothesis, in respect of the 1984 incidents.
- As regards responsibility, I would not, myself, state that meat
was responsible for the outbreaks. Rather, I would say that the
mishandling of meat and their products was responsible for them. In
this context, the pedantic interpretation of the statistics would be
less favourable to the plaintiff. On this and the aforementioned
bases, I would accept that the Greenpeace comment made was fair
comment.
- As to "chicken and minced meat (as used in burgers) being
the worst offenders, I too believe this to be fair comment. It is well
recognised that chicken is the main meat product associated with
food-poisoning, and minced meat is a particularly sensitive
product.
The reason for this is that, on whole jointed meat,
food-poisoning bacteria tend to be a surface phenomenon. They are
readily destroyed by even mild cooking (as in rare steak). However, in
the minced product, the surface area is multiplied, and the surfaces
of the meat are mixed into the body of the product, whereby
contamination is uniformly spread. As such, a more severe cooking
process is required to destroy pathogens and, as a result, the
resultant product is potentially more harmful.
- As to the comment that "when animals are slaughtered, meat can
become contaminated with gut contents, faeces and urine, leading to
bacterial infection", strictly speaking, the word contamination,
rather than infection, would be more accurate. With this reservation,
the essence of what is said is substantially true.
- Regarding the statement that "in an attempt to counteract
infection in their animals, farmers routinely inject them with doses
of antibiotics", I do not know this to be true in the UK (I have
no knowledge of practice elsewhere, but it is possible that in some
countries, controls may be more lax). Food-poisoning organisms are
commonly found in the guts of food animals and birds, often without
causing any symptoms of disease. Farmers rarely take any action with
symptomless animals and, in the event of overt infection, to my
knowledge, antibiotics are generally administered to counter those
specific symptoms. The use, in the UK, must be authorised by a
veterinary surgeon and cannot, in the sense implied, be considered
routine.
- However, in the less common event that an animal might show overt
symptoms of infection, antibiotics are routinely used as a curative
measure. In this sense, the Greenpeace comments can be considered to
have some validity.
- As regards the build up of antibiotics, growth promoting hormone
drugs and pesticide residues in animal feed, which can further ruin
the health of people on a meat-based diet, my view of this claim is
that it is somewhat tendentious. There is no evidence, in respect of
UK stock, that either antibiotic, hormone or pesticide residues have
accumulated to significant levels, or even measurable levels. Growth
hormones and antibiotics are very rarely found in UK produced meat; it is an offense to market meat thus tainted, and special measures are
taken to avoid them entering the food chain. I am not aware of
significant levels of pesticides being found.
[N.B. Regarding this paragraph, the witness stated in court that following more research in this area he did have concerns about residues in meat and he has since made a further statement on this]
- However, it is true to say that excessive residues of either
antibiotics, growth hormones, or pesticides, if they are found in
meat, can ruin the health of its consumers. Given that these were
found, in addition to food-poisoning organisms, it could be said that
further ruin could be involved. This notwithstanding, I could not
wholly support the argument made, on the basis of evidence known to
me.
- Elsewhere in the Greenpeace document, I note a comment made,
under the headline toy food that the food children are "seduced
in eating is at best mediocre, at worst poisonous". I am
not qualified to comment on mediocrity, but would assert that the
comment, as regards the food being poisoning, is true. In the
worst case, the food can be poisonous and I am aware, without knowing
the details - which have not been published, that the McDonalds chain
has been associated with food-poisoning. If the association is true,
and in any case, the Greenpeace comment is fair comment.
- As regards health and safety matters, I am prepared to comment on
these and, from the evidence so far presented to me, am prepared to
say that the number of irregularities so presented - including the
prosecution records - do not suggest to me that McDonalds is a company
which can entirely claim to take its health and safety duties as
seriously as would be expected of a UK-based company.
supplementary statement:
Reports of visits
- At the request of the defendants, on 16 August 1994, 1 visited the
Hereford poultry processing plant of Sun Valley, a division of Cargill
PLC. On 19 August 1994, I visited the burger production facility of
McKey Foods, at Milton Keynes. Both these operations supplied foods
to McDonalds, respectively chicken `burger' type products, and beef
burgers. Shortly thereafter, I visited a McDonald shop, in central
Leeds. My purpose in undertaking the visits was to assess the hygienic
conditions of the respective operations - and the operation as a whole
- and to make observations to that effect.
- I should state that at each site, every facility was afforded. I
was given all access to all relevant areas and suitably knowledgeable
personnel were made available to answer my questions. The following is
my report, based on notes taken at the time and observations recorded
shortly thereafter.
Sun Valley
- Areas visited in this plant included the broiler processing areas
and the McDonald chicken burger production facility. As to the
processing area, the unit was accommodated in a various buildings,
which, in the main, were not new nor specifically designed for the
current processes. I understood that temporary arrangements were in
force, pending major building and development on the site.
- Nevertheless, I noted a good standard of structural repair and an
acceptable standard of structural finishes. The plant and equipment
was typical of a large poultry processing plant, with a high level of
mechanisation, including evisceration. I noted no obvious failures in
the standards of cleanliness, either in the plant or the general
environment. Staff observed were suitably dressed and equipped and
appeared to be working in an acceptable fashion.
- Building services - lighting, ventilation, water supply and drainage
- appeared adequate, and refrigeration/temperature control provisions
likewise appeared adequate - with some minor reservations. The
production system was equipped with modern, comprehensive electronic
monitoring and an impressive recording system.
- Of particular note was the live bird reception area, which was
modern and spacious, equipped with high-capacity crate washers. This
was of exemplary design. I was given to understand that the
installation of crate washers had been part of an overall salmonella
reduction programme in the live birds, which had brought incidence rates in live birds to one percent. However, I was informed that the average salmonella burden in the finished, processed meat was in the order of 25 per cent.
- The burger production facility was situated in a modern, portal
frame industrial building which, I understood, had originally been
furnished as a store. The operation was well laid out, with the
structure and fabric in good condition. Cleanliness was good and there
were innovative control and quality systems in force. Freezer
technology employed was entirely adequate for the nature of the
operation, a nitrogen tunnel freezer being used.
McKey Foods
- This unit was in a modern, purpose-built, portal frame industrial
building. The operation was well laid out, in good repair and
clean. Equipment was to a high standard, also clean and in good
condition. Building services were adequate and staff were well dressed
and suitably equipped. The operation was devoted exclusively to
burger production - no meat cutting was carried out - with a high
degree of mechanisation.
- Of particular note was the mode of delivery of the meat, the quality
thereof and its subsequent treatment. The meat was delivered in large
pallet boxes, which may have contained up to a tonne of primal
butcher's cuts. The cuts were bulked together without individual
wrapping. From the colour and texture of the flesh and fat, I judged
that much of the meat observed I saw what must have been several
tonnes) had been derived from old cows. I noted flank and diaphragm
(skirt) to be the bulk of the meat.
- I understood that the meat was sampled and tested for, inter alia,
fat content, upon which findings, the various batches of meat were
blended to give a uniform fat content of approximately ten percent,
before being processed for burger production.
McDonalds shop
- This unit was a large, city centre site, offered as typical of a
city centre development. The unit throughout was spacious, well
finished, clean and brightly lit. Equipment and fittings were in good
condition and layout presented no serious operational problems. Staff
were well-dressed, tidy and clean.
- Cooking and food handling was conducted speedily and appeared well
organised and I was shown the routine checks carried out to ensure
that cooking temperatures were sufficient.
Discussion
- The three sites visited all demonstrated high standards of what
might be called "visual hygiene". However, it has been well
demonstrated that there is not necessarily any correlation between
visual standards and microbiological standards. It is the latter which
have the most relevance to food safety and, therefore, the standard of
hygiene. In this context, I have found from my own work that there can
be an inverse correlation between high visual standards and the
microbiological standard of the food produced.
- To an extent, this is true of the McDonald operation. Despite
the visual standards, the Sun Valley unit still produced chicken meat
with a salmonella burden of 25 per cent, magnified from one per cent
in the live birds. If salmonella control is judged to be an
essential facet of hygiene operation - and it would not be
unreasonable to so consider - then a production process which
magnifies rather than reduces the burden cannot be termed
"hygienic" in the full, technical sense of the word.
- That the presence of salmonella from the Sun Valley plant is
relevant is demonstrated from my own work, in that I personally
researched a major salmonella outbreak in South Wales in August 1991,
where infected chicken drumsticks from the Hereford plant had been
implicated as the source of infection.
- The magnification of the salmonella burden arises from the volume
of throughput, the intensification of production at all stages, and
the use of high capacity mechanised processing equipment. It is not
possible to clean and disinfect between handling each individual bird,
nor between small batches of birds. Therefore, when salmonella is
introduced in a small number of birds, it is quickly spread to large
numbers of previously uninfected birds.
- In the McDonald operation, which relies on a high turnover of
produce, of consistent appearance, and organoleptic quality
attributes, it would be unrealistic to expect anything other than the
scale of production witnessed. To that extent, high volume production
- with its adverse hygiene implications is "driven" by the
very nature of McDonalds, which is a high volume business. In this
sense, it is fair to say that the McDonalds operation, taken as a
whole, is intrinsically unhygienic - despite the emphasis on wholesome
appearance and allied attributes.
- The same must be said of the beef burger operation. At the
slaughterhouse, there is great emphasis on keeping individual animals
apart to avoid cross-contamination - the transfer of invisible
microorganisms. The subsequent bulking of large quantities of meat,
cut from a large number of individual animals, can do nothing other
than encourage the spread of contamination.
- In that individual batches of meat are excessively large, this
problem is further compounded by the demand for a consistent product,
which requires the blending of meats from different batches to
equalise fat content. In the practical application of hygiene, keeping
batches small, and their segregation, is an important part of the
general discipline. By application of this discipline, if any one
batch is contaminated, the contamination is contained and the
potential risks minimised. The conduct of the burger production,
however, is such to maximise risk. Again, despite the visual
standards, the operation cannot be regarded as hygienic.
- Turning to the shop operation itself, the products concerned
present little risk. Most food-poisoning - from salmonella - involves
the multiplication of a small dose of salmonella in the raw product to
the very large numbers typically required to cause iliness in the
cooked product. This generally requires survival of salmonella through
inadequate cooking, or post- cooking contamination from raw food to
cooked, and the keeping of that food warm for a period of some hours.
There was no evidence from observation of the operation in the single
shop visited that such conditions could arise.
- However, there was no evidence that, given a system breakdown, such
conditions could not arise, in the shop visited or elsewhere in the
chain. In effect, the consumer safety relies almost exclusively on
systems in the various shops, with no defence in depth, the previous
processing having ensured that spread of contamination has been
maximised. Given rigorous control at the point of delivery to the
customer, it is possible to avoid problems, but with the large number
of sites operated by McDonalds, the risk of failure must be magnified
by the number of operations To that extent, the larger the operation,
the greater the risk.
- Having regard to the full nature of the McDonalds operation,
therefore, it is hard to describe the systems as inherently hygienic.
The high operational standards are necessary and implemented not only
to maintain "hygiene" but to overcome defects in an inherently
unhygienic and fragile business.
The implications of the Preston Escherichia coil outbreak in relation to the hygienic operation of McDonald's fast food products
An interim report by Richard A E North PhD
14 December 1995
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In my view, the standards presented in McDonald's outlets in the UK represent a graphic example of the use of visible 'hygiene' as a marketing tool, and do not represent real hygienic standards.
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This chain has a high reputation for hygiene. It designs its kitchens so that they are visible to its customers. They are brightly lit with modern looking finishes and equipment, which would accord with what, in my experience is the expectation of the "lay" consumer as to the nature of hygiene.
Yet, the company has admitted in High Court proceedings to which this report is directed that, in 1991, it caused illness to a number of its customers in an outbreak of a particularly serious disease caused by a strain of a bacterium called Escherichia coli 0157H Marshall, 1991). The outbreak eventually affected 23 people (Advisory Committee on the Micro biological Safety of Food, 1993).
One of the shops involved, in Preston, Lancs, was no different from the others, presenting a clean, "hygienic" appearance, with the fittings and equipment typical of the chain. But, in January 1991, the produce - according to the strict definition of the term - was far from hygienic. By "hygienic" I have regard to accepted definitions of hygiene, which relate to the prevention of food-poisoning and food-borne diseases. By failing to prevent a food-borne disease, the unit failed to conform with the definition of "hygienic" and was, therefore, not hygienic.
This example underlines the limitations of assessing hygiene by means of visual appearances and points up flaws in the system which attests to good hygiene, in particular to the "hygiene" of McDonald's' operations and that of its suppliers. It is widely acknowledged amongst practitioners in food hygiene, and a view which I hold myself, that the conduct of staff in undertaking operational procedures has much greater influence on the real hygiene of a food business than the conditions in which the food is produced.
To that effect, it is important to note the defendants' evidence on the relative youth of McDonald's' UK employees, the working pressures, and equipment problems. From this, it is safe to conclude that - given the scale of the operation in the UK - that a number of stores at any one time might have considerable difficulty in maintaining conformity with standard operational procedures. In this context, the system - taken as a whole - might be regarded as flawed, containing in-built inadequacies and systematic fragility, to the extent that undercooked burgers may be sold from time to time. Thus, the destruction of potentially pathogenic organisms in all their produce cannot be guaranteed. That is certainly my view.
As regards the suppliers' premises, it should be noted that the plant which produced the burgers to which the Preston illness was attributed was clean and in good condition (Marshall, op cit). Furthermore, McDonald's' purchasing policy required that all meat used for burger
production was obtained from EEC approved slaughterhouses, which thus conformed with the most stringent regulatory codes then prevalent in the UK Yet it is apparent from the Preston outbreak that potentially harmful microorganisms were capable of being transmitted through the "hygienic" production system.
What was also evident from subsequent enquiries was that there were many aspects of the McDonalds' cooking operation which could have been improved, and - after the UK outbreak
- many changes were introduced. But, if changes were necessary, they could have been made before, not after tile outbreak, so preventing a great deal of unnecessary harm and distress.
It is easy to be wise after the event, but - in my opinion - this is hardly the case here. In the first half of 1982, two E. coil outbreaks occurred. One in Oregon and the other in Michigan USA, arising from the consumption of burgers, (Riley, el al, 1 982). These had been supplied by fast food operations in the McDon alds' US chain. In my view, from the reading of the technical report, its characteristics were very similar to those of the McDonald's outbreak in be UK.
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The details were published and the lessons were available to all from which to learn, and it is entirely reasonable to assume that they had been closely studied by McDonalds' US executives. Details and the implications could easily have been conveyed to UK executives for transmission to UK operating staff. Those lessons apparently went unheeded, at least in so far as the UK operations were concerned which, in my view, represents a major management failing, an aspect which can also be considered to represent a lack of hygiene in that be management conduct is also an important part of maintaining hygienic conditions. |
After the 1991 UK outbreak, McDonald's required of their burger producer an assurance that their "patties" - as they call them - were E. coli-free. If they were capable of demanding that assurance then, they could have sought it before the outbreak occurred. That they did not is strongly suggestive of an essential lack of capability in relation to the maintenance of hygiene.
This notwithstanding, the supplier gave the necessary assurance, based on routine microbiological sampling carried out in the plants. 13ut an evaluation of the sanipling protocol
- by myself (submitted) - showed that the frequency of sampling was so how, in comparison to the vast amount of meat handled, that the exercise had no realistic chance of finding E. coil even if it was present in quite large numbers. The exercise was - and Is - essentially, public relations, in my opinion, not so very different frotri selling the appearance of hygiene as a substitute for the real thing.
In my overall opinion, therefore, the McDonalds' chain in the UK continues to regard adherence to hygiene codes as more of a marketing tool than an issue of public safety, and is apparently willing to convey the impression of being hygienic without the substantive controls necessary to ensure that state.
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date signed:
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28 July 1993
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status:
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Appeared in court
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references:
Available for this witness
exhibits:
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transcripts of court appearances:
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