Raw milk distributors and E. Coli O157 in Italy:

Errors to be learned from a risk communication perspective and policy making

suggestions

SHORT CHAINS and LONG TAILS

Session: MEDIA COVERAGE OF PUBLIC HEALTH AND FOOD

FLORENCE 2012 PCST 2012 18-20 april

The current presentation ….

1. The case-history, an introduction 2. The Legislative framework 3. The market conditions4. The mediatic outbreak: is raw milk safe?5. The mediatic mismanagement6. The risk management mismanagement7. Make stock of….?

The case …

In recent years in Italy, due to regulatory changes at the EU and national level, it is possible to sell raw milk from automatic distributors

In 2008, a mediatic crisis was out starting from the daily “Il Riformista”, and the issue gained the agenda of national and local press/broadcasting

The raw milk was blamed to be the cause of several cases of a disease due to the Escherichia Coli strain O157 bacterium, highly pathogenic and with possible fatal exit in children

Conditions of production, storage and transport of raw milk have been accused of lacking respect of hygiene requirements, and most of all, of the lack of the pasteurization procedure in place as a general mean to avoid bacterial presence.

As immediate response, the Minister of Health ordered by an urgent decree, to state in red charactes letters in front of the distributors and with a defined size,

“RAW MILK: TO BE BOILED BEFORE CONSUMPTION”

The normative framework

Raw milk and distributors• Following Reg. CEE 1411/1971, Italian law 169/89 forbade raw milk distibution,

apart milk sold directly by farmers in the farm.

• Specific requirements of safety and hygiene need to be guaranteed to this extent, deeper than those required from farms not selling raw milk.

• Self control plans are needed also, accompanied by Veterinary checks on microbiologic parameters.

• Cheks are risk based (the higher the risk, the more frequent the sampling plan)

• Legislative foundations rely on the “Hygiene Package” (4 EC Regulations on food safety requirements), in particular on reg. 853/2004 (whereas 24, and art. 8, which gives liberty to Member States to allow or not the sale of raw milk, under striclty ruled hygienic conditions).

• Section 9 of the reg. 853 sets rigid hygienic requirements

Guidelines from the Minister of Health

January, 25, 2007 Conferenza Permanente per i rapporti tra lo Stato e le Regioni gives guidance to sell raw milk for human consumption and to harmonize legislation

Raw milk can be sold bot at farm and by automatic distributors

Principles

• Direct responsability of the farmer selling it• Clear traceability: the milk sold can come from only one farm

(no cooperatives, etc)• Distributors of milk need to be recorded and monitored

constantly by insepctions• Distributors are built to respect food safety requirements for

selling raw milk• Farmers need to record all the process by documental

compliance• Strict hygienic conditions (food chain temperature,

temperature at milking, temperature at storage, n° of analysis, etc)

Milk Collection at farm and freezing at 4° C

Cold chain mantained(milk to stay under

10° C)

Bacterial charege at 30 ° C to ≤ 100 000 (*)

Adequate sampling plan at

the farmgate

CONSUMER

Somatic cells (per ml) ≤ 400 000 (**)

The same of pasteurised

milk

The market

The evolution• In short time, 1100 milk distributors appeared on the italian landscape (2004-2007)

• For a mkt share between 4-6% of milk sales

• = 80,000 liters on 1 ,230,000 liters total (sold on a daily basis)

• AT HOUSEHOLD LEVEL, THE SAVING PER LITER IS ABOUT 20-40 CENTS-EURO (1 EURO RAW MILK, 1,20/1,40)

MKT-POLICY INTERACTION and FRAMINGDRIVERS of emerging risks

Problem of competitors - Industry which live on pasteurised milk and know and detect risk governance

failures (local knowledge)

Problem of TRANSLATION to differente regional and local

hygienic level controls

Lack of stakeholders’ engagement to pilot the technical process on higienic requirements

Problem of moral hazard and collective action (less careful farmers can damage most careful ones) in self

control regimes

Not possible to adhere to cooperatives which can limiti

behaviors of that kind

INTERNAL EXTERNAL

MKT COMPETITIONIN

TE

RN

AL

EX

TE

RN

AL

GO

VE

RN

AN

CE

“BEFORE AND AFTER” SCIENCE …

The mediatic mismanagement

The necessary premise: in zoonosis, difficult to find the “smoking gun”

EFSA, Annual report on Zoonosis 2010 (most recent one)

GROUND LEFT TO

MEDIATIC DEBATE!

The strating article…Dec 3, 2008

BUT ……

COMPETENT ASL (FOOD AND VETERINARY SERVICES AT LOCAL LEVEL) HAVE DISCARDED AND ABSOLUTELY EXCLUDED LATER THE RESPONSABILITY OF RAW

MILK!

AND ……

The supposed “Legnago child case” was in the spring of 2008, but official data DO NOT reveal any contamination source in

risk-based sampling

Piano di monitoraggio Lombardia

2007 2008

Carica batterica Numero campioni analizzati 1970 1423% < 25.000 ufc/ml 85,8 91,4% > 25.000 ufc/ml 14,2 8,6

Cellule somatiche % < 300.000/ml 82,5 91,9% > 300.000/ml 17,5 8,1

Sostanza inibenti % Negativi 99,9 99,5Campylobacter termotolleranti % Positivi esame colturale 0,1 0,0Listeria monocytogenes % Positivi esame colturale 0,4 0,4Salmonella spp % Positivi esame colturale 0,2 0,2E.coli verocitotossico % Positivi esame colturale 0,1 0,0

E.Coli 0157• However in 2008 24 confirmed cases of Verocito-toxic Escherichia Coli

strains (among which, 7 of O157) for Italy have been reported on in response of official monitoring (EFSA report on Zoonosis) (<0,1 on 100,000 persons, at the lowest EU levels)

• No data on milk however• The link even if plausible it is not strictly demonstrated and meat accounts

for most part of contamination as a general rule.

The Community Summary Report on Trends and Sources of Zoonoses, Zoonotic Agents and Food-borne Outbreaks in the European Union in 2008, EFSA Journal; 2010 8(1):1496. http://www.efsa.europa.eu/en/efsajournal/doc/1496.pdf

Italy, 2008, E. Coli O157?• Even if the news has not been confirmed neither scientifically nor legally,

in Italy there was a mediatic outbreak linking bacterial intoxication and Emolitic Uremic Syndrome (EUS) of 9 cases (to be noted: EFSA recognised only 7)

• EUS causes possible renal failure and brain damages (in vulnerable sub-groups of the population)

• Not scientific sources (daily newspapers) have given ground to link EUS with raw milk supposed to be tainted by Escherichia Coli O157 strain.

• This bacterium can be found in many foods and also in the environment, and processed and transformed foods are not immune

• In Italy there is no a strong tradition of Fact Checkers as in other countries, assessing facts on the field

Emergency Decree on Raw Milk distributors

The Minister of Health urgent prescription (emergency decree)- in date december, 10, 2008:

• Compulsory to report on the milk distributor and on the bottles that milk needs to be boiled before human consumption

• Such information has to be clearly readable and in red. • As maximum term of consumption, the 3° day after being commercialised• Suspended from sales all distributors not complying with the present

requirements• Ban of delivery of raw milk in catering and food services• Farmers are to exclude the availability of glasses or similar to drink raw milk

in loci• Such decree now is in pont to be temporally extended

Time for action vstime for Risk Assessment

3 decemberarticle on Il Riformista, and the supposed Legnago case

4-5-6-7 decemberArticles on national press stressing a probable BAN on raw milk sale

8 december Urgent Decree Minister of Health)

Mkt consequences of mediatic crisis

• - 20% OF SALES of raw milk in a difficult market situation (cow breedings are closing in Italy due to the low ROE)

• AT RETAIL, 1 LITER OF FRESH MILK >>1,15 Euros to 1, 40 Euros “overnight”

• Closed raw milk distributors

MEDIA FACTSHITS: HOW THE FRAMING OF THE ISSUE GAVE RISE

TO A SPECIFIC POLICY OPTION

1. Evidence from Risk Assessment

Policy options

Society, consumers

expectations

3. society-cosumers’

expectations

4. stakeholders’ expectations

2. Mediatic framing

An ideal science-based policy making process

Public communic

ation sphere

(forward-backward)

… and what happened

EVIDENCE BASED RISK ASSESSMENT

MEDIATIC FRAMING

INSTITUTIONAL RESPONSE AND SOLUTIONS

SOCIETY AND CONSUMERS’ EXPECTATIONS

STAKEHOLDERS’ EXPECTATIONS

CAUSE –EFFECT EVERSED (MEDIA VS RISK ASSESSMENT)NO WIDER PLAYERS ENGAGED IN THE PROCESS

HOWEVER, EVEN IN THE MEDIA: HIGH UNCERTAINTY

NEW

SPAP

ERS

IDENTIFICATION OF CRITICAL POINTS FOR FOOD SAFETY (YELLOW: PRESENT RISK)

IDENTIFICATION OF CRITICAL POINTS FOR FOOD SAFETY (YELLOW: PRESENT RISK)

A- intrinsic risk of pathogens in raw milkB- lack of adequate controlsC- Cows positive to E. Coli O157 not removed from raw milk productionD- lack of adequate guidance for farmersE- lack of respect of guidance from farmersF- lack of homogeneous implementation of self control in # local levelsG- Consumers unable to behave H- Speculation by retail and industryI- Mediatic crisisL- health rules not adequateM- lack of info to the consumersN-administrative problems of governance between central and local levelO- immunitary defenses compromised in population subgroups

IDENTIFICATION OF CRITICAL POINTS FOR FOOD SAFETY (YELLOW: PRESENT RISK)

Il Riformista stressed a variety of Risk factors not repealed later by other media (HORIZONTAL LINE)

The 2 unique factors (VERTICAL LINE) on which there is a real degree of convergence in the press are:

• Intrinsic risk of raw milk• Lack of info to the end consumers

Evidence based Policy Making? NO

• No “smoking gun”, as it frequently happens for zoonosis

• No evidence or settled opinions on a number of issues linked to the case

Effective? YES

• An over-conservative response allows for food safety

• This is the approach generally used when lack of data exist or limited data

Efficient? NO

• Policy making requires cost-benefit analysis of options in order to find the better protection not only of public health but also of economic interests at stake (when legitimate)

• The emergency procedure created by the mediatic crisis did not allow to take into account all the relevant factors

• No other policy options have been properly considered and balanced

• The message “TO BE BOILED BEFORE CONSUMPTION” on distributors can generate fear and disaffection among consumers

THE RISK MANAGEMENT MISMANAGEMENT

In Italy as well as in other MS frequency distribution for age classes stresses that the big part of the cases (90%) (N=320) of EUS hit 0-15 years old the age group from 0 to 6 years account for 80% of the cases

Age of individuals

N°

case

s

Long tail: its implication for policy making

EFFICIENT POLICY MAKING REQUIRES NOT GENERAL BUT SELECTIVE ACTIONS (IE TARGETED TO SPECIFIC POPULATIONS GROUPS)

THERE IS NOT HERE A “ONE SIZE FITS ALL APPROACH”

0-15 YEARS

Concept made popular by Chris

Anderson with regard to selling and

communication strategies for the

libraries in the age of internet …

Policy making under long tail assumptions

• Homeless care and services (United States)• HIV transmission• Whereas “Hyper-connected hubs” exist which have a number of links in

potency-law magnitude vs ordinary hubs (airports, web, marketing on the internet….)

It generally works in simplified life-science aspects (height, weight, biological parameters…), or under

urgency conditions …

FOOD SAFETY AND RISK COMMUNICATION: AN ENLIGHTENING PARADOX

• Raw meat accounts for most of the known cases of EUS even in children (%) due to E. Coli 0157.

• EU Syndrome is also known as “Hamburger disease….”• No cartel at retail to cook it for at least 120 seconds at 72°….• Hence, even if a food safety issue cannot be discarded at all (in the end

raw milk is a plausible source of E. Coli…), the spotlight has shed light on an apparently minor cause of EUS, milk.

• Risk communication virtually went on as an abstract and even separate issue with regard to risk assessment and risk management

Further action

• Suggestions from Coldiretti to the Minister of Health to redress risk communication:

• Risk communication: better targeted (age groups more vulnerable)

• Risk communication: better framing needed with more enphasis on consumers’ responsability

Thanks!Corrado Finardi PhD

Confederazione Nazionale ColdirettiFood Safet Dep

corrado.finardi@coldiretti.itTel. 0039-0521508827

www.sicurezzaalimentare.it