Food Safety: Damned Lies & Statistics

A hot button issue

and it should be. But, finding solutions that make a difference should be the focus. The current debate on what to do involves doing the same things we are already doing but more.  Recently, a handful of academics applied probability theory to a hodgepodge of incomplete data from the Center for Disease Control website. Stirring up fear, their conclusion was that the number of cases of foodborne illness annually in the United States is over 9 million illnesses and 2,000 dead a year, most of it unreported. Scary Stuff! 

Published  on the Center for Disease Control website*, it became the basis for a report from UNITED STATES PUBLIC INTEREST RESEARCH GROUP that was widely distributed in the Media, named “Total Food Recall: Unsafe Foods Putting American Lives at Risk.” 

“More needs to be done to protect Americans from the risk of unsafe food.”

Of course it does, but the point should be, what would be effective. Just doing things because you feel something needs to be done accomplishes nothing, and can make things worse. The article asserts:

 “Important rules, standards, and inspections that could significantly improve food safety have been blocked, under-funded, or delayed, allowing the drumbeat of recalls to continue.”
“In other words, instead of things getting better, they appear to be getting worse,” “Our food safety practices are falling short.” 

Note the word "appear" before you panic!

    • Are they getting worse or is reporting getting better?
    • What exactly is the data that their conclusion is based on?

The answer they propose is more inspection, more regulation, more targets and, oddly, more studies. A better answer would be better process. Inspection after the fact is too little too late. 

I am not an industry defender, nor a special interest, but someone who would like to see something done on food safety that makes a real difference: not just a knee jerk reaction to apparently alarming news.

When people reach unreasonable conclusions, it is not to say they are unreasonable people. They are not alone, a number of articles over the years on food product safety draw unreasoned conclusions, based on incomplete, and imperfectly interpreted data, IMHO.

Different Kinds of Statistics?​

The problem is a reliance on the tools of enumerative  statistics, rather than analytic or pragmatic. Think big data and weather prediction. Lot of good that has done!

A typical example of enumerative statistics is a political opinion poll; all you do is count and report. Drawing conclusions from enumerative data can be risky because it does not provide much in the way of context.

Analytic statistics is what Nate Silver used to so accurately predict the outcome of the last election, and is all about understanding data in context.

Pragmatic statistics is what is used in process improvement, taking the theories generated by analytical statistics, and testing them, where opinion rubs up against reality. Statistical data, studied in the abstract, is less science than abstract math. Logical connections can be found in the abstract that simply do not exist in the real world.

When looking at data presented in tables, in muddled sequence, arranged without real affinity, mixing areas of opportunity (a fancy way of saying comparing apples to oranges), it is easy to find things that don’t exist. Finding sense in nonsense is all too human.

Let me say, before we begin, that no sickness is the right amount. But before we jump whole hog into a bunch of new regulations and standards, doesn’t it make sense that we should take a look at what is really going on first? Find the real cause, the root cause, the one that will really make things better?

The article continues, with a seemingly reasonable statement on Food Safety...

“The prominence of dairy in the study model reflects a relatively high number of reported outbreaks associated with raw milk compared with the quantity of raw milk consumed and issues related to Campylobacter spp. infection; these factors likely resulted in an overestimation of illnesses attributed to dairy.”

While true, it is hardly the only, nor the most important influence on the “overestimation” of illnesses attributed to dairy. As you will see, far more than pasteurized or unpasteurized; whether the food was commercially produced or not is key.••

The other thing that kills understanding is relying on measures of comparison, rather than real numbers. They really muddle things up. For instance, the report says:

An estimated 629 (43 percent) deaths each year were attributed to land animal, 363 to plant, and 94 to aquatic commodities… followed by dairy (10 percent) etc.​

Are they saying that every year 62.9 people die from dairy, or are they saying 10 percent of all illnesses? A cow is a land animal after all, as are goats, sheep, yaks and buffalo. Or am I supposed to figure out what 639 is 42% of and then multiply by 10% for myself? 

​The Perils of Percents

Percents are meaningless unless you know the base number, and worse than meaningless if they are based on different numbers. As an example, a dollar compared to 10 dollars is 10 percent, to 100 dollars, only 1 percent, but it is still a dollar! How many deaths from dairy were there? The actual database is not that clear.

Averages presented as if they are real things,

When articles throw a lot of numbers at you, without the hard data to back it up, or the context it sits in, how can you judge? Quantity is not quality. And, an average presents a serious problem, especially when there are wide swings in variation point to point. If you average your pay and Bill Gates’, does that give you any idea about his salary or yours? Averages are comparisons, not real things.

And then comes this nonsense, parading as science:

“One surprising fact consumers should take away from the CDC study of food borne illnesses between 1998 and 2008 is that dairy products, including milk, cheese, and ice cream, are big contributors to food borne illness,”

Caroline Smith DeWaal, food safety director at the Center for Science in the Public Interest (CSPI).

“Dairy products ranked as the leading cause of hospitalizations linked to food borne illness; second to leafy greens in the numbers of illnesses; and second to poultry in the numbers of deaths,”
“Therefore, the incidence of reported outbreaks involving non pasteurized dairy products was ≈150× greater, per unit of dairy product consumed, than the incidence involving pasteurized products. If, as is probably more likely, <1% of dairy products are consumed non pasteurized, then the relative risk per unit of non pasteurized dairy product consumed would be even higher.”

Using other people’s interpretations of data, you get 150x more nonsense. How do they define incidence: by outbreak? Number of people sickened? What is less than one percent? Is it .9 or .5 or .1 percent? With the population of the US hovering around 314 million people, that represents a spread of more than 2,800,000 people, out of which, how many consume dairy products? 

Without an understanding, from the ground up, in the industry itself, someone from an interest group can end up making what sounds like food safety sense, but isn’t. The desire for hot button issues, for publicity, and the lack of training in how to interpret food safety data correctly, leads to conclusions that will make things worse, and take the focus away from what could genuinely help secure the safety of our food supply.

It may seem like it, but I am not nitpicking here: Major changes are being called for, up to and including rules that could put an end to what real people depend on for their livelihood: aged raw milk cheese; and based on nothing more than a song and a throw of the dice

Is a knee jerk reaction to less than stellar analysis based on imperfectly collected, organized, and presented data enough to put an end to one of the last bastions for small family farmers; while sending raw fluid milk production underground, where how it is processed will never be improved.

The actual data tells a different story:

The facts, seen in context, do not bear out these conclusions. I went back to the source, the CDC food borne outbreak database. I will share what I found with you.

Are these predictions based on nothing more than “Stuff?” I downloaded the actual data, the same source they used, and applied the skills I have been lucky enough to learn, and the results point to very different conclusions than those posted on the CDC website, with some promising potential solutions, if we keep in mind that they must be tested first. I was looking for pragmatic ways to have real impact on lowering the incidence of foodborne illness in dairy products. To my surprise I uncovered more, some insight into commonly shared beliefs surrounding the relative safety of dairy products, both pasteurized and raw. 

To review, I downloaded all reported food outbreaks from 1998 to 2010 from here I removed all with unconfirmed causes, or where the food involved was unclear, (which whacked off about 60% of the data.)

I kept any that had “suspected” causes, as having been involved in a few incidents myself, I know how hard it is to fix the exact cause, and what suspected means: a pretty good idea.

I removed all that came from bacteria that are not associated with Dairy Foods, and that can only contaminate after the product leaves the processing plant, like staph. The poor quality of the data would make it difficult or impossible to determine if any single incident is signal or noise.

Non-Commercial Outbreaks Ill Hospital Dead
Raw 129 2262 224 3
Unspecified 41 598 116 0
Homemade 20 154 44 0
Pasteurized 10 153 35 4
TOTALS 200 3167 423 7
Commercial Outbreaks Ill Hospital Dead
Unspecified 30 1184 72 0
Raw 2 244 12 0
Pasteurized 5 243 12 1
TOTALS 37 1671 96 1

Tables of data can be misleading; they don’t provide enough context. It would be easy to assume from this that there is a huge difference in risk between pasteurized and raw milk, one of the beliefs commonly shared, but when seen in the context of commercial production, looks very different.

What you are looking at includes Non-Commercial product from private homes, farmhouses, church events, and picnics as well as commercially produced product. The “homemade” in fact is homemade ice cream. The available data is not clear if raw milk outbreaks came from farmers drinking their own milk, or from those who buy raw milk locally from the farmer. More research would need to be done.

The numbers for commercial products tell a different story, don’t they?Is it possible that the raw milk controversy consuming the dairy industry and some legislatures may be a classic red herring, taking attention and resources away from what could really make a difference?

Rather than trying to distance itself from raw milk products, the industry would be better served trying to ensure the industry as a whole is not compared to non-commercial products.

It is fundamentally unfair to include commercially produced with non-commercial product in the same analysis, and then draw conclusions affecting both.

The single death reported from confirmed commercial product over those 12 years occurred in a pasteurized cheese bought in a supermarket in Oregon in 2006, and was caused by listeria. Even among non-commercial deaths, most came from “bath-tub” producers of fresh Mexican style cheese, both raw and pasteurized.

I am not trying to minimize the tragedy of anyone dying, nor the inherent risks in raw milk, but trying to understand how to deal with what really happened and is likely to happen again. To prevent it, we need to find the real causes and stop blaming the easy targets.

Commercial Incidents

The largest number of outbreaks took place in Restaurants, and the largest number of illnesses per outbreak in Schools and Camps. This makes sense since the number of people served the same food in camp or school is greater, and kids immune systems may not yet be fully developed.

Where the Commercial IncidentsTook Place

LOCATION Outbreaks Ill Hospital Dead
Restaurant 19 351 24 0
School 9 904 42 0
Camp 3 217 7 0
Grocery Store 2 6 4 1
Hospital 1 6 1 0
Nursing Home 1 21 4 0
Office Setting 1 31 4 0
Prison 1 135 10 0
Raw 2 244 12 0
Pasteurized 5 243 12 1
TOTALS 37 1671 96 1

Two-thirds of the 904 illnesses in the schools took place in only five incidents from 2001 to 2005. Three of those were caused by salmonella, with one from pasteurized 2 percent milk, and two others from foods made with cheese, which, based on experience, raises the question of food handling, rather than the innate integrity coming from the factory. In fact, with the exception of the two incidents from grocery stores, most of the other incidents involved post process food handling.

What Matters

A Pareto chart is a useful tool that helps us discern the relative few that really matter.

In the chart above we can see the data organized by most outbreaks to least. This tool helps us figure out where to begin to look to improve the right processes, the ones that will make the most difference. Focusing on Restaurants and Schools would have a huge impact, based on the data we have.

Looking at it from the point of view of illnesses caused, the first place to find a solution would be in schools, the second restaurants.

Schools would be easier as the number of illnesses per outbreak tend to be greater.

If solutions can be found, these two would eliminate over half the illnesses reported for Dairy Products, if the trends from the missing and incomplete data hold. (TESTING REQUIRED)

If the arrow clearly points to schools and restaurants as the first point of entry to analyze and find root causes to improve the system, what will more regulations and inspections for the manufacturer do to help?

By Germ

The following table includes both commercial and non-commercial sources in the more reliable data. While the most outbreaks were caused by Campylobacter, the most illnesses were caused by Salmonella, by a large margin.

GERM Outbreaks Ill Hospital Dead
Salmonella 84 2497 285 1
Campylobacter 119 1592 80 2
E-Coli 26 826 132 0
Listeria 7 68 43 6
Brucella 5 18 7 0
Other 3 14 1 0
TOTALS 244 5015 548 9

Putting Salmonella aside for a moment, one part of the story in the data becomes clear when you consider the link between Campylobacter and Raw Milk: only a tiny number of outbreaks from this germ are linked to anything else.

This is good news. If a way to mitigate campylobacter in raw milk can be found, and processing improved, a huge number of cases could be eliminated: gone, solved, no one sick.With most illnesses coming from Enteric Salmonella a close study would have to be done where the incidents happen to find out how the contamination takes place. It will most certainly involve food handling, as most of the incidents involve secondary processing, meaning after the product leaves the manufacturer, of pasteurized dairy products.

But some reasonable assumptions can be made, based on an understanding of statistical thinking, and the intensity of some things, as you will see are clearly signals, based on knowledge of food production, handling and distribution.

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?

Mental Gymnastics are Not the Same as Reality

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 seem laudable, but the road to ruin 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 the food and dairy industries.

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: aged raw milk cheese, among other products. 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.

A More Reasonable Approach

The Pragmatic Way

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.**

Though 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 points to the need to separate non-commercial from commercial, take a closer look at post manufacturer 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 manufacturer handling. Do we start a war on raw milk, or do we dig deeper, and solve the real problem, through understanding and better process?

The same or similar problems happen with post manufacturer food handling 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***

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.

Towards 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. It is this kind of insight that comes from knowing the context of the data, that people outside of the food industry have no way of knowing, so they throw darts randomly.

Increasing the economic burden on producers 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.

Increasing the burden on producers based on dicey probability calculations not what really happens would devastate family farms

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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 Food Industry, in these examples, the Dairy Industry wants to do something positive, something with vision, rather than merely point the finger at raw milk, or loopy tree huggers, 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), 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.


** Woody Allen


About the Author

I began my work life as a Chef in private clubs, restaurants, and hotels. I was trained at the Ritz and rose to Executive Sous Chef. It was there I first learned to value quality and building teams. I spent ten years working for an independent upscale supermarket as an executive. I helped engineer the creation of a new niche in a highly competitive industry, American Artisan Cheese. Currently, I help small businesses grow without losing who they are, I love my work, am good at it, and ask a lot of questions. Let's make your business better together!

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  • Bill Riedel

    Would you rather have the following approach?

    “Estimates of Food-borne Illness in Canada

    The Public Health Agency of Canada estimates that each year roughly one in eight Canadians (or four million people) get sick due to domestically acquired food-borne diseases. This estimate provides the most accurate picture yet of which food-borne bacteria, viruses, and parasites (“pathogens”) are causing the most illnesses in Canada, as well as estimating the number of food-borne illnesses without a known cause.

    In general, Canada has a very safe food supply; however, this estimate shows that there is still work to be done to prevent and control food-borne illness in Canada, to focus efforts on pathogens which cause the greatest burden and to better understand food-borne illness without a known cause.”


    As a Canadian food microbiologist I have long disliked much about what we say about foodborne disease – it is often scientists spouting their not so science based opinion. One example is the inclusion of lost productivity due to foodborne disease. Since I lived off the avails of bad food not good food I felt working on an outbreak was productive work. In fact, often the loss in productivity is smaller that the payroll and wealth generated from work that would not exist if there was no outbreak. On the other hand, I give a talk entitled:
    and finally let me quote Living with Risk by The British Medical Association “Nothing in life is safe!”

    • Bill, thank you very much for your comments. It is very frustrating when so much time and effort is spent on something that should really be about mitigation of real risk, not zero defect thinking. As you mentioned, food is alive, and moving it over distance is inherently risky. By better analysis we can focus in on things that can make a real difference, but never fully remove all risk. What is needed is real understanding and a cooperative effort on all parts of the food industry, not legal grandstanding, and inspection after the fact. By the time inspection finds something it is too late. The solution is more complex, less newsworthy but more effective: better process, and better understanding, don’t you think?

      • Oh, and thanks for the link. They are again using probability theory, from first glance. Great for describing a population of data, not so great for predicting in a less that stable complex world like food distribution. What does it profit them to guess at a number when what matters is to go back and look at the process from the ground up, literally, and work on improving it. (In statistical terms, there is most likely not a normal distribution, and probability theory doesn’t work for prediction when the data is not normally distributed. Food is not a closed system, there is a lot of complexity in it. Dr. Deming, who is my main influence, would say, quality is everyone’s job, and you can’t inspect it in. Only by better process, building quality in from the get go, can you make real progress. Inspection after the fact doesn’t work. And for me, these kinds of studies make money for the academics who do them, but take our eyes off of the ball.

        • Bill Riedel

          Dan: I feel that you would really enjoy some of the references in the following cover letter for a talk I give. Of specific interest should be the legal argument in Andrew Aberdein’s paper and the definition of science in Macintosh’s paper. I absolutely like Heather
          Douglas – Bullshit at the Interface of Science and Policy: Global Warming,
          Toxic Substances, and Other Pesky Problems, is must reading for
          policy wonks, politicians, bureaucrats and obviously scientists. I think that is enough for today; but there is much more academic lit. on B.S.

          Truthiness, Scientification and
          Bullshit in Communication – From Public Health to Politics.

          Presented by G.W. (Bill) Riedel, Ottawa
          Writers need to
          “develop a built-in bullshit detector.” (Hemingway) and so do readers!

          Canadian academic
          and author Laura Penny opens her book – ‘Your Call is Important to Us, the
          Truth about BULLSHIT’ (There are at
          least 10 books in Ottawa public libraries with the word bullshit in the title, most of them written by academics) by
          quoting Lilly Tomlin: “No matter how cynical you become, it is never enough to
          keep up.” She then delivers her own judgement by starting the book with the
          observation: “We live in an era of unprecedented bullshit production” thereby
          joining other authors who have made similar claims. For example:

          Neil Postman – 1969 – “every day in almost every way
          people are exposed to more bullshit than it is healthy for them to endure….” He
          further notes that “the best things schools can do for kids is to help them
          learn how to distinguish useful talk from bullshit.”

          Harry Frankfurt – 2005 – begins his book ‘On Bullshit’
          (translated into 26 languages) with “One of
          the most salient features of our culture is that there is so much bullshit.”

          Stephen Law – 2011 – Believing Bullshit notes – ‘It
          seems to me that every child should have some immunity to bullshit built into
          their upbringing.”

          In spite of this there are few attempts to examine the
          human propensity to bullshit, especially as it exists in public health and
          politics. This presentation will survey much of the academic literature on the

          Perhaps the most important question to be examined
          will deal with potential legal consequences for bullshitters – Andrew Aberdein deals with the
          question in, Raising the tone: Definition, Bullshit, and the Definition of
          Bullshit, Chapter 10, page 152 of Gary L. Hardcastle and George A. Reisch,
          2006, Bullshit and Philosophy – guaranteed to get perfect results every time,
          Open Court, Chicago. Aberdein observes: “In British and American common law, a
          civil claim for negligence arises when the defendant has a duty of care to the
          plaintiff which he neglects to exercise, thereby harming the plaintiff. Here
          the deceptive bullshitter has a duty to tell the truth; neglecting this duty
          harms his audience if they come to believe his false statements…. The
          associated culpability can range from inadvertence to willful blindness”.

          If you are not concerned about
          culpability perhaps finding out what BBB, ABB and BBSN stand for might be
          sufficiently of interest to attend this presentation. The end of leadership in the
          age of mba?

          Increase the efficiency of your
          organization by declaring: THIS IS A

          Berkun, Scott – #53 – How to detect bullshit –, August 9, 2006(accessed Nov. 23, 2010). (The first rule is to
          expect bullshit).

          “Postman’s core message, which I would summarize as, Citizens
          living in a democracy, if they hope to keep that democracy, need to learn how
          to tell the difference between facts and bullshit.”

          An Exploration of the
          Academic(s’) Literature on Bullshit with

          Emphasis on the
          Canadian Contributions – By G.W. (Bill) Riedel, PhD, MCIC

          Examples of CANADIAN Academic(s’) literature on bullshit:
          Canadians are making significant contributions to this field and as usual, we
          Canadians are punching above our weight.

          Penny, Laura, 2005, Your Call is Important to us – The Truth
          about Bullshit, McClelland &
          Stewart, Toronto, Ontario. (Laura Penny holds a Ph.D. in Comparative
          Literature and teaches at Mount Vincent University in Halifax)

          Sneddon, Andrew, 2007, Bullshitting Bullshitters and the
          Bullshit They Say, Page 146 in Holt, Jason, (Editor), 2007, The Daily Show and
          Philosophy – Moments of Zen in the art of fake News, Blackwell Publishing
          (Andrew Sneddon is Associate Professor of Philosophy at the University of

          Richardson, Alan, 2006, Performing Bullshit and the
          Post-Sincere Condition, Page 83 in Hardcastle, Gary L. , George A. Reisch
          (Editors), 2006 , Bullshit and Philosophy – Guaranteed to Get Perfect Results
          Every Time, Open Court, Chicago, USA. ( Alan Richardson is Professor of
          Philosophy at the University of British Columbia)

          McCallum, John S., 2005, Viewpoint – On Bullshit is not
          bullshit, Ivey Business Journal, Sept./Oct., 1-3. (John McCallum is Professor
          of Finance, University of Manitoba)

          Macintosh, Norman B., 2006, Accounting – Truth, Lies, or
          Bullshit? A Philosophical Investigation, Accounting and the Public Interest,
          vol. 6 (Norman Macintosh was Emeritus Professor of Accounting at Queen’s

          Riedel, Guenter W. 2007, On the field of bullshit, The
          Gateway Online, U. of Alberta, 30 October (
          ) (“Bill” Riedel studied at U. of Alberta and was Chief, Program Planning and
          Development Division at Health Canada in Ottawa)

          Ronald L., 2011, On bullshit and section 5 of the Food and Drugs Act, Food in
          Canada, Jan./Feb. (Ronald L. Doering, BA, LL.B,
          MA, LL.D, is a past president of the Canadian Food Inspection Agency)

          Basil, Bob, PPtP ‘On
          Bullshit’ at (Bob Basil is Professor Applied Communication, Kwantlen Polytech. U., Surrey, B.C.)

          Bousquet, Tim, 2013, The politics of BULLSHIT: Why
          Nova Scotia’s political parties aren’t addressing the issues that matter, and
          what we can do about it, The Coast – Halifax’s Website, October 3.

          ( accessed 29/10/2013).

  • Lynton Cox


    What you say is of course true. May I say though that a lot of what you mention should be done has already been done. Back in the seventies and before at the Public Health Laboratory Service in the Uk. Food service situations either in restaurants or institutions or at large scale gatherings, along with home-cooked foods (particularly at barbecue seaon) were identified as those most important places where foodborne disease occurs.

    They also analysed closely the practices in outbreaks that contributed to outbreaks. I won’t write the list but it has formed the basis of all education and inspection carried out since. The CDC know this very well as do FDA, USDA and no doubt State and City Public health

  • Lynton Cox


    Yet, year on year the cases still increase even in the UK. What is it then about the food service situation that despite the knowledge we have that such little success has been had?

    I wonder sometimes in the US whether the agencies charged with food safety actually speak together but it is sure that the distiction of responsibilities between food in interstate commerce and that only within a State is one factor that hampers ‘joined-up’ thinking. For instance in the USDA ‘master plan’ there is no mention whatsoever of the FDA FSMA document ( Food Safety Modernisation Act).
    Such interagency difference makes for unhelpful competition? Certainly pointing the finger at raw dairy or raw meat is a neat way to point the finger at USDA

  • Very good observations Lynton thank you. Worth pondering why. Of course, haven’t the slightest but would be a problem I would love to dig into. I wonder if authorities knowing what needs to be done is enough. Even providing guidelines. Quality needs to be built into the process. Currently, there is not a clear vision in the food service industry, and the relationship remains antagonistic, at least in the US, and the companies and individuals are dealing with a very complex, adaptive system filled with the most complex of all, people. There are economic pressures as well, and the ongoing attitude that you fix things up for the inspection or audit… better known as CYA quality. I had the head of quality for a major distributor tell me that they were only going SQF, the US version of the Global Food Safety Initiative, because their insurance told them to. CYA. (Cover your ….., for the uninitiated.

    To find the answer we would need that joined-up thinking you mention, and some of the tools from soft systems: those ugly concept maps, understanding the entire system, not just the biological, and only then, perhaps, find where to start looking for things that could really make a difference.

  • Your comments on the FDA vs. USDA vs…. etc. are very apt. The entire structure of the food safety system is wrong for Quality and process improvement. Balkanized. Filled with misunderstanding and fear.

    I am beginning a paper for on how the new markup language for government agencies to define their missions, could be adapted to use in public/private initiatives as a way of breaking down the walls of misunderstanding and will post it here when done.

    some shooting from the hip without due diligence:

    There has to be understanding of how all the pieces fit first, then some kind of general agreement on what is trying to be accomplished.

    The best model I have seen for effectiveness in public private initiatives has been the agricultural service working out of the land grant colleges in the US. Not perfect, but because it was adhoc, created during the works progress administration era of the depression, at grassroots level, much freedom was left to the individual agent, linked to farmers directly, and not wonks in offices dictating what should or should not be done: it is a highly adaptable, vibrant, and essential service accomplishing amazing things in the background. Something similar perhaps could help in creating a sense of joint involvement in food safety.

    And we need to start with,

    Is the increase an increase in reporting or an increase in actual outbreaks?
    Where exactly is it increasing if it is?
    What kinds of foods, what kinds of outlets?
    Where in the process?
    Which bacteria?
    And try to find the connections, the context. We can’t do that without trust between everyone and good data.

    So, how can we make food safety visionary, so the cook who is preparing the food to the farmer in the fields to the scientist in his lab to the bureaucrat in a government office to the consumer, who may have to pay more to ensure safe food, are all working together towards the same thing? The answer to the question, what are we trying to accomplish, on the tip of the tongue of everyone in the food chain: If we want to get serious about finding a solution. Putting the BIG brain to work.

    And be open to the fact that the solution could have to do with logistics, how far food travels, or even that there is no solution there is only mitigation. We all have points of view, but are like the wiremen and the elephant, but we obviously don’t yet have the answer, and the only way to get that answer is in looking at the how and testing. This much I’ll say, the food safety audit system is good for the auditing company, and ensure great paperwork, but in practice, though there are some improvements, the us against them mentality leads to changes in the paperwork more than understanding and real change in the handling of the food. It is the wrong approach: economically wasteful, not guaranteeing safe food as you mentioned, and naive psychologically: but very lucrative for some.

    If you ask the farmer what food safety is, he will tell you a department in state government that is a pain in the tucus, and costs him money.
    The restauranteur: something to be feared.
    The cook: something that always gets them in trouble
    The inspector: something the people who they inspect are always cheating on.
    The scientist, I don’t know because I am not one…. etc.

    all the way down to the consumer who wants it FREE, PERFECT and NOW.

    WE need to get representatives of everyone down to the table to create the full vision, model what we think is going on, go to where the action is to ensure that is what is going on, without the threat of ill affect if there is not compliance. No improvement can take place in an atmosphere of fear.

    Until then we are trapped in a labyrinth, and at the whim of chance.