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SHORT CHAINS and LONG TAILS

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 ….

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SHORT CHAINS and LONG TAILS

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  1. 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

  2. The current presentation …. • The case-history, an introduction • The Legislative framework • The market conditions • The mediatic outbreak: is raw milk safe? • The mediatic mismanagement • The risk management mismanagement • Make stock of….?

  3. The case … • In recent years in Italy, due to regulatory changes at the EU and national level, itis possible to sell raw milk from automatic distributors • In 2008, a mediatic crisis was out starting from the daily “Il Riformista”, and the issuegained the agenda of national and local press/broadcasting • The raw milk was blamed to be the cause of severalcases of a disease due to the Escherichia Coli strain O157 bacterium, highlypathogenic and with possible fatalexit in children • Conditions of production, storage and transport of raw milk havebeenaccused of lackingrespect of hygiene requirements, and most of all, of the lack of the pasteurization procedure in placeas a generalmeantoavoidbacterialpresence. • As immediate response, the Minister of Healthorderedbyanurgentdecree, to state in redcharactesletters in front of the distributors and with a definedsize, • “RAW MILK: TO BE BOILED BEFORE CONSUMPTION”

  4. The normative framework

  5. Raw milk and distributors • FollowingReg. CEE 1411/1971, Italianlaw 169/89 forbade raw milk distibution, apart milk sold directlybyfarmers in the farm. • Specific requirements of safety and hygieneneedto be guaranteedtothisextent, deeperthanthoserequired from farms not selling raw milk. • Selfcontrolplans are needed also, accompaniedbyVeterinarychecks on microbiologicparameters. • Cheks are risk based(the higher the risk, the more frequent the samplingplan) • Legislative foundationsrely on the “Hygiene Package” (4 EC Regulations on foodsafety requirements), in particular on reg. 853/2004 (whereas 24, and art. 8, which gives liberty toMemberStatestoallow or not the sale of raw milk, under stricltyruledhygienicconditions). • Section 9 of the reg. 853 sets rigid hygienic requirements

  6. 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

  7. 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)

  8. Milk Collection at farm and freezing at 4° C Adequatesamplingplan at the farmgate Coldchainmantained (milk to stay under 10° C) The same of pasteurised milk Bacterialcharege at 30 ° C to ≤ 100 000 (*) Somaticcells (per ml) ≤ 400 000 (**) CONSUMER

  9. The market

  10. 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)

  11. MKT-POLICY INTERACTION and FRAMINGDRIVERS of emerging risks “BEFORE AND AFTER” SCIENCE … MKT COMPETITION INTERNAL EXTERNAL Problem of moralhazard and collective action (lesscarefulfarmers can damagemostcarefulones) in self controlregimes Not possible toadheretocooperativeswhich can limiti behaviors of thatkind Problem of competitors - Industrywhich live on pasteurised milk and know and detect risk governancefailures (localknowledge) INTERNAL GOVERNANCE Lack of stakeholders’ engagement topilot the technicalprocess on higienic requirements Problem of TRANSLATION to differente regional and localhygieniclevelcontrols EXTERNAL

  12. The mediatic mismanagement

  13. The necessary premise: in zoonosis, difficult to find the “smoking gun” GROUND LEFT TO MEDIATIC DEBATE! EFSA, Annual report on Zoonosis 2010 (most recent one)

  14. The stratingarticle… 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 ……

  15. The supposed “Legnago child case” was in the spring of 2008, but official data DO NOT reveal any contamination source in risk-based sampling

  16. 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

  17. 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

  18. 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

  19. Time for action vstime for Risk Assessment 8 december Urgent Decree Minister of Health) 3 december article on Il Riformista, and the supposed Legnago case 4-5-6-7 december Articles on national press stressing a probable BAN on raw milk sale

  20. 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

  21. MEDIA FACTSHITS: HOW THE FRAMING OF THE ISSUE GAVE RISE TO A SPECIFIC POLICY OPTION

  22. An idealscience-based policy makingprocess Policy options 4. stakeholders’ expectations Public communicationsphere (forward-backward) Society, consumers expectations 3. society-cosumers’ expectations 2. Mediatic framing 1. Evidence from Risk Assessment

  23. … and what happened • CAUSE –EFFECT EVERSED (MEDIA VS RISK ASSESSMENT) • NO WIDER PLAYERS ENGAGED IN THE PROCESS

  24. HOWEVER, EVEN IN THE MEDIA: HIGH UNCERTAINTY IDENTIFICATION OF CRITICAL POINTS FOR FOOD SAFETY (YELLOW: PRESENT RISK) NEWSPAPERS

  25. IDENTIFICATION OF CRITICAL POINTS FOR FOOD SAFETY (YELLOW: PRESENT RISK) A- intrinsic risk of pathogens in raw milk B- lack of adequate controls C- Cows positive to E. Coli O157 not removed from raw milk production D- lack of adequate guidance for farmers E- lack of respect of guidance from farmers F- lack of homogeneous implementation of self control in # local levels G- Consumers unable to behave H- Speculation by retail and industry I- Mediatic crisis L- health rules not adequate M- lack of info to the consumers N-administrative problems of governance between central and local level O- immunitary defenses compromised in population subgroups

  26. 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

  27. 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

  28. Effective? YES • An over-conservative response allows for food safety • This is the approach generally used when lack of data exist or limited data

  29. 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

  30. THE RISK MANAGEMENT MISMANAGEMENT

  31. 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 N° cases Age of individuals

  32. Long tail: its implication for policy making Concept madepopularby Chris Anderson with regard toselling and communicationstrategies for the libraries in the age of internet … 0-15 YEARS 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”

  33. 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….)

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

  35. 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

  36. 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

  37. Thanks! Corrado Finardi PhD Confederazione Nazionale Coldiretti Food Safet Dep corrado.finardi@coldiretti.it Tel. 0039-0521508827 www.sicurezzaalimentare.it

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