That's crazy.
I worked with the exact same product here (USA) for two years (vacuum packed, whole muscle beef cuts) and FSIS wouldn't even think of considering to address C.botulinum as a pathogen of concern. Provided you are providing safe handling instructions on your packaging, and depending on the end-user, there are a couple of considerations:
1. Whole muscle meat that has not been pierced is sterile past 1/8" or less past the surface.
2. C.bot toxin is inactivated quickly (<2m) at temperatures of 176F (80C)
3. Any cooking exposure of a whole muscle product, whether it be grilling/frying/broiling/braising (basically anything aside from sous vide as mentioned above) will inactivate any extremely unlikely toxin that may have been released from spores that are virtually never going to be present on whole muscle red meat, and long before you would even be able to cook the meat to "rare" even.
Scampi also brings up a good point - during most slaughter processes, the carcasses are sprayed with an acidic solution, though it wouldn't be citric - more likely acetic/peracetic/lactic acid would be used. We took it a step further and set up an "intervention cabinet" whereby we would pass our subprimals through a spray of 200ppm peracetic acid prior to trim, because (at the time) we were using our bench trim to make 80/20 ground beef.