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Declaration of Listeria spp in RTE

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katjad

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Posted 29 October 2015 - 01:02 PM

Hello, i have a question about where in the CFIA or in Health Canada it says we must declare when a food is found to be contaminated with Listeria.  I am trying to establish a corporate policy on not accepting any products with Listeria regardless of species but need backing.  The risk is obvious for monocytogenes or ivanovi the two pathogenic varieties but what about the other non-pathogenic species that may be found. To be its clear but need to justify this to suppliers that question this.

thanks



Charles.C

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Posted 29 October 2015 - 03:34 PM

Hello, i have a question about where in the CFIA or in Health Canada it says we must declare when a food is found to be contaminated with Listeria.  I am trying to establish a corporate policy on not accepting any products with Listeria regardless of species but need backing.  The risk is obvious for monocytogenes or ivanovi the two pathogenic varieties but what about the other non-pathogenic species that may be found. To be its clear but need to justify this to suppliers that question this.

thanks

 

Hi katjad,

 

It's a considerably debated issue.

 

http://www.foodsafet...al-possibility/


Kind Regards,

 

Charles.C


QUALITY22

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Posted 29 October 2015 - 06:44 PM

In light of the BLUE BELL LISTERIA OUTBREAK- 2 of the top 100 consumer good companies in the world have given me insight on how they view Listeria and how the FDA views it going forward, since are business is 80% of their products.

 

Listeria is LISTERIA MONO.- it does not matter if it is mono or inno, or the other 5. They consider it to be worst possible scenerio. We currently swab 65 sites a week in a 40,000 sq ft facility 40 of those areas are zone 2 locations. If we have a positive on zone 2 locations- the "customer(s) may hold product even if its not monocytongenes, but another sub species.

 

THE FDA will be coming to 250 ice cream plants in DEC 2015- to swab 100-200 sites depending on what they SEE. Apparently, they will be going after drains at most plants. We are told they will be considering DRAINS to be the same as FOOD CONTACT areas- but this is just speculation.

 

If it is found on a food contact surface- zone 1, I would hold product. Especially after blue bell and the final hearing of PCA. I am not going to prison for anyone, i do not care if the company will lose a billion dollars LOL.

 

Are program currently is funded by one of the two "POWERHOUSES" so we are CC'ed on all results with them. So they know, when we have a positive. The other customers do not need to know unless its on a food contact surface, in my opinion. If I feel it is a RISKY situation, I will place the product on hold from the last CIP. Perform a root cause analysis and find out how to eliminate further issues.



Tony-C

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Posted 30 October 2015 - 05:51 AM

Hi katjad,

 

Will depend on your product, here is an example from CFIA Annex H: Policy on the Control of Listeria monocytogenes in Ready-to-Eat (RTE) Meat and Poultry Products

 

There is similar info on the website for other products.

 

Regards,

 

Tony
 

 



Charles.C

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Posted 30 October 2015 - 12:54 PM

Hi Tony,

 

Thks for yr efforts. Interesting document. Offhand, looks to be an extension of EC philosophies.

 

The cfia website is IMO a deliberate maze of frustration. And constantly changing.

 

I looked for the “other products” version of the meat link and eventually picked these 2 offerings as the nearest I could see to currently valid information. Totally unsurprised to be proven wrong.

 

http://www.inspectio...30236419?chap=0

(last modified Nov.2013)

 

http://www.hc-sc.gc....es_2011-eng.php

(ca. Apr.2011)(possibly obsolete but I was unable to locate any later revision)

 

The meat document, Appendix H (last modified Sep.2015), looks to be developed from the above links. (Due to its variable grammar, I found it occasionally difficult to decide whether the text was [cut/pasted] generic or specifically aimed at meat/poultry).

 

Interesting to note that ice-cream is in Category B. Perhaps Canada have not yet had any major ice-cream incidents, unlike meat, eg –

http://www.bccdc.ca/...steriaStudy.htm

 

The innovative NRTE labelling option as discussed in para.2.0 of yr link has popped up in threads here before. I guess it similarly exists in USA. Theoretically the manoeuvre sounds easy to refute but logistically maybe less so.


Kind Regards,

 

Charles.C


herdy

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Posted 04 November 2015 - 09:07 PM

If you have to declare any food with Listeria, than any Listeria Spp. food shouldn't be accepted. Even if it isn't the pathogenic type, it is still contaminated with  some species of Listeria, so there shouldn't really be an issue with regulations or anything. Legally, if that is how it is phrased, L.spp + has to be reported the same as L.mono +.

 

The best way I have found to get people to understand is that the only reason something is tested for Listeria Spp. Is to determine if it is possible and/or more likely that it is contaminated with L.mono. Often, when something is listed as L.spp +, it means that they didn't do any testing to determine which it is (When I worked at a food microbiology lab, we would have to ask before confirming it was L.mono+ or - as it was costly. If they did want it to be confirmed, the CoA for that same sample would still say L.spp+ but on a second line it would say something like L.mono confirmation and then + or -, so even if the incoming goods are not L.mono+ so if it only has the L.spp+, you have no idea what species of Listeria it is) If they don't say L.mono, you have no idea if they are or are not. All testing for L.spp does is indicate whether the food could be contaminated with L.mono. If you aren't going to listen to your results, then why even test? The L.spp test is just a cheap way to test for L.mono. Yes, you may have to throw out a bit more if you have to throw out Listeria positive but mono negative contaminated foods, but it's still cheaper than a recall.

 

If that explanation still doesn't work, you could just tell them you won't accept product that hasn't been tested for L.mono . I would almost guarantee that after they saw the price differences in the species versus mono testing, they would agree to just not accept supplies that has a potential to be deadly for pregnant women, children, and the elderly.

 

Hope that helps! Let me know if I got too confusing.



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Charles.C

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Posted 05 November 2015 - 05:24 AM

Hi herdy,

 

I appreciate yr philosophical deductions/ opinions but I think the relevant post to yr OP is Post No.4.

 

Please respond so as to (hopefully) enable a (CFIA) specific / scientific response.


Kind Regards,

 

Charles.C


Scampi

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Posted 05 November 2015 - 05:13 PM

hopefully this link will help katjad

http://www.hc-sc.gc....es_2011-eng.php

 

One of the bullets is roles and responsibilities for operators, it should be buried in there somewhere


Please stop referring to me as Sir/sirs


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Charles.C

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Posted 05 November 2015 - 05:32 PM

hopefully this link will help katjad

http://www.hc-sc.gc....es_2011-eng.php

 

One of the bullets is roles and responsibilities for operators, it should be buried in there somewhere

Hi scampi,

 

Same link as post 5 ?


Kind Regards,

 

Charles.C


Scampi

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Posted 05 November 2015 - 05:39 PM

it is the same. those guideline were a result of the huge Canadian recall due to listeria in 2009. There will not be a more recent version unless/until there is another recall that prompts a review


Please stop referring to me as Sir/sirs


Tony-C

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Posted 06 November 2015 - 03:50 AM

Hi scampi,

 

Same link as post 5 ?

 

Looks remarkably similar ;)

 

it is the same. those guideline were a result of the huge Canadian recall due to listeria in 2009. There will not be a more recent version unless/until there is another recall that prompts a review

 

Section 2. Purpose and Scope:

'In addition to what is outlined in this policy document, additional regulatory requirements specific for particular food commodities may also be applicable (e.g., CFIA's Meat Hygiene Directives (CFIA, 2010)).'

 

Regards,

 

Tony



handyandy

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Posted 22 January 2016 - 05:24 PM

It sounds like you are trying to create a policy to deal with accepting product that have tested positive for Listeria Spp. First and only question is why on earth would you do that? Even Listeria Spp is an indicator of poor sanitation.



katjad

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Posted 24 January 2016 - 08:44 PM

   Its very much the opposite I am trying to look for support for our refusal of all species of Listeria regardless if it is Mono or some other. I have found that some suppliers only test for mono and are wondering why we test for all and will refuse all.  trying to get suppliers to change and backing up our corporate policy is my aim so that all Listeria species are refused without arguments from suppliers about our reasoning.



Charles.C

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Posted 25 January 2016 - 12:42 AM

Hi handyandy/katjad,

 

The various interpretations  generally relate, for example, to Science/RA/Commerce/Validation.

 

Specifically perhaps to the Justification Principles of Microbiological Standards / Specifications / Guidelines eg Codex

 

And perhaps the Precautionary Principle.


Kind Regards,

 

Charles.C




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