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Do we report if positive for Listeria on a non-food contact surface?


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#1 Pizza&Sandwich

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Posted 13 November 2015 - 05:40 PM

According to the USDA FSIS Listeria Guidelines, non food contact surface swabs for Listeria are not required and any positives do not render the product adulterated. In the document it states that cooling units, ceilings, walls, floors, drains are all non food contact surfaces.

If a swab from a ceiling or cooling unit (above product contact surfaces) is positive, this would not need to be reported to USDA FSIS as the swabs are not required and the product does not contact these areas. Correct?

 


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#2 Charles.C

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Posted 14 November 2015 - 06:47 AM

According to the USDA FSIS Listeria Guidelines, non food contact surface swabs for Listeria are not required and any positives do not render the product adulterated. In the document it states that cooling units, ceilings, walls, floors, drains are all non food contact surfaces.

If a swab from a ceiling or cooling unit (above product contact surfaces) is positive, this would not need to be reported to USDA FSIS as the swabs are not required and the product does not contact these areas. Correct?

Hi P&S,

 

I'm not in USA but I'll start the ball rolling.

 

I presume this is RTE product.

I presume the relevant reference is this attachment, esp Pg 3-12.

 

Attached File  Controlling_LM_RTE_guideline_0912.pdf   891.2KB   37 downloads

 

I cannot see any comment in the FSIS document regarding reporting anything to FSIS so i assume that yr  OP query comes from some other (mandatory?) arrangement ? Within any Listeria Program, some documented "follow-up" to a positive Listeria finding (anywhere) would presumably be expected by a Regulatory body.

 

From a purely sanitation POV the risk assessment  of yr hypothesised finding particularly relates to the potential for direct/indirect cross-contamination as discussed in the attachment. Insufficient details to say much more, clearly whether in the post-lethality area is of immediate interest.


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Kind Regards,

 

Charles.C


#3 KTD

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Posted 18 November 2015 - 03:45 PM

Dear Pizza&Sandwich -

     There are numerous FSIS publications that state that any and all data collected in support of your food safety system is requestable and reviewable by FSIS inspection personnel. That is not the same as saying you have to present it to them. How you choose to approach it depends a lot on your relationship with in-plant IPP and their Front Line Supervisor (FLS). Not showing the data may cause them to think you are trying to hide something; however, if IPP are not knowledgeable, they might start an unnecessary fuss. Either way, you should have a documented detailed investigation with CAs & PMs to demonstrate you reacted properly.

     [If you need a couple of the FSIS references, let me know, and I'll post.]

 

KTD


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