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#1 JuicerICU

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Posted 20 March 2017 - 10:33 PM

Hi All,

 

Can anyone confirm if I am mistaken or correct on the following?

 

I am going to do swabbing according to No.2 alternative for RTE. I have decided to swab once a month at the end of production,5 samples, right before sanitation starts cleaning. This will allow pathogens if present to thrive and be detectable.

 

I was told that for listeria swabbing it has to be done after the area has been cleaned and sanitized. This does not make sense to me because whatever bacteria was there would have been eliminated. and if sanitation is aware the area is to be sampled they will obviously put in extra effort. In my mind the point of EMP is to find pathogens not to avoid finding them. Or am I thinking too much into this.

 

Please enlighten me on the matter.


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#2 Charles.C

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Posted 21 March 2017 - 05:03 AM

Hi All,

 

Can anyone confirm if I am mistaken or correct on the following?

 

I am going to do swabbing according to No.2 alternative for RTE. I have decided to swab once a month at the end of production,5 samples, right before sanitation starts cleaning. This will allow pathogens if present to thrive and be detectable.

 

I was told that for listeria swabbing it has to be done after the area has been cleaned and sanitized. This does not make sense to me because whatever bacteria was there would have been eliminated. and if sanitation is aware the area is to be sampled they will obviously put in extra effort. In my mind the point of EMP is to find pathogens not to avoid finding them. Or am I thinking too much into this.

 

Please enlighten me on the matter.

 

Hi Juicer,

 

A little context might assist, eg -

 

product ?

process ?

reference to what is No.2 ?

basis for yr choice of frequency ?

 

I anticipate you are referring to (some portion of) the encyclopedical/maze-like, FSIS Compliance Guideline: Controlling Listeria monocytogenes in Post-lethality Exposed Ready-to-Eat Meat and Poultry Products (2014) but it helps to be on the same "page".


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Charles.C


#3 JuicerICU

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Posted 21 March 2017 - 05:08 AM

Hi Juicer,

 

A little context might assist, eg -

 

product ?

process ?

reference to what is No.2 ?

basis for yr choice of frequency ?

 

I anticipate you are referring to (some portion of) the encyclopedical/maze-like, FSIS Compliance Guideline: Controlling Listeria monocytogenes in Post-lethality Exposed Ready-to-Eat Meat and Poultry Products (2014) but it helps to be on the same "page".

Correct. I am referencing it but the 2017 revision.

 

Product will be Organic Salad dressings. They consists of fresh veggies, spices and oils(olive,coconut)

 

We only produce this rte product once a week which is why I chose Alternative No.2. The rest of the products we produce undergo HPP.


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#4 Tony-C

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Posted 21 March 2017 - 06:26 AM

Hi JuicerICU,

 

I agree with what you are saying, the idea of environmental monitoring is to remove the source of contamination before it becomes an issue. I would be wanting to swab at the end of production as you say but also after cleaning so that you have verification that the cleaning is effective.

 

You will want to know that high risk areas such as food contact surfaces are free of Listeria at all times and also work to remove the source of positives in other areas that you are monitoring such as drains.

 

Kind regards,

 

Tony


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#5 Charles.C

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Posted 21 March 2017 - 06:52 AM

Hi Tony,

 

 

Hi JuicerICU,

 

I agree with what you are saying, the idea of environmental monitoring is to remove the source of contamination before it becomes an issue. I would be wanting to swab at the end of production as you say but also after cleaning so that you have verification that the cleaning is effective.

 

You will want to know that high risk areas such as food contact surfaces are free of Listeria at all times and also work to remove the source of positives in other areas that you are monitoring such as drains.

 

Kind regards,

 

Tony

 

hi Tony,

 

If the FSIS/Lm document is relevant (but see below), the Regulatory sampling requirements are from head-ache/memory quite specific. No reason not to exceed of course i suppose though.

 

@Juicer, just saw yr post. I see no meat !?. is this USDA or USFDA ?


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Charles.C


#6 Asanele

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Posted 21 March 2017 - 06:53 AM

Thank you very much Tony. As i was going there my self the point of swabs taken after cleaning. Is to verify the effectiveness of your clean system in place .


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#7 Charles.C

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Posted 21 March 2017 - 07:00 AM

Thank you very much Tony. As i was going there my self the point of swabs taken after cleaning. Is to verify the effectiveness of your clean system in place .


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Hi Asanele,

 

Sorry to disagree but this is an over-simplification IMO, ie necessary but not sufficient.


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Charles.C


#8 JuicerICU

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Posted 21 March 2017 - 07:11 AM

Hi Tony,

 

 

 

hi Tony,

 

If the FSIS/Lm document is relevant (but see below), the Regulatory sampling requirements are from head-ache/memory quite specific. No reason not to exceed of course i suppose though.

 

@Juicer, just saw yr post. I see no meat !?. is this USDA or USFDA ?

 

We do not handle meat whatsoever... we are cold pressed juice, puree, smoothies and salad dressings 


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#9 JuicerICU

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Posted 21 March 2017 - 07:13 AM

Hi JuicerICU,

 

I agree with what you are saying, the idea of environmental monitoring is to remove the source of contamination before it becomes an issue. I would be wanting to swab at the end of production as you say but also after cleaning so that you have verification that the cleaning is effective.

 

You will want to know that high risk areas such as food contact surfaces are free of Listeria at all times and also work to remove the source of positives in other areas that you are monitoring such as drains.

 

Kind regards,

 

Tony

 

Tony- I cannot recall where I read it but I read testing should be done towards the end of production. I know it can be done after production after certain amount of hours  But am I completely mistaken in believing Swabbing is ok towards the end of production without sanitizing first?


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#10 Charles.C

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Posted 21 March 2017 - 07:20 AM

We do not handle meat whatsoever... we are cold pressed juice, puree, smoothies and salad dressings 

 

Hi Juicer,

 

So I presume USFDA.

 

So FSIS requirements/directives are presumaby irrelevant from a Reg. POV.

 

Is the 2017 document you refer from USFDA ?, If not perhaps you can clarify the Reg. USFDA requirements ? (if any)


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Charles.C


#11 Tony-C

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Posted 21 March 2017 - 12:09 PM

Tony- I cannot recall where I read it but I read testing should be done towards the end of production. I know it can be done after production after certain amount of hours  But am I completely mistaken in believing Swabbing is ok towards the end of production without sanitizing first?

 

My preference would be immediately after production before any cleaning but if this is not practical then near the end would still give a good indication.

 

Control of Listeria monocytogenes in Ready-To-Eat Foods: Guidance for Industry has some useful guidance but is is not directed to processors of RTE foods that receive a listericidal control measure applied to the food in the final package, or applied to the food just prior to packaging in a system that adequately shields the product and food contact surfaces of the packaging from contamination from the food processing environment.

 

Kind regards,

 

Tony


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#12 Charles.C

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Posted 21 March 2017 - 01:51 PM

Hi Juicer,

 

This (producer) fresh produce extract from an attachment in another thread is similarly targetted to previous post but somewhat expands the sampling/testing "logic":. I don't know what yr process looks like but maybe of some interest.

 

Attached File  Listeria swabbing.pdf   838.02KB   31 downloads

 

PS - OT but JFI I also noticed this vaguely interesting QC snippet -

 

http://laist.com/201...d_juice_fda.php

 

PPS - also JFI, extracted from the fsis 2014 manifesto -

 

Attached File  fsis rte meat - post-pasteurization - listeria evaluation.png   243.66KB   4 downloads

 

PP3S - i should have noted that the above options assume that  USFDA does not impose a Regulatory response analogous to that of USDA for meat.


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Charles.C


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#13 Asanele

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Posted 21 March 2017 - 05:42 PM

CIP takes place first and there after production will follow


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#14 Charles.C

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Posted 21 March 2017 - 07:22 PM

CIP takes place first and there after production will follow


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Hi Asanele,

 

Sorry but i don't quite understand yr comment.

 

Do you mean that IYO listeria swabbing should be done after cleaning all direct/indirect food contact surfaces ?


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Charles.C


#15 Ryan M.

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Posted 21 March 2017 - 09:09 PM

I recently attended a webinar on the most recent FDA guidance regarding Listeria in RTE foods.

 

The presenters recommended swabbing no sooner than 3 to 4 hours into the start of production to allow any potential listeria time to grow.

 

Your thought process on swabbing at the very end of production prior to sanitation is very sound.  As Tony mentioned you will also want to swab the same areas after cleaning in case any of your end production samples come back positive.

 

The one snippet from the webinar which I don't wholly agree with is swabbing zone 1 areas.  They stated specifically, "Facilities get a “mulligan” after one positive FCS test to continue production, with requirements for sanitation, retesting, and investigation."

 

The positive could be Listeria genus or even L.Mono.  It made me scratch my head because they mean to allow companies, facilities to ship product with a positive L.Mono on zone 1 surface.  I honestly don't agree with this and we only swab zone 2 through 4 surfaces in our facility.  Any zone 1 environmental testing is for indicator organisms only.  I think there is too much liability in doing what the FDA suggests, at least of what the presenters viewed and stated.

Attached Files


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#16 Charles.C

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Posted 22 March 2017 - 06:48 AM

Hi Ryan,

 

Many thks for the input.

 

I find FDA's exact Regulatory involvement with some of their jurisdictioned products/Listeria rather unclear as compared to UDSA's overseeing ot meat/poultry.

 

Some of the slide content confused me (quick look only). eg -

 

Pg 13 - use of FSIS's logics, I think, implies a listericidal stage. So unrelated to RTE fresh veg. produce ?

            I am sort of unclear whether OP's cold-pressed (apparently requiring 5D[L.mono?] product qualifies also ?

            The stated sample sizes are clearly unrealistic without an army. (= routine ICMSF caveat)

 

With respect to yr own mentioned criticisms, these detection get-outs/Zone1 sampling avoidance have been discussed in the Literature, also with varying degrees of contention IIRC (eg no sampling = no News = Good News). :smile:


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Charles.C





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