Dear hsalazar,
Slightly OT
If one goes back to the reasons which drove the introduction of
haccp, a major item was the ubiquitous global existence of nonsensical microbiological specifications and the associated routine mass testing of end products.
This is more politely reiterated in the classic 2003 Codex hygiene document.
However I guess retailer’s may have little choice from a legal protection point of view, especially in the current litiginous climate, plus IMEX many processor MDs will cheerfully sign off on the most ridiculous micro. specs just to avoid hassle. And we all know where any later problems get dropped on.
Some countries may have their own micro.culture also. The OP is apparently in USA which I believe has an official tradition of “Listeria” hunting for all types of food process, regardless of whether the finished product is raw or RTE, wet or dry. This perhaps was a derivative of their Salmonella inspection scheme, containing by far the highest routine sample size procedure in the world AFAIK.
Accordingly, although I stick to my belief that without knowledge your risk is unlimited, the 2nd/3rd posts may (sadly) spell out the practical necessities, regardless of any risk assessment or cost factors. Of course, the results may verify a blanket attack. Presumably you have some idea about this already ?
Rgds / Charles.C