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Confirmation of Listeria Innocua with cooked frozen product

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bibi

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Posted 04 April 2015 - 09:33 AM

We had the confirmation of Listeria innocua with one of our cooked frozen product.

We sent more different products with the same process, and other environment swabs  in the same day ,2 days before and 2 days after all came back not detected for L.monocytogens.

The product infected still in house,what do you advise for next steps?

 

Bibi.

 

 

 



Charles.C

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Posted 04 April 2015 - 09:00 PM

The OP query seems to focus on the disposition of the Lot of finished product which has sampled / tested positive for L.innocua.

I make no comment on the environmental sampling other than to attach one suggested Listeria system SOP  below. There are many others already posted on this forum, some regulatory, some not.

 

I presume you already have an existing procedure in the case of detection of L.mono. in the finished product.

(It should be noted that a negative result for a particular micro.species  using a sample from a given lot can never guarantee that the whole lot has zero contamination. (Sampling 101)).

 

AFAIK,  L.innocua is not generally regarded as a significant human pathogen unlike L.monocytogenes.

 

Typical cooking processes should “eliminate” (inter alia) both L.monocytogenes and L.innocua if present in the raw material at “normal” levels. Testing of the finished cooked product for the above 2 species should therefore result in a finding(s) of  “undetected”.

Accordingly, detection is typically assumed to imply that post-cooking contamination has occurred.

 

With respect to a specific Lot, I have encountered at least 3 interpretations of a positive finding such as referred in the OP –

 

(1) A conservative  interpretation  which assumes that the detection of L.innocua indicates the potential for L.monocytogenes to also be present, even if negative analytical results were obtained for the latter. Follow-up is then identical to finding a positive detection for  L.monocytogenes.

(2) An interpretation based solely on compliance to the appropriate micro. specification for the product. IMEX, product specifications only reference L.monocytogenes. The typical follow-up in such a case was to further sample / check for L.monocytogenes. If negative, the product was released (with respect to L.mono). If positive, (1) was followed.

(3) As a variation on (2), the finding for L.innocua was ignored and the product released (with respect to L.mono).

 

The choice between options like (1-3) may well relate to the detailed context, eg product, history, local regulatory factors, buyers, contract, etc.

 

Attached File  Listeria Mono. Control Manual,Crab.pdf   349.77KB   109 downloads


Kind Regards,

 

Charles.C


bibi

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Posted 05 April 2015 - 08:55 AM

Thanks you very much for your reply.

On the instructions of the product to be defrosted and heated for ready to eat

.History of the plant never had L.mono. confirmation for the last 3 years or the species.

The customer request a positive release( certificate of analysis) of the product.

We sent another sample for the same batch and came not detected.

My manager said to send the product because L.mono is not detected and L.innocua is not pathogenic to human??

Any other advise.The product is due for delivery the following week.

 

 

Kind Regards

 

BIBI



Charles.C

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Posted 05 April 2015 - 11:22 AM

Hi bibi,

 

I am a little confused.

 

Yr OP indicated to me (or perhaps i misunderstood)  that this item was a frozen cooked product, ie RTE by the consumer.

Yr 2nd post sounds like the item is actually a frozen raw product and must be fully cooked by the consumer before eating.

 

The difference may be relevant to the comments in my own post and also to the query in yr 2nd post.

 

Please clarify the raw/cooked status of this item ?

 

It's Ok if the information is proprietary but i am curious (and it may also be relevant) as to what the product is ? Shrimp ?


Kind Regards,

 

Charles.C


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Posted 05 April 2015 - 04:29 PM

 

My manager said to send the product because L.mono is not detected and L.innocua is not pathogenic to human??

Any other advise.The product is due for delivery the following week.

 

 

Kind Regards

 

BIBI

 

L. Innocua is far from harmless. Granted when we think of listeriosis we regard LM as the usual culprit, however there are documented cases of illness reported as recently as 2012.  

I would advise against releasing the product.


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"Some people freak out when they see small vertebra in their pasta" ~ Chef John


Charles.C

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Posted 05 April 2015 - 07:41 PM

L. Innocua is far from harmless. Granted when we think of listeriosis we regard LM as the usual culprit, however there are documented cases of illness reported as recently as 2012.  

I would advise against releasing the product.

 

Hi Slab,

 

Are you aware of FDA/USDA ever taking any regulatory action due to detection of L.innocua in raw or RTE foods. ?  I was unable to find any refs to such an event however, in view of the US viewpoint on L.mono,  it would not surprise me if option (1) in my post #2 was initiated for RTE foods.

 

i hv so far failed to  find refs to any food micro. standards which include limits/zero tolerances for L.innocua.

 

Most refs i hv seen consider that L.innocua is harmless to humans, ie non-pathogenic,  but there are always exceptions to any "rule", eg -

 

http://jmmcr.sgmjour.../2/e003103.full

http://www.foodsafet...heets/listeria/


Kind Regards,

 

Charles.C


Slab

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Posted 05 April 2015 - 08:42 PM

Hi Slab,

 

Are you aware of FDA/USDA ever taking any regulatory action due to detection of L.innocua in raw or RTE foods. ?  I was unable to find any refs to such an event however, in view of the US viewpoint on L.mono,  it would not surprise me if option (1) in my post #2 was initiated for RTE foods.

 

i hv so far failed to  find refs to any food micro. standards which include limits/zero tolerances for L.innocua.

 

Most refs i hv seen consider that L.innocua is harmless to humans, ie non-pathogenic,  but there are always exceptions to any "rule", eg -

 

http://jmmcr.sgmjour.../2/e003103.full

http://www.foodsafet...heets/listeria/

 

Hi, Charles;

 

No, there are no action levels established by U.S. regulation.

 

However, the fault of regulatory action levels in my experience is retroactive vs. proactive... Personally I'm very much reluctant to wait on regulatory action to protect my consumer. Better to stay ahead of the curve so to speak as populations and 'end use' are too variable per case studies of L. Innocua infection.

 

 


Food Safety News  Marine Stewardship Council

 

"Some people freak out when they see small vertebra in their pasta" ~ Chef John


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bibi

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Posted 06 April 2015 - 08:45 AM

Hi all thanks again.

 

I agree is it  confusing yes the product is cooked but for quality issue to be heated by the food service to be served hot to the end consumer.

 

BIBI



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Posted 06 April 2015 - 09:03 AM

Thanks

www.kfs.edu.eg



Charles.C

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Posted 06 April 2015 - 09:52 AM

Hi bibi,

 

Thks for the info. I deduce the product is classified as RTE, ie the heating step you mention is only a “warming”.

 

The difficulty for advising  is that no information is available regarding items like the product / process / destination / consumer/ quality history / specification. And similarly for the sampling / analytical follow-up.

 

This necessitates taking a (very) conservative viewpoint.

 

I assume you have worked with this product for a “significant” time and have previously had no detection of Listeria species using an acceptable sampling/analytical capability. I also assume you have a validated cooking procedure, process, etc.

I assume the tolerance for L.monocytogenes in the product is zero and that there is no mention/regulation  of limits for other Listeria species

 

IMEX, a typical cooking procedure for large shrimp “eliminates” Listeria at usual levels in the raw material. Accordingly, the current detection  suggests something has changed, negatively. The cause IMEX  is one or more of 3 things – (a) raw material has an unusually  high level of listeria species, (b) the cook-freeze process has become relatively ineffective, © post-cooking contamination has occurred (somewhere), (d) delays in the process prior to cooking.

 

The worst case scenario is maybe that, even if  L.innocua  can be assumed  to be harmless (product level unknown),  an increased risk of the presence of L.monocytogenes has logically occurred.

 

Without knowing more, I would not recommend you to immediately “commercialise”  the product.

 

I suggest you need more data to make a rational decision, eg  (1) further (quantitative) testing of the particular lot (assumed known) to determine the extent of any Listeria contamination, (2) investigation of the validity of the process / input materials at/around the time of production of the “defective” product, (3) cross-checking the reliability of your analytical service.

An obvious alternative is to reprocess.

 

Hope the above makes sense. :smile:

 

PS- one more comment, if the product is destined for a sensitive consumer, eg a residence for elderly people, I probably woudn't consider sending it at all.


Kind Regards,

 

Charles.C


bibi

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Posted 06 April 2015 - 04:14 PM

Thanks again for all your replies.

 

We already quarantine the product, and in the process with the external lab for further investigations.

we also produce today a new batch, and sent samples for testing

- the finish product

- the suspected fresh raw vegetable

- and the surrounding area of the process for swabbing.

Hope to get some results before end week.

 

BIBI 



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Posted 06 April 2015 - 11:04 PM

Thanks again for all your replies.

 

We already quarantine the product, and in the process with the external lab for further investigations.

we also produce today a new batch, and sent samples for testing

- the finish product

- the suspected fresh raw vegetable

- and the surrounding area of the process for swabbing.

Hope to get some results before end week.

 

BIBI 

 

Hi, BIBI;

 

Best of luck. Listeria spp. can be extremely invasive in a system and finding contamination ingress is a huge undertaking. The attachment provided by Charles C. in post #2 is an excellent source for GMP environmental controls.  Your inputs (assuming provided by 3rd parties) should be accompanied by COAs and documented scientific assessment of kill steps kept on file (current supplier HACCP etc.). Given the harborage of listeria spp. in soils, raw vegetables are more susceptible as carriers and should be held under greater scrutiny.


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"Some people freak out when they see small vertebra in their pasta" ~ Chef John




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