Another Ice Cream Manufacturer with Listeria

This is another ice cream manufacturer that is not sure of how the Listeria got into their plant.  It's a smaller company, too.  Maybe a common ingredient?

http://www.foodsafet...k/#.VTpRKk0tH3g

Martha

That is a possibility, but more likely its poor sanitation.  Listeria is the rare pathogen that can survive being exposed to sub zero temperatures. Because of this, it is the most likely pathogen to exist in foods that are frozen or refrigerated.  Most food pathogens cannot  survive 4 C or below.

That is a possibility, but more likely its poor sanitation.  Listeria is the rare pathogen that can survive being exposed to sub zero temperatures. Because of this, it is the most likely pathogen to exist in foods that are frozen or refrigerated.  Most food pathogens cannot  survive 4 C or below.

Actually, it was pointed out in the article below that Listeria does not grow in frozen food, but does at 4 deg C, which makes the idea of a refrigerated ingredient the source of the issue more appealing.  It will survive when frozen, but not grow and multiply enough to contaminate large amounts of product.  Blue Bell has been trying to remove it since the original recall, and it is persisting.  Now there's two smaller manufacturers with a very similar problem, and neither have had any recalls in the past, so it gets suspicious. 

I'm not the only person thinking along those lines, since Listeria is rarely found in ice cream.

http://www.foodmanuf...12&location=top

Martha

As I said, its a possibility that raw materials are the culprit, but I would put my money on the sanitiation of the plants, especially employee sanitation.

The article below does a good job of a quick risk assesssment of Listeria in ice creams in the New Zealand market. 

http://www.foodsafet...ce_Research.pdf

To put my Inspector hat back on for a second, the majority of Listeria issues are linked to the environment of, and sanitation programs in, food production facilities.  I have attached the USDA Lm guidelines.  The majority of these guidelines focus on the cleaning and sanitation programs in production facilities, however, a "kill step" is also a necessary part of these guidelines, as applicable.  Some facilities may not have a "kill step" in their process, which makes the cleaning and sanitation program extremely important.  I found an excellent training program put together by Penn State.

http://extension.psu...-establishments

Countries differ in their regulatory approach to the presence of L. monocytogenes in RTE food.

In the USA a ‘zero tolerance policy’ is taken on the presence of L. monocytogenes in any RTE food, and the pathogen should be absent in 25 g of product. However in 2008 the US Food and Drug Administration (FDA) published a draft consultation paper proposing to loosen up these controls to allow a maximum limit of 100/g in frozen and refrigerated RTE foods that do not support the growth of Listeria.

European Union regulations generally permit a count of up to 100/g at the end of shelf life for RTE foods, except those intended for infants and for special medical purposes.

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

Guidance on the application of limits for Listeria monocytogenes FINAL.pdf   289.24KB   27 downloads

Countries differ in their regulatory approach to the presence of L. monocytogenes in RTE food.

In the USA a ‘zero tolerance policy’ is taken on the presence of L. monocytogenes in any RTE food, and the pathogen should be absent in 25 g of product. However in 2008 the US Food and Drug Administration (FDA) published a draft consultation paper proposing to loosen up these controls to allow a maximum limit of 100/g in frozen and refrigerated RTE foods that do not support the growth of Listeria.

European Union regulations generally permit a count of up to 100/g at the end of shelf life for RTE foods, except those intended for infants and for special medical purposes.

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

 

Guidance on the application of limits for Listeria monocytogenes FINAL.pdf

In that draft guidance from the FDA in 2008, which was actually guidance on how frozen and refrigerated food manufacturers can make their products Listeria free, it is stated that the limit for colonies is .04/g in a finished product.  "We recommend that you demonstrate, through scientific studies, that a listericidal control measure that you establish and use consistently destroys viable cells of L. monocytogenes and consistently leads to a finished food that contains less than 0.04 cfu/g of L. monocytogenes."  So I'm not sure where the author of the 2013 article you cite got his "100/g" number.  It most certainly is not readily located on the FDA site, because I just spent a long time trying to find it.  Here is a link to the 2008 FDA guidance document that he appears to use, which I quoted.  http://www.fda.gov/F...m073110.htm#bg 

We've had enough outbreaks of Listeria in the US to be wary of it.  The Blue Bell outbreak has already killed 3 people.  The cantaloupe outbreak of 2011 killed 30 people.  The FDA has always vigorously pursued Listeria outbreaks, so I think/hope that the zero tolerance policy persists and will continue to persist.  The implementation of FSMA will probably only tighten standards, not loosen them.

Martha

Hi Martha,

The relevance/benefit/usage of  “Zero Tolerance” Standards has always been a highly emotive / debated issue of course, scientifically and politically. And particularly as a corollary of the Precautionary Principle.

<0.04/g simply means not detected in 25g (presumably as an average).

The 100/g cross-reference in my previous link  is in  section XX- B of the link you provided.

(this limit goes back to the 2000 era or perhaps earlier, [from memory EC were discussing <= 1999])(the USFDA -QMRA seems to be 2003)

The Canadian set-up (2011) looks to have implemented something similar to yr 2008 link (sub-link in my previous post).

Here is another quite interesting  (2015) link –  

http://www.wga.com/m...e-or-low-levels

Nonetheless, I do agree with you that, in the absence of solid data, caution is the right default where pathogens are concerned, eg Jack-in-the-Box.

Hi Martha,

 

The relevance/benefit/usage of  “Zero Tolerance” Standards has always been a highly emotive / debated issue of course, scientifically and politically. And particularly as a corollary of the Precautionary Principle.

 

<0.04/g simply means not detected in 25g (presumably as an average).

 

The 100/g cross-reference in my previous link  is in  section XX- B of the link you provided.

 

 

I'm not sure of the math on the <0.04cfu/g means nd in 25g.  I suspect that 0.04 cfu/g is the limit of detection with the tests that were accepted in 2008.

The 100 cfu/g is only the recommended trigger for establishing a corrective action plan, not what is acceptable to be in the food.  For those outside the US, if you initiate a recall, there are no requirements to submit a corrective action plan, though if the FDA orders the recall they may order a corrective action plan.  This document is to help you decide what is a good practice.  This section describes the recommended conditions for starting a corrective action plan, and not the limit for what is acceptable to be in the food.  Emphesis is mine.

"XX. What Corrective Actions Should I Take Regarding Food if I Detect Contamination of a Critical Food-Contact Surface or Food With L. monocytogenes, or if I Assume that ListeriaSpecies on a Critical Food-Contact Surface or in Food is L. monocytogenes?...

We recommend that you establish and follow a corrective action plan that describes the steps to be taken, and assigns responsibility for taking those steps, to ensure that no finished RF-RTE food that does not support the growth of L. monocytogenes enters commerce if:

• The food bears or contains greater than or equal to 100 cfu of L. monocytogenes per gram of food; or
• The food has been prepared, packed, or held under insanitary conditions whereby it may have become contaminated with filth, or whereby it may have been rendered injurious to health."

As far as the FDA is concerned, if you can detect a human pathogen that can cause death or severe health consequences, that's a Class I recall.  No matter how little, the food is considered adulterated and is not to enter commerce.  We are sending executives to prison for this these days, and it is the FDA that is prosecuting.

And having just listened to the FDA about FSMA, it's not going to get more lax.  That is definitely not the trend that I heard this week.

I'm not sure of the math on the <0.04cfu/g means nd in 25g.  I suspect that 0.04 cfu/g is the limit of detection with the tests that were accepted in 2008

 

Have a look at the link in my previous post. It's a standard assumption in QMRA texts. ND = <1cfu / 25g = <0.04cfu / g.

From a microbiological safety POV, the  important point is the interpretation of the significance of  100/g. I suggest you have a look at some of the QMRAs to see the logic. Not that it's black and white of course, back to RAs again. :smile: