10 replies to this topic

[jtang]

Can I get feedback on this, what is everyone doing for their facility?

 

 

If your product is considered low risk for Listeria. We do not have finished product testing as a micro clearance for product release (we only test SPC and coliforms/E.Coli as a due diligence and internal trending).

 

Do you put product on hold AFTER environmental Listeria swabs for food contact surfaces?

 

My take on this is that environmental monitoring is a spot check, done weekly, and putting product on hold does not capture others that were not tested. Also the purpose is for environmental monitoring, not product clearance.

 

Thanks!!

[PS1]

Hi,

Just a quick reply as I am about to go out the door so apologies for brevity.

 

What does your pathogen management manual say?Make sure you adhere to what is written there. 

 

How do you know that that the product doesn't contain Listeria? I'm assuming that its monocytogenes too not species? Low risk does not = no risk.  How often are you performing the environmental swabbing? 

 

I would put the product on hold and do product contact testing and also some product testing (select batches made around the same time period as the environmental swab). Its better you have the product under your control then in the marketplace and then have to recall it. 

 

You will also need to re-evaluate your redline controls (if applicable), cleaning and sanitation procedures, staff training, maintenance etc. Perform a few investigative swabs to work out the source of the contamination. 

 

My 2c :)

[Charles.C]

Can I get feedback on this, what is everyone doing for their facility?

 

 

If your product is considered low risk for Listeria. We do not have finished product testing as a micro clearance for product release (we only test SPC and coliforms/E.Coli as a due diligence and internal trending).

 

Do you put product on hold AFTER environmental Listeria swabs for food contact surfaces?

 

My take on this is that environmental monitoring is a spot check, done weekly, and putting product on hold does not capture others that were not tested. Also the purpose is for environmental monitoring, not product clearance.

 

Thanks!!

 

Hi jtang,

 

More info is required for a relevant answer.

 

BRC standard or  ?

Product / process ?

[IzzyP]

I agree with PS1. You need to put what you can on hold and implement a testing regime of both your plant & product.

 

I would test batches of finished product made for listeria, and I would do more than one sample from each batch (depending on batch size). You may need to consider testing your raw ingredients too. Unfortunately your low risk operation now needs to be reassessed and it may be that you elevate it to a medium risk until such time you have enough data to reduce it back to low risk.

 

With regards to the environmental swabbing, I would swab the life out of everything in that area, working my way out (in a circle). Id also make sure that everything  (and I mean everything) was thoroughly cleaned and then re-swabbed (if it was there on the original, then you want to make sure that the cleaning has removed it) . I would increase my swabbing frequency until I had X number of days clear. I'd also map out where I'd swabbed and what was positive, so you can build up a trend. 

[Charles.C]

Can I get feedback on this, what is everyone doing for their facility?

 

 

If your product is considered low risk for Listeria. We do not have finished product testing as a micro clearance for product release (we only test SPC and coliforms/E.Coli as a due diligence and internal trending).

 

Do you put product on hold AFTER environmental Listeria swabs for food contact surfaces?

 

My take on this is that environmental monitoring is a spot check, done weekly, and putting product on hold does not capture others that were not tested. Also the purpose is for environmental monitoring, not product clearance.

 

Thanks!!

 

Hi jtang,

 

Did you mean after a Listeria result is positive ?

 

That would obviously, for the related production, not comply with "positive release" if  the criteria for such release  included environmental  "Listeria" being undetected (which they presumably should do).

[jtang]

Hi,

Our regulatory guideline says we do not need to put product on hold on the first listeria positive in environmental swab.

We need corrective actions (sanitation), and reswab.

 

However, I want to see what the industry practice is, and if it is necessary to go beyond the regulatory guideline. As some of us feels that this is more applicable to products with shorter shelf life (which cannot be held back by testing), versus our product with shelf life that is 1 year.

 

Another reason for my question is that, by holding back any product that we do swabbing on the same day for... does it not make Listeria a micro clearance. And why would it be necessary when pathogen testing is not a micro clearance for our products?

 

 

Hi,

Just a quick reply as I am about to go out the door so apologies for brevity.

 

What does your pathogen management manual say?Make sure you adhere to what is written there. 

 

How do you know that that the product doesn't contain Listeria? I'm assuming that its monocytogenes too not species? Low risk does not = no risk.  How often are you performing the environmental swabbing? 

 

I would put the product on hold and do product contact testing and also some product testing (select batches made around the same time period as the environmental swab). Its better you have the product under your control then in the marketplace and then have to recall it. 

 

You will also need to re-evaluate your redline controls (if applicable), cleaning and sanitation procedures, staff training, maintenance etc. Perform a few investigative swabs to work out the source of the contamination. 

 

My 2c :)

[jtang]

Hi Charles,

I want to know if we should put ALL products on hold, from last sanitation to next, on the day we do food contact Listeria swabbing, before we get results.

 

Current regulatory procedure, as well as our own SOP, which we follow regulatory guideline, is to do full cleaning, and reswab. No products are put on hold.

 

But my question is more from a risk stand point...

 

FYI - it's the Health Canada decision tree that we follow.

 

Thanks!

 

 

Hi jtang,

 

Did you mean after a Listeria result is positive ?

 

That would obviously, for the related production, not comply with "positive release" if  the criteria for such release  included environmental  "Listeria" being undetected (which they presumably should do).

[Charles.C]

Hi jtang,

 

IIRC, the USA detail the required follow up procedure regarding "holding" in their Listeria control documents.

 

IIRC it may also relate to your (unknown) product/process.

 

Whether Canada follow a similar procedural pattern, no idea.

 

PS - sorry, i missed yr post 6, i guess Canada does spell out what to do just like USA.

Any risks will presumably relate to yr process details / control procedures.

[jtang]

Hi Charles,

We refer to the Canadian Policy on Listeria mono. in Ready To Eat Foods. http://www.hc-sc.gc....es_2011-eng.php

Our product is kept frozen, but is thawed and ready to eat. Same category as ice cream.

 

If we follow the procedure, am I correct to say we have fulfil environmental monitoring?

Corrective action is to clean and reswab (individually).

 

Finished product testing is a separate procedure. We test SPC and coliforms per lot (daily), and only when we get high counts, we test for Listeria species.

 

 

Hi jtang,

 

IIRC, the USA detail the required follow up procedure regarding "holding" in their Listeria control documents.

 

IIRC it may also relate to your (unknown) product/process.

 

Whether Canada follow a similar procedural pattern, no idea.

 

PS - sorry, i missed yr post 6, i guess Canada does spell out what to do just like USA.

Any risks will presumably relate to yr process details / control procedures.

[Charles.C]

Hi Charles,

We refer to the Canadian Policy on Listeria mono. in Ready To Eat Foods. http://www.hc-sc.gc....es_2011-eng.php

Our product is kept frozen, but is thawed and ready to eat. Same category as ice cream.

 

If we follow the procedure, am I correct to say we have fulfil environmental monitoring?

Corrective action is to clean and reswab (individually).

 

Finished product testing is a separate procedure. We test SPC and coliforms per lot (daily), and only when we get high counts, we test for Listeria species.

Hi jtang,

 

Assuming yr linked document is the current version, looks like you need to follow Procedure MFLP-41 for environmental sampling with the results interpreted as, depending on yr product category, Figs 1/3 or 2/3. These figs/text also specify the Corrective Action where required.

 

 environmental sampling.pdf   503.24KB   128 downloads

 

A finding of Listeria spp. in the RTE processing environment should trigger follow-up actions, e.g., corrective actions which include intensified cleaning and sanitizing, timely re-testing of the contaminated area, testing of end-products that were potentially in contact with the positive FCS, in-depth review of the plant's food safety system, etc., as appropriate...................etc

 

 

Any Canadian users welcome to correct if otherwise.

[Charles.C]

Hi jtang,

 

This is a slightly OT addendum to previous post -

 

With respect to Food Contact Surface (FCS) / Listeria sampling frequencies, there is a highly detailed (2013) presentation for meat/poultry RTE products versus Category1/2/RRL settings at the link below.

I have so far not seen any analogous data for other product types (yr link-post9 only refers to a sample size of10 afai cud see) so may be a useful guideline if no other resources. I noticed some of the FCS appendix flow charts are v.similar  to those in yr 2011 link-post 9

 

http://www.inspectio...0541911699#app3