12 replies to this topic

[Rachel Hache]

Hi everyone! I am a new supervisor in a snow crab processing company. I am looking for a guide, a table or documents that tell me the microbiological criteria to meet for export to the US. Thanks for your advice 

[Scampi]

It may be buried in this link

https://inspection.c...7/1304428174144

[Rachel Hache]

What could I do if a found a Listeria monocytogenes in our product.  What are we suppose tu do?  Un sampling of 5 sample by lot?  But I need a guide to confirm what I need to continue.

[Scampi]

Whoa-ok    Here are 2 CFIA docs to help  Listeria Control Policy and the Sampling Plan

 

By the by-I would HOLD product (recall any if it's already shipped) and retest

 

 

https://inspection.c...on or more of L.

 

The following outlines the parameters for determining the L. monocytogenes risk category of a RTE food:

• Category 1 product: an RTE food in which the growth of L. monocytogenes can occur
  • This category applies to all RTE food that does not fall in category 2A or 2B (below)
• Category 2A product: an RTE food in which the growth of L. monocytogenes can occur but is limited to levels no greater than 100 CFU/g over the course of the stated shelf-life

  Note: If the shelf-life exceeds 5 days, the RTE food could be classified a Category 2A product - but only if a validation is conducted and demonstrates that the growth cannot exceed 100 CFU/g. The Health Canada documents Validation of ready-to-eat foods for changing the classification of a category 1 into a category 2A or 2B Food - in relation to Health Canada's Policy on Listeria monocytogenes in Ready-to-Eat Foods (2011) and Listeria monocytogenes challenge testing of ready-to-eat refrigerated foods provide information on the validation of the L. monocytogenes RTE risk category.

  • This category applies to an RTE food that has a refrigerated shelf-life of 5 days or less
• Category 2B product: a RTE food in which the growth of L. monocytogenes cannot occur over the course of the stated shelf-life.

  This category applies to a RTE food that meets the following parameters:

  • products that are frozen, or
  • have a pH < 4.4 regardless of the aw, or
  • have water activity (aw) < 0.92 regardless of the pH, or
  • have a pH < 5.0 and an aw < 0.94

https://inspection.c...4/1528203403149

 

https://inspection.c...on or more of L.

[Slab]

Please see attached guidance for CFR 21 part 123 on pathogens, toxins, and chems;

 

 Fish-Fishery-Products-Hazards-Controls-FDA-EPA-Safety-Levels-in-Regulations-and-Guidance-Appendix5-August2019 .pdf   490.43KB   8 downloads

 

If any of the limits in attachment are exceeded then you need to recall product. 

[Rachel Hache]

I have the informations for the Canada, but it's for export into US that I can't find anything

Do you have something for US market?

[Scampi]

The doc that Slab attached says any detectable limits of l.mono are not permitted. So you need to ensure that your holding and testing prior to exporting

 

 the United States has a “zero tolerance” for L.mono in RTE foods.  A zero tolerance policy means absence of L.mono in 25 gram samples (i.e., less than 1 in 25 g, or less than 0.04 in 1 g), which is typically reported by microbiology laboratories as <1/25g or <0.04/g.

According to the U.S. Food and Drug Administration (FDA), this standard is currently in effect whether or not a food supports the growth of L.mono.

[Charles.C]

Hi everyone! I am a new supervisor in a snow crab processing company. I am looking for a guide, a table or documents that tell me the microbiological criteria to meet for export to the US. Thanks for your advice 

 

Hi Rachel,

 

Few comments/queries.

 

Some info on presentation would have been useful. I assume frozen and not vac.packed.

 

(1) Rachel - I was personally unable to locate any US data via links in Post 2. Were you ? If so what (or where) were the result(s) ?

 

(2) I speculate that the directly relevant data in Slab's useful attachment may mostly be those that referenced FDA's compliance programme x.842,/policy y.300 +  Shank et al (also see below).  (+ ??) . Unfortunately the current x.842 FDA document seems elusive as far as data is concerned. (older versions of document differ regarding some values and have some additional requirements).

 

My prediction is that definite items in Slab's attachment listed under  "BIOLOGICAL" are -  2(older versions do have this in x.842 ), 3, 5(older versions differ quantitatively) and maybe 4(IMEX of frozen raw seafood [not crab] this was not tested afaik).

 

Sampling for Salmonella is presumably FDA's massive BAM scheme. L.monocytogenes no idea, maybe same since identical requirement ? ("Presence" is a remarkably unquantitative statement !!)

 

Might mention that certain States of USA, eg Texas, appear to have their own additional import micro requirements for crabmeat.

[Rachel Hache]

Yes It's frozen crab - in shell

 

Thanks everyone for you help!

 

It'will be SO easy if FDA could share a chart with all the microbiological specification!

[Scampi]

HAHAHA the FDA never shares pertinent information in a timely or easily accessible format---part of the reason they have so many issues

 

Seriously, this is the same organization that took months and months to tell us that animal feces were contaminating lettuce when you could see the animals, the canal and the lettuce field in a photo all at once!!!

 

I have used askFSIS before, it's not quick, but you will get an answer

 

Also, dont be afraid to ask your inspector for assistance, CFIA is a good resource  (that you're paying for i might add)

[poof]

AskFSIS is for USDA related questions- however seafood is under FDA jurisdiction..

 

Here is a link to FDA/EPA agreed upon values.. https://www.fda.gov/.../80400/download

 

This is not import specific, but I hope this is at least a starting point for you!

[Charles.C]

AskFSIS is for USDA related questions- however seafood is under FDA jurisdiction..

 

Here is a link to FDA/EPA agreed upon values.. https://www.fda.gov/.../80400/download

 

This is not import specific, but I hope this is at least a starting point for you!

 

Hi gballard,

 

Thks but yr link seems  identical to that in Post 5 and discussed in subsequent posts.

[Charles.C]

Yes It's frozen crab - in shell

 

Thanks everyone for you help!

 

It'will be SO easy if FDA could share a chart with all the microbiological specification!

 

Hi Rachel,

 

JFI/clarity I have illustrated what I deduce to be the most likely micro requirements (ie 2-5) for frozen, RTE, crab from 2019 document and compared to data in previous edition of FDA Fishery manual (2011)

 Comparison of RTE Micro. Data 2011, 2019 - FDA-EPA REGS.xlsx   352.17KB   5 downloads

 

And, JFI here is the equivalent, official(afaik) FDA-EPA data for 2001  (micro. solely related to  Compliance Program 7303-842/Policy).

(this pdf may have subsequently been replaced by the appendix 5 in successive editions of the Fishery manual).

 FDA-EPA safety levels in regs and guidance,3rd ed,2001.pdf   125.2KB   1 downloads