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Listeria mono in frozen vegetables

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Tcarpenter

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Posted 21 September 2022 - 03:33 PM

I have question concerning the regs for frozen vegetables.

Facility testing customer specific product, and shipping other product of the same flavor on the same day of production without waiting for the results from the micro of the other customer.

What would be the procedure if customer product tested positive for mono.

Frozen vegetables have to be cooked, cooking instructions on package, goes to food service. Would the firm need to recall cases of product sent to the other customer.

Procedure has been updated all product on production day on hold until results come back, testing not customer specific but product specific.

Thanks



G M

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Posted 21 September 2022 - 04:16 PM

...

What would be the procedure if customer product tested positive for mono.

...

 

Generally speaking I would expect everything back to the last verified sanitation cycle to be tied to that positive result, and everything containing those same raw material lots.    

 

If you have long operational runs or large batches of ingredients that can result in the kind of recall that covers vastly larger quantities of finished goods than the single lot that tested positive.  



jfrey123

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Posted 21 September 2022 - 04:33 PM

I think putting each day's production on hold is going to be a chore in maintaining a massive hold log.  Without knowing which GFSI scheme you're under (if any), I default to SQF code requirement 2.4.7 Product Release that states a company has to determine their own proper steps in releasing a product for shipping (i.e. which inspections and analysis must be complete).  You could implement a policy change that no product is to be released without micro tests being reviewed.  It's not on hold for a problem, it's merely not available for release pending a positive QA review of required documentation.

 

Finding mono in the product would require a hold at minimum for extra testing.  If you've already shipped product and therefore cannot further investigate a stray mono result, I think you'd be hard pressed to justify not performing a recall.



Brothbro

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Posted 21 September 2022 - 05:20 PM

I would agree with jfrey123, it seems like the risks associated with your product would require some micro testing prior to release from your facility. I've worked in facilities where this system is managed through a "soft" and "hard" hold process. All finished goods are automatically placed on soft hold and kept at the facility while testing is underway. After test results are reviewed an approved by qualified personnel, goods are released from soft hold for distribution. If test results indicate a problem, product is instead moved from the soft hold onto a hard hold. From here the investigation begins into root cause, disposition, etc.

 

The soft hold system has the advantage of keeping product quarantined while test results come in, while not throwing off the metrics associated with product that has failed specifications.

 

I believe there are laboratories that offer listeria mono testing via PCR with less than 24 hour turnaround time. A well designed sampling system can also help reduce the amount of product that needs to go on hold when positive results are found.

 

In this situation I would also agree a recall is needed to further test the lot and start an investigation. For the future, your procedure update of not releasing product until test results confirm food safety will prevent recalls of this nature.



Scampi

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Posted 21 September 2022 - 05:22 PM

Without knowing which GFSI scheme you're under (if any), I default to SQF code requirement 2.4.7 Product Release that states a company has to determine their own proper steps in releasing a product for shipping (i.e. which inspections and analysis must be complete).  

 

 

You default should always be legislative regulatory requirements, not your GFSI scheme

 

XIV. Sampling and Testing of RTE Foods A. Periodic Sampling and Testing of RTE Foods to Verify Adequacy of Your Controls Periodic sampling and testing of RTE foods that you produce can provide a historical reference of performance for your production plant and verify the adequacy of your control of L. monocytogenes over time. We recommend that you test food products for L. monocytogenes rather than for Listeria spp. because of the risk to public health from L. monocytogenes in food. If you choose to test food for Listeria spp. and find it to be positive, we recommend you determine whether the Listeria spp. is L. monocytogenes or treat the food as if it were contaminated with L. monocytogenes. We recommend that you hold all product that is represented by the food you test, e.g., food lots produced from cleanup to cleanup. We recommend that you establish and implement a written procedure for the periodic collection of samples of your RTE food product, and for testing those samples for the presence of L. monocytogenes. We recommend that your written procedure include the frequency of sampling (e.g., monthly, quarterly) and the sampling plan. The frequency of sampling and the sampling plan will depend on many things, such as customer requirements, the risk of foodborne illness if the finished product is contaminated with L. monocytogenes, and the frequency of detection of Listeria spp. in environmental samples. For recommendations on corrective actions to take if you find L. monocytogenes in samples of an RTE food, see section XIV.B of this guidance.

 

 

https://www.fda.gov/...Foods-(PDF).pdf


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jfrey123

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Posted 21 September 2022 - 08:36 PM

Apologies Scampi, I probably could have explained better.  I was attempting to point out an example of the positive release model SQF requires, and how such a practice may assist the OP.  I did not reference regulation in that matter as I'm unable to find any FDA requirement of positive release for foodstuffs.



Charles.C

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Posted 21 September 2022 - 09:12 PM

I have question concerning the regs for frozen vegetables.

Facility testing customer specific product, and shipping other product of the same flavor on the same day of production without waiting for the results from the micro of the other customer.

What would be the procedure if customer product tested positive for mono.

Frozen vegetables have to be cooked, cooking instructions on package, goes to food service. Would the firm need to recall cases of product sent to the other customer.

Procedure has been updated all product on production day on hold until results come back, testing not customer specific but product specific.

Thanks

As I understand, all the product being discussed is NRTE and appropriately labelled as such.

 

I'm not in USA but I thought detection of L.mono is only (Regulatory) relevant in RTE products ?


Kind Regards,

 

Charles.C


Tcarpenter

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Posted 21 September 2022 - 09:48 PM

Thank you everyone for this information. We market the frozen vegetables as NRTE. Detailed cooking instructions on the package.





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