6 replies to this topic

[Miss Frankie]

Can someone point me in the right direction for finding clear, defined rules on testing for listeria and retesting?

I have searched the FDA site and can't find that I need.

 

My co-worker and I have proposed a slight modification on how we perform our salmonella and listeria testing. Our proposed change would save the company a LOT of money. BUT, if did have a positive listeria, it would result in a higher loss than our previous method, but still the savings would still be huge.

 

Our senior managers like our initial change, but not the higher loss of product, which is understandable.  BUT, they want us to change how we would retest.

 

Currently, we pull 3 samples from every 36 cases for a test. (2 per pallet).  Our change would be to pull 6 samples from 72 cases (1 per pallet)

So if we tested positive, we would retest the 72 cases and then dispose of 72 cases if the retest was positive.

Senior managers are ok with the first test of 72, but want any retest to be broken down to every 24 cases (or ever 12), so if ONE set of 24 was positive, only 24 (or 12) cases would be disposed of.

 

Co-worker and I do NOT agree with this but can't explain it in a way to make SM understand (language barrier partly).  
I need something I can refer them to so they can see for themselves.

 

This being said, we've only had 1 incident of listeria in the 3 years my co-worker has been here (I've only been here 1 1/2 years)

 

 

 

[Evans X.]

Greetings Miss Frankie,

 

To my knowledge there is no definitive sampling method. Rules say you have to test and you follow a general sampling guideline extrapollated from scientific data and taking into account the susceptibility of your product to Listeria contamination.

From what you describe your main problem is on the retesting. The understandable and easiest way to expalin what happens in case you release a possible Listeria positive product is to inform your SM that since Listeria is a pathogen, should you miss it and have a Listeria outbreak, then the company will be facing FDA inspections, fines, lawsuites, suspencions, possible shut down for a period of time, close monitoring from FDA afterwards and all of that topped with bad reputation, since this is gonna go public.

Simply put Listeria = possible death especially to sensitive members of the populance. It was not exaggeration that in Europe (EC 2073/2005) has a specific mention for RTE foods intended for infants to be tested for Listeria.

If it comes down to discarding 72 packs then so be it or the company may end up "discarded" if things go bad. If you search history of pathogens outbreaks and even for lesser reasons you will find plenty information of what happens and how difficult it is to recover unless you are backed up by a giant fund.

 

Regards!

[Charles.C]

Hi Miss Frankie,

 

I find the concept of rejection/destruction based solely on detection of Listeria (not a pathogen per se) difficult to justify microbiologically.

 

Another example of Listeria/Hysteria ?.

 

JFI the FSIS sampling logics following a pathogen detection are IIRC based on well-established Probability formulae as also propounded by ICMSF. The snag is that the practical implementation may require a small army of samplers and analysts.

[SHQuality]

Hi Miss Frankie,

 

I find the concept of rejection/destruction based solely on detection of Listeria (not a pathogen per se) difficult to justify microbiologically.

 

Another example of Listeria/Hysteria ?.

 

According to the EU legislation, it is apparently allowable in certain foods under a certain level (Consolidated TEXT: 32005R2073 — EN — 08.03.2020 (europa.eu)), but every supplier and customer I know requires absence, because if it is present, it can grow out of control.

 

You could try pasteurizing it (if Listeria is even susceptible to that), but I would reject anything that is Listeria positive.

 

Also, I'm curious: What do you mean by "not a pathogen per se"? 

[Miss Frankie]

Greetings Miss Frankie,

 

To my knowledge there is no definitive sampling method. Rules say you have to test and you follow a general sampling guideline extrapollated from scientific data and taking into account the susceptibility of your product to Listeria contamination.

From what you describe your main problem is on the retesting. The understandable and easiest way to expalin what happens in case you release a possible Listeria positive product is to inform your SM that since Listeria is a pathogen, should you miss it and have a Listeria outbreak, then the company will be facing FDA inspections, fines, lawsuites, suspencions, possible shut down for a period of time, close monitoring from FDA afterwards and all of that topped with bad reputation, since this is gonna go public.

Simply put Listeria = possible death especially to sensitive members of the populance. It was not exaggeration that in Europe (EC 2073/2005) has a specific mention for RTE foods intended for infants to be tested for Listeria.

If it comes down to discarding 72 packs then so be it or the company may end up "discarded" if things go bad. If you search history of pathogens outbreaks and even for lesser reasons you will find plenty information of what happens and how difficult it is to recover unless you are backed up by a giant fund.

 

Regards!

 

Easier said than done! Our president talks about how we don't want to have anyone get sick, but in reality, it's all about the bottom line and saving $$$$. 
We found listeria last year and SHOULD have destroyed a lot more product than we did, but senior management wouldn't allow it.  They said it was on them, and that's why we have insurance.

Our parent company is based in Japan, and our president is an (past) retirement age, crazy woman who is still living in the 70s with some of her ideas.

I talked to an SQF Consultant that I worked with at my previous job and she agreed with me on our testing and how much should be destroyed.  After telling this to our president, she wants NOTHING to do with this consultant, saying she's just after our money.

 

So, in order to proceed with the changes we want to make, we need to find written proof that backs up what we propose.  They (SM) won't take our word for it without siting sources.

 

Very frustrating!  (I need a new job!)

[Scampi]

Are you stereotyping after a positive hit?

 

I worked for a large Canadian company that killed many people as a result of listeria (I was not in food safety at that time) and I will NEVER take listeria sampling/testing/reporting with a grain of salt

 

To me, even disposing of the full 72 cases seems illogical to me---in what realm can you claim to know it's only those 72 cases infected?  How are you possibly collecting a representative sample anywho..........

 

Here's the information you seek-----let me draw your attention to the section in RED

 

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

 

B. Corrective Actions If You Detect L. monocytogenes in an RTE Food If you detect L. monocytogenes in an RTE food, we recommend that: Contains Nonbinding Recommendations 53 • You reprocess with a validated listericidal control measure, divert to a use in which the food will not be consumed by humans or animals, send for use in food to be consumed by animals where appropriate, or destroy the lot(s) of RTE food in which L. monocytogenes has been detected. You should consider lots produced between two cleaning and sanitizing cycles to be implicated by the product positive; • You determine whether other lot(s) of food are potentially contaminated with L. monocytogenes and segregate and hold those lots of food. We recommend that you also review environmental monitoring results to determine if other lots could be contaminated. We recommend that you subject potentially contaminated lots to “hold and test” procedures (see our recommendations for “hold and test” procedures in section XIII.F.3 of this guidance). You should reprocess with a validated listericidal control measure, divert, or destroy any lot of RTE food in which L. monocytogenes is detected; • Your corrective actions regarding your plant and your procedures include intensified sampling and testing of FCSs and non-FCSs, followed by the corrective actions we discuss in sections XIII.E and XIII.F of this guidance, until you find the source of contamination and eliminate it; and • You determine whether food in commerce would be subject to a recall.

 

For comparison, here is Canada's CFIA policy on listeria testing in RTE foods

 

https://www.canada.c...html#sampleanal

Edited by Scampi, 31 March 2023 - 06:12 PM.

[Charles.C]

According to the EU legislation, it is apparently allowable in certain foods under a certain level (Consolidated TEXT: 32005R2073 — EN — 08.03.2020 (europa.eu)), but every supplier and customer I know requires absence, because if it is present, it can grow out of control.

 

You could try pasteurizing it (if Listeria is even susceptible to that), but I would reject anything that is Listeria positive.

 

Also, I'm curious: What do you mean by "not a pathogen per se"? 

Hi SHQ,

 

Sorry delay, missed yr Post.

 

The, afaik, Globally accepted answer is here -

 

 BAM-Ch10.pdf   420.46KB   11 downloads

 

PS - hence also the "hysteria" comment. It is true there have been some very bad health incidents involving the species L.monocytogenes but not  the genus Listeria "per se".

And yes, applying pasteurization to "kill" L.mono is a cooking standard in UK.