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mapry2

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Posted 18 December 2013 - 05:19 PM

Hi All,

 

We are dealing with Ready to Eat Frozen Fruits and Vegetables and doing some risk analysis with regards to pathogen.

 

I have gone through the CFIA, Health Canada and FDA guidelines on pathogen in RTE foods and no where found this information. Please guide me if I am missing something here.

 

All my reference documents indicating how to deal with Listeria Monocytogens but no one talking how to deal with Listeria Spp in RTE food.

 

Hopefully someone can put more light on this.

 

Thanks in advance.



GMO

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Posted 20 December 2013 - 11:04 AM

Ideally it should be absent.  I'm not familiar with Canadian legislation; strictly speaking in EU legislation up to 100cfu is permitted of mono and no restriction on other species but I don't know of any retailer who would tolerate that.



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Charles.C

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Posted 20 December 2013 - 02:02 PM

Dear mapry,

 

It is slightly unclear what you are seeking. :smile:

 

Do you mean minimally processed RTE products.?

Which kinds of fruit, veg.?

 

Do you mean Listeria from the fruit/veg. itself or Listeria from the processing environment ? I guess the former.

 

The reason why articles to risk related analyses of veg.,fruit raw materials are mainly to L.monocytogenes is because this is the major pathogen from Listeria genus.

 

Screening, particularly environmental, often starts/stops with Listeria using this as an indicator for L.mono.

Screening for raw material is more likely to go to L.mono. for reason above.

 

The haccp impact of L.mono is for example included here –

 

http://www.inspectio...410?chap=0#s5c4

 

Or are you simply looking for a micro.limit value as suggested per previous post?

 

An official micro.limit for "Listeria" probably does not exist for the reasons above although some standards are still formulated in terms of Listeria  where people do not understand the meaning of "pathogen". Or "Listeria". :smile:

 

There are many other Canadian articles in this field but I'm not clear what you are actually seeking to know ?

 

Rgds / Charles.C

 

PS -L.monocytogenes is generally regarded as ubiquitous in the environment which is why it is not unexpected to find it included in a list of typical potential pathogens for raw materials from the "field".

 

If there is absence of any postharvest  "elimination"  bactericidal process steps, any L.mono  may carry through to the final product although possibly at undetectable levels.


Kind Regards,

 

Charles.C


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KevinB

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Posted 20 December 2013 - 02:16 PM

HI mapry,

 

I recently checked with our outside lab with regards to this question. I was told that the only species of Listeria that is regulated in the US is LM and the current standard is absent in a 25 gr sample. They have also said that the presence of any listeria species should be of concern because if one species can grow in that environment then LM can also grow in that environment. 

 

Hope this helps. 

 

Kevin



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Charles.C

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Posted 20 December 2013 - 02:35 PM

HI mapry,

 

I recently checked with our outside lab with regards to this question. I was told that the only species of Listeria that is regulated in the US is LM and the current standard is absent in a 25 gr sample. They have also said that the presence of any listeria species should be of concern because if one species can grow in that environment then LM can also grow in that environment. 

 

Hope this helps. 

 

Kevin

Dear Kevin Burnsteel,

 

Thks for the input.

 

I am happy to be corrected by some documentation but I suspect that "Listeria" detection is a sufficient US official alarm bell if environmental testing is the sole objective. Probably not the situation for mapry though.

 

I anticipate the reference to nil detect / 25g (absence is unprovable, but nonetheless popular) is dependent on the product. Probably true for RTE / US due history, inter alia. And may well be shared by Canada.

 

Logically it would seem difficult to haccp support where no bactericidal step exists in the process ? I daresay the number of rejections of RTE minimally processed food is significant ?

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


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Posted 20 December 2013 - 02:40 PM

Charles

 

You inserted part of a document about auditing. Is there anyway that you can forward me that entire document or point me to where i can get it.

 

 

Thanks Kevin



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Posted 20 December 2013 - 03:03 PM

Dear Kevin,

 

Sorry, It came from another forum i think, somewhere / sometime.

 

I'm a bit of a squirrel. :smile:

 

Rgds / Charles.C

 

PS -  you might try searching for something like food / BRC internal audit although will be a lot of hits for sure


Kind Regards,

 

Charles.C


mapry2

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Posted 20 December 2013 - 10:43 PM

Thanks GMO, Charles and Kevin.

 

We are in to RTE frozen fruits like berries and tropical fruits. We import in frozen condition and repack in to the retail bags. We solely reply on the supplier to follow the proper GMP.

 

I am looking at finish product inspection for Listeria. As per the CFIA guidelines, if LM is negative then we can release the product.  

 

From what I have understood, Listeria is not a pathogen but an indicative organism to alert something has gone wrong in the GMP. 

 

But my question is as long as my end product test confirms LM nagative (irrespective of the Listeria Spp test outcome), am I good to release the product ?


Edited by mapry2, 20 December 2013 - 10:43 PM.


Charles.C

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Posted 21 December 2013 - 01:07 AM

Dear mapry,

 

I think you have slightly misunderstood the microbiology. :smile:

 

Listeria is a genus (a group of bacteria). L.monocytogenes is the major human pathogen in the group. Some of the other members do have some pathogenic characteristics but mainly for other creatures. Can see this link if seriously interested –

http://www.fda.gov/F...s/ucm071400.htm

 

Or this link for a less heavyweight view -  

http://en.wikipedia.org/wiki/Listeria

 

The Bad Bug Book (2012) comments - 

Of the five other species in the genus Listeria – L. grayi, L. innocua. L. ivanovii, L. seeligeri and L. welshimeri – only L. ivanovii is considered pathogenic, and mainly in ruminants, rather than in humans.

 

The traditional test procedure on a sample of the product is in principle something like –

 

(1) apply a screening procedure for detection of any members (species) of the genus (group) Listeria.

(2) examine any positive results from the screen to see if the detected species is L.monocytogenes

(probes are faster)

So, in principle, it is possible to have a positive result for Listeria and a negative result for L.monocytogenes.

 

I am not routinely working with Listeria/L.monocytogenes but in such a case I would imagine that a random, final, external laboratory negative result for L.mono. would usually be reported as “OK”. Such a conclusion typically cancels reporting of any presumptive screening data unless some very unusual event occurs, eg noticing some other significant risk.

 

However, here is one Canadian interpretation for Listeria / L.monocytogenes for, I think, local  food processors.

 

Attached File  listeria monocytogenes policy, 2011.pdf   1.16MB   94 downloads

 

From a quick look, the answer to yr type of question depends on the specific product category. And  (see the Flow charts provided) may well be “problematic”, ie require further expert advice.

 

The answer for imported goods will probably require similar information regarding Canadian import standards.

 

Are you  seeking a legally accurate opinion on some actual data/situation or is this a purely hypothetical query in the sense of a safe / wholesome  commercialisation of your product? :smile:

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


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Posted 21 December 2013 - 10:15 AM

 

 

The traditional test procedure on a sample of the product is in principle something like –

 

(1) apply a screening procedure for detection of any members (species) of the genus (group) Listeria.

(2) examine any positive results from the screen to see if the detected species is L.monocytogenes

(probes are faster)

So, in principle, it is possible to have a positive result for Listeria and a negative result for L.monocytogenes.

 

 

 

 

 

This the usual method in my experience.  Simple:  Test for L. spp. if positive, then prove negative for LM.  

I find it utterly astonishing that any level above negative is acceptable, given that this pathogen accounts for a high mortality with infection.  Considering the durable nature of this bug (surviving in low aw, low temps, low oxygen, etc), our own cooking method is a 6d log for shellfish.  We cook with a significant loss of raw material, but peace of mind.

Of course for fresh produce this cooking method isn't an option, but a healthy dose of PAA at 5% (50-190 ppm) in final processing should give you the same log reduction.


Food Safety News  Marine Stewardship Council

 

"Some people freak out when they see small vertebra in their pasta" ~ Chef John


Charles.C

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Posted 23 December 2013 - 11:16 PM

Dear mapry,

 

Does the previous information enable you to make a  decision regarding release of product ?

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


mapry2

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Posted 23 December 2013 - 11:19 PM

Hi Charles,

 

Yes it does. Thats why I was confused. I understand there is a potential risk by Listeria Spp itself. But no standard talking about it. But the information here did help me getting a better understanding of the risk.

 

Thanks again.



GMO

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Posted 30 December 2013 - 12:43 PM

Just be wary if you are releasing on the basis of testing; L. (not mono) does not mean mono is not there.  Also depending on how the species is established, it is easy on lab tests to confuse L mono with L innocua (just to worry some people on here...)



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Posted 03 January 2014 - 05:45 AM

We are in to RTE frozen fruits like berries and tropical fruits. We import in frozen condition and repack in to the retail bags. We solely reply on the supplier to follow the proper GMP.

 

But my question is as long as my end product test confirms LM nagative (irrespective of the Listeria Spp test outcome), am I good to release the product ?

 

With Listeria present there is much higher risk that monoctoygenes is there too. My concern would be despite a clear result what is the likelihood of it being positive for mono at end of life.

 

Also if you are totally reliant on your supplier you need to make sure they investigating the issue, taking action plus increasing the sampling future deliveries.

 

Regards,

 

Tony





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