Just thought of it - there is a guide on how many you should test by the FDA - https://www.fda.gov/...ready-eat-foods
Page 36 - "3. Sample locations and number of sites to be tested" will help you determine how many you should do. This should also be sufficient evidence for SQF.
So in your risk assessment state at the end "Based on the size of the plant, plant features, product flow, characteristics of the RTE food, the processing methods used to produce the food, and previous sampling results (if any) we will take (state how many, how often and which zones)
Thks. I think this is same file I posted here yesterday, -
https://www.ifsqn.co...nt/#entry144934
Note this is a draft Guidance. And focused on L.monocytogenes. And specific to RTE.
There are, IMO, some equally interesting (L.mono.) thoughts/observations (particularly for fresh produce) in the other Guidance file in same post.
PS - I am not in USA but a (quick) "Listeria" comparison for routine sampling/testing methodologies between FDA and FSIS appeared to suggest that - for an RTE item supporting growth of L.mono where post-lethality Listeria control (ie freedom from re-contamination) is achieved by Sanitation Program only (eg Frozen Ice-Cream), FSIS (if it had jurisdiction this product [which it does not]) seems potentially more processor-friendly inasmuch as -
(a) FSIS requires EMPG program to be applied to post-lethality surfaces only, (cf zones whole factory)
(b) FSIS prioritizes sampling frequency based on Contamination Potential / Volume of production (ice-cream > "2b" > quarterly). (cf weekly)
(c) FSIS accepts 3-5 FCS samples per Production Line at each sampling event. (cf minimum 5 [+5 non-FCS])
@HokeyP - looks like 5+5 (as per Post 9) for L.mono (or Listeria) per week is the least amount sampling you can expect from FDA. Not sure why presently 15. An attempt to go from (current) 15 > 10 per week might arouse an FDA interest in Salmonella.
PPS - A corollary to the above from a BRC/SQF etc POV would appear to be that both FDA and FSIS are implicitly supporting a viewpoint that a non-RTE finished product should not require environmental monitoring for Listeria/L.monocytogenes.
FSIS Listeria Guideline RTE meat,Poultry,2014.pdf 1.03MB
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