The Food Safety and Inspection Service (FSIS) has authority under the Federal Meat and Poultry Products Inspection Acts to ensure that products are not adulterated at retail and at all steps in the distribution chain. Retail operations are generally inspected by State or local authorities which have adopted some form of the model Food Code developed by the Food and Drug Administration (FDA) with input by FSIS.
A comprehensive risk assessment was completed by FSIS and FDA that identified the need for specific actions which could be taken by retailers at delis to reduce the risk for listeriosis, and improve public health. Therefore, FSIS determined it was appropriate to create a Compliance Guideline that was helpful for the retail sector. The Compliance Guideline steps include specific actions that retailers can take to help maintain deli products under sanitary conditions to prevent Listeria from adulterating product. A self-assessment tool is also provided that can assist retailers in determining the adequacy of their current practices in controlling Listeria. Best practices in the control of Listeria that may be adopted are also provided.
These actions are not to replace the State or local authorities' Food Code, but are to assist retailers in identifying additional best practices they can take in protecting public health. The risk assessment estimates that for those listeriosis illnesses that are attributed to deli meats; 83% are associated with deli meat sliced and packaged at retail as opposed to deli meat sliced in federally-inspected establishments (Endrikat et. al., 2010).
Doom and Gloom highly recommend that retail operators review the Compliance Guidelines and the FSIS supporting materials, and make any applicable changes in their operations.
Areas to consider include:
The Compliance Guideline provides good recommendations for retailers to ensure they are able to incorporate "best practices" for controlling Lm at the deli. Doom and Gloom say, "before you slice - make sure you have incorporated this advice!"
About "Dr. Doom"
Mixed in with the attorneys at OFW Law is the former USDA Food Safety Inspection Service's (FSIS) Administrator, Dr. Barbara Masters. Dr. Masters is a veterinarian who spent eighteen years with FSIS - the final three years as Acting Administrator and Administrator. During her rise to the Administrator's position, Dr. Masters served as the Deputy Assistant Administrator for Office of Field Operations. While in these key leadership positions at FSIS, Dr. Masters' primary focus was on the implementation of science-based policies for the protection of public health. Dr. Masters issued the initial Federal Register Notices for a systematic approach to humane treatment of livestock and poultry.
Dr. Masters was involved in the drafting of the training of inspection personnel on the Hazard analysis and critical control points (HACCP) and Sanitation Standard Operating Procedures (SSOP) regulations. She was the lead of the FSIS HACCP Hotline. In addition, Dr. Masters provided technical review for establishment's hazard analysis, HACCP plans and supporting documentation. She started her career at FSIS as a public health veterinarian that had responsibilities for ante-mortem inspection, sanitation inspection and all post-mortem inspection responsibilities. She has a good understanding of what happens at the in-plant location, because she has spent many of long days working there.
About "Ms. Gloom"
In the attorney ranks at OFW Law, there is only one attorney who would raise a hand if all were asked if they had any "hands-on" experience in the operation of a Townsend "Frank-O-Matic" hotdog maker, producing bean sprouts for use in egg rolls or in managing a food facility sanitation crew. In fact, there are probably no attorneys out there who could raise their hands except Jolyda Swaim.
Prior to law school and OFW Law, Ms. Swaim spent years in the food industry, beginning as a microbiologist and Quality Assurance technician. In these years, she had direct charge of quality assurance, production, sanitation and consumer affair departments at various companies producing products from pickles, sauerkraut and barbeque sauce, to various meat and poultry products, to frozen entrees, egg rolls and pizza to spices and spice blends. Her last position at Sara Lee as Director of Food Safety had her auditing its facilities in the United States and Mexico to ensure facilities producing ready-to-eat products were following best practices in sanitation and product handling.