All ready-to-eat processors, whether regulated by the Food Safety and Inspection Service (FSIS) or the Food and Drug Administration (FDA), will have the environment, food contact surfaces, and products sampled for Listeria monocytogenes. While many facilities dread this, there is no secret to being prepared for a regulatory sampling. Establishments should expect that the regulatory agency will target previous sites that were positive and sites related to poor employee practices and flow, as well as consider additional targeted sites based on conditions observed at the establishment during the visit.
In this blog, Dr. Doom and Ms. Gloom offer on-going tips for facility maintenance and repair to assist facilities in being prepared for the selection of targeted sampling sites by FSIS and/or FDA.
Future blogs will discuss employee practices and testing.
To eliminate "targeted sites," establishments should constantly be reviewing and maintaining the facility in "good repair." Areas that will be considered high priority for sampling by both FSIS and FDA include broken, cracked and rough welds, areas with moisture under damaged floors and seeping out from behind walls, peeling paint, cracked seals around doors or wall openings, saturated and exposed insulation, rusty framework, cracks and pits in equipment surfaces, hollow rollers, pipes and tubing. Establishments should ensure that equipment is cleanable and able to drain so that water is not pooling on the equipment. Additionally, establishments should ensure there are no “dead ends” or “openings to no where” on equipment and piping.
Doom and Gloom have also found that Listeria has a fondness for “asset tags” on equipment, electrical boxes on walls, areas such as support or guide bars under belts that cannot be removed, stop and start buttons, spiral freezers, areas of construction…
By “checking the room” and maintaining the facility in good repair, including considering sanitary design when making all equipment purchasing decisions, establishments are taking the first step to controlling Listeria in their facility. By eliminating these “targeted locations for sampling,” it is hoped that the establishment is also eliminating locations where there is a high probability of finding the organism or creating a harborage for it to grow and multiply.
Doom and Gloom recognize both agencies will continue to test – however, they encourage facilities to take proactive steps to eliminate the known potential harborage sites and improve food safety.
Stay tuned for the future blogs on employee practices and testing.
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.