6 Tactics You Need To Have In Your Listeria Control Program For FSIS Compliance
It’s no secret to anyone in the food and beverage industry that an outbreak can cost an average of $10 million in damages. So why are food manufacturers still reacting AFTER something happens instead of preventing BEFORE a situation runs out of control? It’s beyond vital that plant managers not only have an appropriate corrective action plan for handling positive test results on finished product, but it’s equally if not more important to have strong preventative measures in place to catch pathogens in the production environment BEFORE they enter the product and worst of all BEFORE they leave the facility!
The USDA Food Safety and Inspection Service offers a detailed guideline for Listeria testing. In it, you will find information that you can apply to your Listeria control programs.
In order to remain proactive, six tactics are necessary to be incorporated into your Listeria control program to ensure you are being as proactive as you can in food safety.
1. Identify the Types of Products Produced
You need to be sure that your HACCP plan has the Listeria control program considered. You should be able to identify a critical control point (CCP) where “control can be applied to eliminate biological, physical or chemical hazards to minimize the likelihood of occurrence.”
2. Figure out Listeria Control Alternatives
There are three different risk-based alternatives for categorizing products in your Listeria control program. You need to determine which alternative is used for each product. The University of Wisconsin Madison Center for Meat Process Validation defines each alternative as:
- Alternative 1: Use a post-lethality (post-cooking) treatment that reduces or eliminates Listeria monocytogenes (LM) AND an antimicrobial agent or process that suppresses or limits LM growth throughout shelf-life.
- Alternative 2: Use either a post-lethality treatment that reduces or eliminates LM OR an antimicrobial agent or process that suppresses or limits LM growth throughout shelf-life.
- Alternative 3: Use only sanitation measures to prevent LM contamination.
3. Identify what Organisms Need to be Sampled
Determine if you are sampling LM, Listeria spp., or Listeria-like organisms.
4. Create Routine Sampling Programs
You will need to list the sites that need to be sampled, including all possible food contact sites. You also need to list the frequency with which samples will be collected and have an explanation as to why that frequency is sufficient to manage your own unique risk profile.
As you are establishing your Listeria control program, be sure to note the size of each site that will be sampled. In addition, you will need to establish a sampling and testing method, including a step-by-step collection method. The type of analysis performed will need to be detailed so laboratory analysis methods can be maintained by the lab.
If you’re sampling a non-FCS product then the number and frequency of samples will need to be collected as well as your response to positive results.
5. Enhance Your Sampling Programs Continuously
It’s imperative to have the follow-up sampling timeframe detailed. What will you do after your first FCS positive result? Or, if you’re doing an intensified testing, you need to be sure to have a timeframe outlined for additional FCS positives. Your response plan to these positive results will also need to include corrective and preventative actions. If you are running an intensified testing you need to include details about your Sanitation SOP.
6. Hold & Test Programs for Product Regularly
FSIS outlines a Hold and Test program you need for your product, including the:
- Conditions for hold and test
- Organism to be sampled
- Type of analysis performed
- Number and type of products to be sampled
- Product disposition in case of a positive result
Ensuring these 6 steps are outlined will help you when creating your Listeria control program. This in-shift food safety solution will give you greater insight and actionable steps from reaction to prevention.