By Chris Young, AAMP Executive Director
This article was published previously by AAMP due to the number of Listeria positive tests in plants around the country. AAMP has received increased questions from some members regarding Listeria, as well as the number of recalls that have happened recently. Please take the time to review this article as a reminder and reach out to us if you have questions.
How are you doing in controlling Listeria Monocytogenes in your facility? When was the last time you took the time to take a look at your Listeria control program? Is your prerequisite program for Listeria up-to-date and functioning as you say it is? What alternative are you using and what are you doing for testing? Are you employing a test and hold policy?
These are all legitimate questions to ask yourself and you need to be clear on the answers to each one. In recent months, there has been an increase in recalls for possible product contamination from Listeria Monocytogenes in ready-to-eat (RTE) products. I am not sure if there is an increased presence in Listeriathat has occurred naturally, or if it is because we have become complacent to the job it takes to implement our Listeria controls and preventions.
Setting up sanitation programs
Listeria is naturally occurring and will not be eliminated completely, but it can be controlled and prevented from contaminating your products. Listeria thrives in the environment that exists in most of your facilities. It loves the cool wet areas like floor drains and overhead cooling units in processing rooms, as well as other places. Controlling Listeria should be a concern and priority for everyone, not only those who make RTE products. Listeria should be a target when setting up sanitation programs. How often do you clean and treat problem areas like floor drains and cooling units, including the drip pans? Once you have looked at your sanitation procedures, you need to then look at product flow and determine the area where products could possibly become adulterated if Listeria were to make it past your controls. Look at how products are moved throughout the facility; is there a concern about wet floors and/or splash from spray making it onto the products? Does the product pass areas where moisture coming out of an overhead cooling unit could land on uncovered product? A thorough audit of your product flow is needed to ensure that you have covered a possible contamination site.
Plenty of information is available to help you when you review your Listeria control program. Several guidance documents offer helpful information. USDA has a compliance guideline for Listeria for post lethality; they also have one for control of Listeria in delis and FDA has a new guide for Listeria control. AAMP has a prerequisite program available on our website that is complete with flow diagrams, testing guidance, and log sheets. If you are unsure with which products are covered, the following information from USDA’s guidance document can help get you started. If your program is in place, I would encourage you to go back and review it to make sure that nothing has changed and that it is functioning as stated.
Products Covered by the Listeria rule:
Establishments should determine the alternatives to which it will adhere in its processes.
The following steps can guide establishments in making this decision:
- Determine whether product is RTE or not RTE (NRTE) Resource 1 of the Directive and Attachment 2 of these Compliance Guidelines can guide the establishment in determining whether its product is RTE or NRTE. NRTE products are not covered by the rule.
- If the product is RTE, the establishment should determine whether the product is exposed to the environment after the lethality treatment (e.g., cooking) and before packaging. Examples of exposure to the environment after the lethality treatment are the following: 1) when product is removed from its cooking bag and re-packaged; 2) when product is removed from the cooking bag and sliced or cut-up and re-packaged; or 3) when product is peeled and repackaged; or when it is fermented or salt-cured or dried and smoked and packaged. (e.g., roast beef, cooked ham for slicing, hotdogs, fermented sausage, cured ham, and jerky).
- If the product is not exposed to the environment after the lethality treatment and before packaging, then the product is not covered by the Listeria rule. Examples of these products are fully cooked product in cook-in-bag that leaves the official establishment in the intact cooking bag; thermally processed, commercially sterile products; and products receiving a lethality treatment and hot-filled as long as the lethality temperature and sanitary handling are maintained during the period of time in which the product moves from the point of lethality to the point of packaging.
- If the product is post-lethality exposed, the establishment should determine the control methods it is using to control Listeria Monocytogenes during the post-lethality exposure. The control methods used by the establishment will determine to what alternative the product can be categorized.