Tag Archives: Zero Tolerance

Listeria: Is zero tolerance consistent with risk-reduction

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Tom Karst of The Packer writes it doesn’t seem quite right that many fresh produce processors aren’t testing for listeria on food contact surfaces in their facilities. Aren’t belts and other parts of a processing plant that touch product an important place to look for pathogens that might be present on food? 

listeria4Yet, that is the way it is, based on industry’s evaluation of Food and Drug Administration Guidance. Because any finding of listeria on food contact surfaces could result in an immediate recall situation, many in the industry believe the FDA’s zero-tolerance policy inhibits companies from testing food contact surfaces. 

The FDA is considering changing some of their guidance on listeria testing. Industry experts a new version of the guidance by late this year or early next year.  Perhaps the FDA will give more flexibility for companies to test for the listeria species – indicating the presence of the family of bacteria, but not necessarily the dangerous Listeria monocytogenes strain. Perhaps the FDA will establish a tolerance level for Listeria monocytogenes, though that doesn’t seem likely.

Karst got some standard answers from government spokesthingies, but got a more proactive answer from Martin Bucknavage, a Pennsylvania State University Department of Food Science food safety extension specialist, who said fresh produce and other food companies have to do a better job of understanding the presence of listeria within their operations and take stronger corrective actions. Most of the testing now being done for listeria is pre-operational and on nonfood contact areas, which he said has limited use.

“They have got to get more proactive and get rid of it,” he said. “I think it is time to batten down the hatches, get aggressive on sampling and put this thing to bed.”

Government warns plants not to alter practices during listeria testing

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Anyone can clean up for a day. I’m proof.

But the U.S. Department of Agriculture’s Food Safety and Inspection Service is warning meat and poultry processing plants to cut it out: how else will the government-types know what goes on – listeria-wise — the rest of the year, or every four years?

"By altering routine practices, establishments may make changes that are not consistent with their documented food-safety system and that impede FSIS’s ability to assess the safety of the product," FSIS said in a notice signed by Daniel Engeljohn, assistant administrator for the Office of Policy and Program Development.

The notice warns processing plants to avoid making changes in their procedures in food manufacturing during testing and says that a Noncompliance Report (NR) could be issued to a plant that changes its practices without good reasons during LM testing. Permission to use the equipment involved in making the product could also be denied, the notice says.

Every four years, FSIS conducts a Food Safety Assessment (FSA) and routine sampling for listeria (RLM) at any plant that produces ready-to-eat meat and poultry products, such a frankfurters or chicken nuggets. Intensified Verification Testing (IVT) is conducted anytime LM is found in the product or on a food contact surface, the notice said.

"A recent analysis of data from FSIS LM verification programs showed that some establishments have altered routine production, sanitation, or food safety practices during RLM or IVT sampling," Engeljohn wrote. "These changes typically are temporary, in that they are applied only during FSIS RLM or IVT sampling, and normal production processes are resumed at the completion of the RLM or IVT sampling," he wrote.

The changes have included increasing the use of sanitizer during testing; "drastically" reducing the length of the production shift, the lot size, or the number of employees handling the product; skipping production of product with a higher level of risk, such as sliced product; and failing to use equipment that had previously been shown to be contaminated.

"Such practices can interfere with FSIS’s assessment of routine conditions or corrective actions at the establishment and may limit FSIS’s ability to determine whether post-lethality exposed RTE meat and poultry products are not adulterated as required by the Federal Meat Inspection Act (FMIA) and Poultry Products Inspection Act (PPIA)," Engeljohn wrote.

If the plant cannot provide a "supportable rationale" for making changes in its processes during the scheduled testing period, the test should be rescheduled and FSIS enforcement personnel should inform their district offices, the notice said.

Does zero tolerance promote such practices? 

Don Schaffner, guest barfblogger: Looking for ugly in the food industry

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One of my favorite books of all time is "Out of Control" by Kevin Kelley.  It’s a non-fiction book that deals with understanding complex  systems.  Kelley is a bit of a polymath.  He was a hippie, who edited the hippie bible, the whole earth catalog.  He was there at the beginning of the internet with the creation of the Whole Earth ‘Lectric Linkup.  I’ve starting reading his blog recently, and he  always has something interesting to say… like how to build foam robots.

Anyway, he recently blogged about "Looking For Ugly" where he writes "Preventing errors within extremely complicated technological systems is often elusive. The more complex the system, the more complex the pattern of error".  He’s writing generally, but I immediately thought about the food system.

Kelley goes on to write specifically about the airline industry, saying "The safety of aircraft is so essential it is regulated in hopes that regulation can decrease errors. Error prevention enforced by  legal penalties presents a problem, though: severe penalties discourages disclosure of problems early
enough to be remedied.  To counter that human tendency, the US FAA has generally allowed airlines to admit errors they find without punishing them."

Hmmm.  "severe penalties discourages disclosure of problems early enough to be remedied".  Sounds to me like he’s talking about a "zero tolerance" vs. regulatory limit for Listeria.

Of course the counter argument (for the airline industry) also maps well to the food industry, as Kelley writes "The general agreement in the industry is that a policy of unpunished infractions encourages quicker repairs and reduces the chances of major failures. Of course not punishing companies for
safety violations rubs some people the wrong way."

Yup.  He’s nailed it.  This idea dovetails nicely with Doug’s call to "make all data of Listeria testing in plants public so others in the industry can improve and consumer confidence can be enhanced with data not just words."