pathogen reduction. comparison/contrast n salmonella u performed by fsis n e. coli u performed by...
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Pathogen Reduction
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Comparison/Contrast
Salmonella Performed by
FSIS
E. coli Performed by
Establishment
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Comparison/Contrast
Salmonella Enforcement
begins on same day plant comes under HACCP
E. coli Enforcement for
greater than very low volume plants in January 1997
Enforcement for very low volume plants in June 1997
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Comparison/Contrast
Salmonella Used as an
indicator of process control and sanitary dressing procedures
E. coli Used as an
indicator of process control and sanitary dressing procedures
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Comparison/Contrast
Salmonella Sponge Whole bird rinse Product
E. coli Sponge Excision Whole bird rinse
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Comparison/Contrast
Salmonella Carcass
Sponge beef swine turkey
E. coli Carcass
Sponge beef swine turkey
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Comparison/Contrast
Salmonella Excision
none
E. coli Excision
beef swine
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Comparison/Contrast
Salmonella Whole bird rinse
chicken
E. coli Whole bird rinse
chicken turkey
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Comparison/Contrast
Salmonella Raw Product
ground beef, ground pork ground
chicken ground turkey
E. coli Raw Product
none
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Comparison/Contrast Salmonella
FSIS samples Performance
Standards qualitative positive or
negative # samples
tested (n) maximum # of
positives to achieve standard (c)
E. coli Plant samples Performance
Criteria quantitative m/M expressed as
cfu/cm2 or as cfu/ml
statistical process control
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Comparison/Contrast
Salmonella Performance
Standards steers/heifers cows/bulls ground beef hogs broilers ground
chicken ground turkey
E. coli Performance
Criteria cattle swine chickens
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Comparison/Contrast
Salmonella Performance
Standards expressed as
a “positive” or “negative”
E. coli Performance
Criteria expressed as
cfu/cm2 or as cfu/ml
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Comparison/Contrast
Salmonella Sampling
procedures explained in FSIS Directive 10,230.5
E. coli Sampling
guidelines given in §310.25 and
§381.94; in 2
guidelines; and
in plant written procedures
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E. coli Guidelines
Guidelines for Escherichia coli Testing for Process Control Verification in Cattle and Swine Slaughter Establishments
Guidelines for Escherichia coli Testing for Process Control Verification in Poultry Slaughter Establishments
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Comparison/Contrast Salmonella
Sampling frequency each day
product requested is produced
based on compliance history
E. coli Sampling
frequency based on
numbers of animals slaughtered
alternative frequencies an integral part of HACCP plan
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E. coli
Basic requirements Written collection procedure Collect samples from species
slaughtered in greatest numbers Record results on a process
control chart or table
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E. coli
Written procedures identify sample collector sampling locations sampling randomness sample integrity
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E. coli Collect from predominant species
only if that species is covered by the regulations
Beef Swine Chicken Turkey
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E. coli
E. coli Control Chart
-200
20406080
100120140
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Test Number
E. c
oli c
fu/s
q cm
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E. coli
Basic compliance is determined by an E. coli Special Team Member if the plant is not under HACCP
All plants began E. coli testing in 1997 (January and June, depending on plant volume)
When a plant comes under HACCP, then the IIC can perform basic compliance if needed
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E. coli
Basic (05A01) Noncompliance (use Checklist)
Withholding action Inform plant Document NR (no trend indicator)
and attach Checklist Notify the DO If plant takes no action,
Compliance is called in
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E. coli
Other Requirements The plant must follow its written
procedure The samples must be analyzed
using an AOAC Official Method or other method published by a scientific body
The plant must keep proper records for test results
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E. coli
Other (05A02) Noncompliance with written
procedures Plant not collecting samples in
stated location Plant not sampling with appropriate
method Plant not sampling at required
frequency Plant not sampling randomly
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E. coli Other (use Checklist)
Noncompliance actions Notify plant Document on NR (mark “Other”
trend indicator) and attach Checklist
No additional action unless plant repeatedly fails to implement the immediate and further planned actions, then IIC calls DO
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Salmonella
Implementation Pre-implementation Phase
take 250 samples per plant in a one-year period
should be completed prior to implementation
no enforcement actions
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Salmonella
Implementation Compliance Phase
begins on same date as HACCP starts in plants
enforcement of standards in effect
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Sampling Frequency
Normal daily within a sample set if more than one shift, randomly
determine from which set to take the sample
acceptable to hold the sample overnight before FedExing carcass, not sponge ground product already collected
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Salmonella
There is no basic or other (05A03) The IIC takes a sample according
to the FSIS Directive 10,230.5 The sample is FedExed to the lab The lab analyzes the sample and
records the results OPHS tracks the results
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Salmonella
Results After the sample set is complete,
OPHS will e-mail the complete results to the DO Establishment (if it has provided an
e-mail address) Sampling Coordination Team
(SCT)
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Salmonella
The District Office will notify the IIC Establishment (even if OPHS sent
an e-mail message)
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Salmonella
Negative Results All parties are notified Sampling continues at normal
frequencies for new sample sets
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Salmonella
Positive Results DO will notify plant that it needs to
investigate and identify the cause and implement appropriate corrective actions
DO will guide the IIC in documenting the performance standards failure on the NR (no trend indicator, only procedure code)
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Salmonella
Positive Results DO will instruct the IIC in the
frequency for sampling further sample sets
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Salmonella
Failure to Meet Standards First time
plant needs to identify the cause and take appropriate corrective actions to lower the incidence of Salmonella for all product of the type that failed
IIC issues NR effectiveness is measured by
subsequent testing (within 60 days) frequency of testing may change
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Salmonella
Failure to Meet Standards Second time
plant must reassess its HACCP plan IIC issues NR effectiveness is measured by
subsequent testing (within 30 days) frequency of testing may change
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Salmonella
If it fails a third consecutive series:
This would constitute a SSOPand a HACCP systems failure
FSIS will suspend inspection of the product associated with the HACCP system failure
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Salmonella
Failure to Meet Standards Third time
IIC takes a withholding action for all product of the type that failed
IIC issues NR since the DO notified the IIC, the DO is
aware of the situation and will dispatch a Compliance Officer to the plant
frequency of testing other product types may change
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Salmonella
Fail Standard put into a targeted pool start second sample set for failed
product type within 60 days sooner if compliance history
warrants it
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Sampling
Large Plants May have both compliance and
baseline samples to take Take both if possible If not possible, compliance
samples take precedence
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Sampling
Small and Very Small Plants May have both pre-implementation
and baseline samples to take Take both if possible If not possible, baseline samples
take precedence