Pathogen Reduction

1
Pathogen Reduction
2
Comparison/Contrast

• Salmonella
• Performed by FSIS

• E. coli
• Performed by Establishment

3
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

4
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

5
Comparison/Contrast

• Salmonella
• Sponge
• Whole bird rinse
• Product

• E. coli
• Sponge
• Excision
• Whole bird rinse

6
Comparison/Contrast

• Salmonella
• Carcass Sponge
• beef
• swine
• turkey

• E. coli
• Carcass Sponge
• beef
• swine
• turkey

7
Comparison/Contrast

• Salmonella
• Excision
• none

• E. coli
• Excision
• beef
• swine

8
Comparison/Contrast

• Salmonella
• Whole bird rinse
• chicken

• E. coli
• Whole bird rinse
• chicken
• turkey

9
Comparison/Contrast

• Salmonella
• Raw Product
• ground beef,
• ground pork
• ground chicken
• ground turkey

• E. coli
• Raw Product
• none

10
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

11
Comparison/Contrast

• Salmonella
• Performance Standards
• steers/heifers
• cows/bulls
• ground beef
• hogs
• broilers
• ground chicken
• ground turkey

• E. coli
• Performance Criteria
• cattle
• swine
• chickens

12
Comparison/Contrast

• Salmonella
• Performance Standards
• expressed as a positive or negative

• E. coli
• Performance Criteria
• expressed as cfu/cm2 or as cfu/ml

13
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

14
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

15
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

16
E. coli

• Basic requirements
• Written collection procedure
• Collect samples from species slaughtered in
  greatest numbers
• Record results on a process control chart or table

17
E. coli

• Written procedures identify
• sample collector
• sampling locations
• sampling randomness
• sample integrity

18
E. coli

• Collect from predominant species only if that
  species is covered by the regulations
• Beef
• Swine
• Chicken
• Turkey

19
E. coli
20
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

21
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

22
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

23
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

24
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

25
Salmonella

• Implementation
• Pre-implementation Phase
• take 250 samples per plant in a one-year period
• should be completed prior to implementation
• no enforcement actions

26
Salmonella

• Implementation
• Compliance Phase
• begins on same date as HACCP starts in plants
• enforcement of standards in effect

27
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

28
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

29
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)

30
Salmonella

• The District Office will notify the
• IIC
• Establishment (even if OPHS sent an e-mail
  message)

31
Salmonella

• Negative Results
• All parties are notified
• Sampling continues at normal frequencies for new
  sample sets

32
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)

33
Salmonella

• Positive Results
• DO will instruct the IIC in the frequency for
  sampling further sample sets

34
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

35
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

36
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

37
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

38
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

39
Sampling

• Large Plants
• May have both compliance and baseline samples to
  take
• Take both if possible
• If not possible, compliance samples take
  precedence

40
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