Guidance for the Application of Health Canada's Policy on Listeria monocytogenes in Ready-to-Eat Foods
6.0 Strategies

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The inspection activities presented in this document are based on the program's legal authorities, policies, guidelines, and product risk. They include both proactive and reactive activities. Specific activities may differ for each program.

A general summary of these activities is found in the tables of this section and in Appendix A. As well, Figure A outlines the activities which should be conducted when Lm is detected in the finished product and/or when environmental sampling results demonstrate the presence of Lm.

6.1 Proactive Activities

Proactive activities can include industry communication, environmental sampling (monitoring), product sampling and assessment of industry's controls. Refer to specific program references for further information.

6.1.1 Industry Communication

Communication can occur with industry by various means on issues related to the Policy and its implementation. For example, communication can occur through website postings, letters, meetings, information sessions, symposia, and direct dialogue during routine inspection activities and correspondence.

6.1.2 Environmental Sampling

As part of their regular microbiological monitoring program, the Dairy and Processed Egg programs will use the environmental sampling plans outlined in the following table. The purpose of these plans is to monitor the effectiveness of a plant's sanitation and GMPs in preventing contamination of processing environments.

Program Description
Dairy Lm environmental monitoring program for cheese establishments. Swabs taken of FCS during production.
Egg Environmental monitoring of FCS and Non-FCS will continue; the plan now includes Lm testing. There is no additional work for Operations.

6.1.3 Product Sampling

As part of regular microbiological monitoring programs, products samples are planned under the following sampling plans:

Program Product Description
Dairy Domestic Cheese To monitor dairy products for Lm and other pathogens
Dairy Imported dairy To monitor dairy products for Lm and other pathogens
Dairy Domestic fluid milk To monitor dairy products for Lm and other pathogens
Dairy Domestic acid & rennet coagulated dairy products To monitor dairy products for Lm and other pathogens
Dairy Special plan for domestic cheese To monitor the safety of the cheese produced on the same packaging lines where FCS swabs are taken under environmental plan.
Egg Domestic processed egg Domestic product monitoring for all regulatory microbiological standards (already includes testing for Lm)
Egg Imported processed egg Import product monitoring for all regulatory microbiological standards (already includes testing for Lm)
Fresh Fruit & Vegetables Domestic RTE Fresh-cut fruit & vegetables To monitor RTE Fresh-cut fruit & vegetables for pathogens, including Lm.
Fresh Fruit & Vegetables Imported RTE Fresh-cut fruit & vegetables To monitor RTE Fresh-cut fruit & vegetables for pathogens, including Lm.
IMFP RTE Fermented Meat Directed sampling to support inspection findings
Samples will be taken at the discretion of the inspector to verify inspection observation.
IMFP RTE Non-Fermented Meat Directed sampling to support inspection findings
Samples will be taken at the discretion of the inspector to verify inspection observation.
IMFP RTE Fish Directed sampling to support inspection findings
Samples will be taken at the discretion of the inspector to verify inspection observation.
IMFP RTE FFV Directed sampling to support inspection findings
Samples will be taken at the discretion of the inspector to verify inspection observation.
IMFP Soft & semi-soft cheese Directed sampling to support inspection findings
Samples will be taken at the discretion of the inspector to verify inspection observation.
Processed Products Domestic frozen fruit To monitor frozen fruit for Lm
Processed Products Imported frozen fruit To monitor frozen fruit for Lm
Processed Products Domestic frozen vegetables without cooking instructions To monitor frozen vegetables without cooking instructions for Lm
Processed Products Imported frozen vegetables without cooking instructions To monitor frozen vegetables without cooking instructions for Lm
Processed Products Domestic refrigerated pickled products To monitor refrigerated sauerkraut, refrigerated pickles, and refrigerated olives for Lm
Processed Products Imported refrigerated pickled products To monitor refrigerated sauerkraut, refrigerated pickles, and refrigerated olives for Lm

6.1.4 Assessment of Industry's Controls

CFIA's inspection activities, including sampling activities, will assess industry's controls; however, Dairy and Egg have the following specific directions in their Inspection Manuals:

Dairy – The Dairy Program has enhanced its establishment and product inspection activities for domestic and import in order to reflect the HC Lm Policy. Additional requirements for registered establishments are described in the Dairy Establishment Inspection Manual tasks 1.10.07.01 and 1.10.07.03 in Chapter 10 and 1.13 in Chapter 9. Additional tasks have also been added for dairy importers (Dairy Product Inspection Manual, Chapter 16.6.3.1).

Egg – As part of the Processed Egg Inspection Program Activities, a Registration file review is conducted periodically, which includes a review of the stations pre-requisite programs such as the Quality Assurance program. If a deviation is noted, it is recorded on the "Processed Egg Station - Sanitation and Inspection Report (CFIA/ACIA 1082)". Depending on the severity of the deviation or non-compliance, the processed egg station is to come up with an action plan.

6.2 Reactive Activities

Reactive activities can include Industry communication, environmental sampling, product sampling and assessment of industry's controls. These activities may occur when Lm is detected in the finished product and/or when environmental sampling results demonstrate the presence of Lm. Figure A outlines the activities which should be conducted when Lm is detected in the finished product and/or when environmental sampling results demonstrate the presence of Lm. Program specialists should be consulted for further guidance.

6.2.1 Environmental Sampling

The purpose of the directed sampling plans is to follow up on previous unsatisfactory results, GMP concerns or other triggers.

Program Description
Dairy Taken from establishments exhibiting poor control over their sanitation program, with a poor compliance history or undergoing renovations.
Dairy Used as a follow-up sample when a monitoring sample is unsatisfactory.
Egg Used as a follow-up sample when a monitoring sample is unsatisfactory.
Fresh Fruit & Vegetables Food Contact Surface (FSC) samples will be collected on a case by case basis only.
IMFP On a case by case basis. These samples are collected on special request e.g. complaints/investigations.
Processed Products On a case by case basis. These samples are collected on special request e.g. complaints/investigations.

6.2.2 Product Sampling

The following sampling plans should be used for follow up to positive Lm results from monitoring sampling, complaints, illnesses, recalls etc.

Program Product Description
Dairy Domestic frozen dairy products Used for directed samples taken as follow-up to unsatisfactory monitoring samples when the inspector detects possible non-compliance.
Dairy Domestic milk powders Directed samples are taken under these plans when the inspector detects possible non-compliance.
Dairy Domestic cheese Used for directed samples taken as follow-up to unsatisfactory monitoring samples.
Dairy Imported dairy Used for directed samples taken as follow-up to unsatisfactory monitoring samples.
Dairy Domestic fermented dairy Directed samples are taken under these plans when the inspector detects possible non-compliance.
Dairy Domestic Butter Directed samples are taken under these plans when inspection detects possible non-compliance.
Dairy Domestic fluid milk Used for directed samples taken as follow-up to unsatisfactory monitoring samples.
Dairy Domestic acid & rennet coagulated dairy products Used for directed samples taken as follow-up to unsatisfactory monitoring samples.
Dairy Special plan for domestic cheese Used for directed samples taken as follow-up to unsatisfactory monitoring samples.
Dairy Domestic dairy Products Special requests for consumer/ trade complaints, illnesses, recalls etc.
Dairy Imported dairy products Special requests for consumer/ trade complaints, illnesses, recalls etc.
Egg Domestic Processed Egg Directed samples stemming from unsatisfactory monitoring samples.
Egg Imported Processed Egg Directed samples stemming from unsatisfactory monitoring samples.
Egg Special Requests Special requests such as consumer/ trade complaints, illnesses, recalls.
Fresh Fruit & Vegetables Domestic RTE Fresh-cut fruit & vegetables Directed samples stemming from monitoring sampling.
Fresh Fruit & Vegetables Imported RTE Fresh-cut fruit & vegetables Directed samples stemming from monitoring sampling.
Fresh Fruit & Vegetables Domestic Fruit & vegetables Special requests of microbiological concerns such as consumer, trade complaints, illnesses, recalls.
Fresh Fruit & Vegetables Imported Fruit & vegetables Special requests of microbiological concerns such as consumer, trade complaints, illnesses, recalls.
IMFP Fermented Meat Follow-up samples taken in response to unsatisfactory/investigative results from pro-active sampling.
IMFP Non-Fermented Meat Follow-up samples taken in response to unsatisfactory/investigative results from pro-active sampling.
IMFP RTE Fish Follow-up samples taken in response to unsatisfactory/investigative results from pro-active sampling.
IMFP RTE FFV Follow-up samples taken in response to unsatisfactory/investigative results from pro-active sampling.
IMFP Soft & semi-soft cheese Follow-up samples taken in response to unsatisfactory/investigative results from pro-active sampling.
IMFP Domestic Manufacturer Compliance Follow-up samples taken in response to unsatisfactory/investigative results from pro-active sampling.
Processed Products Domestic frozen fruit When the result of a monitoring plan is unsatisfactory, follow-up samples may be submitted.
Processed Products Imported frozen fruit When the result of a monitoring plan is unsatisfactory, follow-up samples may be submitted.
Processed Products Domestic frozen vegetables without cooking instructions When the result of a monitoring plan is unsatisfactory, follow-up samples may be submitted.
Processed Products Imported frozen vegetables without cooking instructions When the result of a monitoring plan is unsatisfactory, follow-up samples may be submitted.
Processed Products Domestic refrigerated pickled products When the result of a monitoring plan is unsatisfactory, follow-up samples may be submitted.
Processed Products Imported refrigerated pickled products When the result of a monitoring plan is unsatisfactory, follow-up samples may be submitted.
Figure A. Follow-up procedure when Lm is detected in finished product / environment
Flowchart - Follow-up procedure when Lm is detected in finished product / environment. Description follows.
Description for Follow-up procedure

Figure A outlines the activities which should be conducted when Lm is detected in the finished product and/or when environmental sampling results demonstrate the presence of Lm. Figure A outlines the activities which should be conducted when Lm is detected in the finished product and/or when environmental sampling results demonstrate the presence of Lm. Program specialists should be consulted for further guidance.

1 Evidence of persistent findings of Listeria spp. on a FCS (2 or more successive positive results from the same production line, i.e. Using the same equipment) in a short time frame should also be communicated to the CFIA.

2 Some CFIA programs may implement environmental monitoring programs.

3 As per the guidelines in Figure 1 (Step B) and Figure 2 (Step C) of the Policy.

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