Environmental and Finished Dairy Product Sampling Monitoring for Listeria monocytogenes

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1.1 Objective of Activity

To monitor the effectiveness of the controls in registered dairy establishments in preventing contamination of product with Listeria monocytogenes through environmental sampling of food contact surfaces (FCS) and finished product testing.

1.2 Scope

This activity is conducted as a monitoring activity by Canadian Food Inspection Agency (CFIA) inspectors at traditionally inspected or HACCP recognized registered cheese establishments, as well as a directed activity in establishments to investigate or verify suspected problems

1.3 Background

Environmental sampling is an important verification tool for assessing trends as well as the source, and dispersion of any microbiological contamination in food establishments. One microbial pathogen of concern in the food industry is Listeria monocytogenes (Lm). Listeria spp. is widely distributed in nature and hence, could be present in dairy processing environments and lead to a serious concern for the dairy industry. Presence of Lm in dairy products has resulted in outbreak situations, product recalls, destruction of contaminated product, extensive sanitation procedures and major financial losses for dairy operators. Environmental sampling and testing for Lm in the processing environment can permit earlier identification of any potential persistent contamination and provide an increased ability to identify and protect against Lm contamination of the finished products.

Listeria monocytogenes is a gram-positive, non-sporeforming facultative anaerobic rod bacteria which grows between -0.4 and 50°C. This microorganism has been isolated from plant, soil, and surface water samples, and has also been found in silage, sewage, milk of normal and mastitic cows, and human and animal feces. Listeriosis can manifest itself in two different forms, namely, invasive and non-invasive. Invasive listeriosis typically occurs in people with weakened immune systems (e.g. patients with AIDS, cancer patients, elderly, etc.), while non-invasive listeriosis can occur in anyone if large numbers of bacteria are consumed (e.g., >1000 cfu/g). The Center for Disease Control and Prevention reported that listeriosis had the second highest case fatality rate (20%) and the highest hospitalization rate (92.2%) of all infections caused by foodborne pathogens. This elevated degree of severity highlights the importance of minimizing exposure, particularly among populations at higher risk.

Although Lm is eliminated by pasteurization, post-processing contamination of dairy products is possible so control of Lm in processing plant environments is essential. Environmental testing provides an opportunity to identify problems before they lead to finished product contamination, potential health risk to consumers or product recalls.

The 2008 Canadian listeriosis outbreak linked to RTE meat products and the subsequent Investigator's Report resulted in the recommendation that Health Canada (HC) revise its 2004 "Policy on Listeria monocytogenes (Lm) in Ready to Eat (RTE) food" to update and clarify its position with respect to all high risk RTE foods. In summary, the 2011 HC policy recommends revised practices that are aimed at reducing the risk of Lm contamination in establishments as well as in products. The Listeria policy has categorized RTE foods into two categories based upon health risk. Category 1 RTE foods are those foods which can support the growth of Lm (Lm is assumed to grow in RTE foods with a pH greater than or equal to 4.4 and with a water activity (aw) greater or equal to 0.92). Category 2 contains two subgroups: 2A) RTE food products in which limited growth of Lm to levels not greater than 100 cfu/g can occur throughout the stated shelf-life and 2B) RTE food products in which the growth of Lm cannot occur throughout the stated shelf-life (foods with a pH of less than 4.4, regardless of the aw, nor in foods with aw of less than 0.92, regardless of the pH, combinations of pH and aw (e.g., pH < 5 and aw < 0.94 and frozen foods).

1.4 Required References and Equipment

References

Equipment

  • Sanitizer – Food Grade Chemical (e.g.70% Ethanol)
  • Environmental swab kits
    • 10 sterile cellulose sponges pre-moistened with 10 ml of neutralizing buffer
    • 10 sterile (Twirl-ties) sample bags
    • 12 sterile large nitrile gloves
    • 1 Styrofoam shipping box
    • 2 gel freezer paks (hard case)

1.5 Sampling

There are various activities for Lm monitoring/verification in federally registered dairy establishments:

  1. Monitoring environmental sampling program (sampling plan D222). Its purpose is to monitor industry's effectiveness of sanitation and GMP in preventing contamination of cheese processing environments. Five to ten swabs are taken and composited for analysis.
  2. Domestic Cheese monitoring sampling plans (D207 & D221):
    • D207 - tests cheese for Listeria monocytogenes, E. coli count, S. aureus count, and Salmonella spp. as well as E. coli O157:H7 for products made from non-pasteurised milk.
    • D221 - performed at the same time as environmental sampling plan D222. Tests for Lm in cheese produced on the same packaging line where food contact surface sampling was done under plan D222.
  3. Directed environmental sampling program (sampling plan D212D). This biased environmental monitoring is performed to investigate or verify any suspected problems (i.e. poor GMP or new registrations) in dairy establishments. Lab analysis will include both Listeria monocytogenes and Salmonella spp.
  4. Other dairy products are sampled for Lm and various pathogens under specific sampling plans. Sampling plans that include Lm analysis: Domestic milk powders (D205), Imported dairy (D210), Fermented dairy (D217), Domestic butter (D218), Domestic fluid milk (D219) and Domestic acid & rennet coagulated dairy products (D220).

1.6 Inspection Procedures for Environmental Sampling

1.6.1 Preparation for Environmental Sampling

The environmental sampling frequency is stated in the microbiological sampling guidelines under sampling plan D222 (Environmental sampling for cheese processing establishments).

Prior to conducting an environmental inspection, provide the establishment with at least 24 hours notice to ensure that a packaging line is in operation and that the establishment can make arrangements for breaks during production for swabbing. This will also enable industry to schedule any changes in product distribution plans (e.g. voluntarily holding the product affected by the sampling). Inspectors should verify that the best before date stated on the environmental kits has not been exceeded. Expired kits should not be used. It is also important to place gel packs from the kit into the freezer at least 24 hours before the sampling is going to be conducted.

1.6.2 Selection of Food Contact Surface Sample Sites

Food contact surfaces (FCS) are anywhere an exposed surface or object has direct contact with the unpackaged RTE product. For environmental sampling, select sites in the final packaging area which are exposed to both the environment and the product or where there is a higher probability of RTE product contamination and the greatest potential to affect the safety of the final product. Suggested food contact surface sites in the final packaging area are:

  • Slicers, dicers, shredders, etc.
  • Carts/racks
  • Cheese molds
  • Blades of slicers
  • Packaging tables, conveyor belts
  • Scales
  • Cutting tables
  • Utensils (knives, trays)
  • Packaging equipment (vacuum packaging, etc.), packaging material
  • Employee gloves/hands, aprons. Note that it is recommended to randomly swab at least two employees if these sites are selected.

Select one (1) specific packaging line. Give priority to the packaging line most at risk, i.e. those packaging the highest risk cheeses in category 1, and to shredding, slicing and dicing operations where the risk of post-processing contamination is higher. Ideally 10 FCS sites should be selected (minimum of 5 FCS) in the packaging area. The number of sampling sites will vary according to the complexity of processing system or packaging line. Prior to starting sampling, survey the packaging line to determine sites to be sampled, and document them on the LSTS submission form. A 900 cm2 (30 x 30 cm or equivalent) surface should be swabbed whenever possible. Surfaces are to be swabbed after the start of the operations (i.e. 2-3 hrs into processing is recommended).

In cheese processing establishments the highest risk cheeses would include:

  • Soft mold ripened cheese lines (e.g. Brie, Camembert, Blue, Gorgonzola);
  • Soft and semi soft fresh cheeses (e.g. Feta, Havarti, Queso Fresco, Queso Blanco);
  • Paneer, Ricotta, Mozzarella;
  • Washed rind cheeses (e.g. St. Paulin, Oka, Tomme).

1.6.3 Environmental Sampling Techniques

Aseptic sampling must be used for all samples taken for microbiological purposes. It is a technique which uses sterile containers and equipment to prevent the introduction of any contamination from outside sources into either the product or sample taken.

When samples are taken under these conditions, it is assumed that the results of the analysis indicate the actual conditions under which the product was manufactured or handled. Cross-contamination caused by the person taking samples is avoided, if proper procedures are followed. If Lm is found in the sample, then it can be indicative that it was introduced during the manufacturing process and not by the sampler.

Environmental sampling kits are supplied by the operational centre. Ten pre-moistened swabs for sampling food contact surfaces are provided with each kit. Upon receipt of the kits and before taking samples, review the instructions on sanitary sampling techniques and the content list supplied with the kits. Report any problems with the sampling kits immediately to the Area Program Specialist. Avoid contaminating the materials from the sampling kit, the samples, the equipment or the product being sampled. If resources permit, it is recommended that the swabbing process be completed by two inspectors.

Use the following sampling techniques when taking the swabs:

  1. Label the Twirl-ties sample bags and record information about the sampling sites. Use a waterproof soft felt pen for labelling all bags and ensure that while writing you do not puncture the plastic bag.
  2. Thoroughly wash and dry hands.
  3. Open the package containing the pre-moistened sterile swab, put on sterile gloves and take sterile swab out.
  4. Rub the swab firmly and thoroughly over the surface to be sampled, without lifting the swab, swab the surface area up and down until the whole target surface is covered (see Figure A), then turnover the swab and swab the surface area from right to left until the whole target surface is covered (see Figure B)
    This image displays the swabbing using an up and down motion
    Figure A: Up and down motion
    This image displays the swabbing using a right to left motion
    Figure B: Right to left motion

    Note that for surfaces which are difficult to swab because of their contour (i.e. conveyor belts), it may not be possible to swab a defined area using the mentioned procedure. In this case, swab the area to be sampled using the same described technique (Up and down/ left to right) and then turn over the swab once again and swab the surface area in a diagonal pattern. This allows the sampling of every plane of the surface that will likely come into contact with the food (see Figure C)

    This image displays the swabbing using an up and down/right to left and diagonal motions
    Figure C: Swabbing of irregular surfaces - Up and down/right to left and diagonal motions.
  5. Release the swab into the appropriately labelled Whirlpak® sample bag. Do not let the swab touch the outside of the bag.
  6. Seal the bag, making sure not to contaminate the sample.
  7. Place the bag in the Styrofoam box.
  8. Sanitize the sample site using a 70% ethanol spray solution following environmental swabbing (note that some establishments might want to perform their own FCS sanitation after CFIA swabbing)
  9. Change gloves for the next sampling site and complete swabbing all selected sites.
  10. Once all samples have been taken, place the freezer pak at the bottom of the Styrofoam box. Use newsprint or similar material to prevent direct contact between the pak and the samples.
  11. Place the sample in the middle and use fillers to prevent shifting of the samples during shipping. Add another freezer pak on top.
  12. Include a complete LSTS submission form inside an empty Whirlpak® bag. Seal and label the box.
  13. Send to the laboratory indicated in the sampling guidelines within 1 working day.

Note that sampling under this plan is linked to sampling under D221, Listeria monocytogenes in cheese. When taking a sample under D222 take a finished and packaged cheese sample (consisting of 5 sub samples-at least 200 g) from the selected packaging line and if possible, around the same time the line was swabbed under D222. It is recommended that industry hold all finished product lots produced on the sampled packaging line between full sanitation cycles. A full sanitation cycle means cleaned and sanitized (i.e. clean-up to clean-up). Any distributed products produced between these sanitation cycles are subject to a recall if finished product results are unsatisfactory.

1.7 Follow-up for Unsatisfactory FCS Results

An unsatisfactory result for Listeria monocytogenes under D222 (Lm environmental in cheese plants) indicates that the establishment is not operating according to Good Manufacturing Practices (GMP's).

Initiate the follow-up procedure explained below any time a CFIA FCS sample result is unsatisfactory for Lm.

  1. Inform the operator of the unsatisfactory test result as soon as possible, either in person or electronically.
  2. Open an IMS file and include all pertinent information and references, (e.g. establishment information, LSTS report, FCS sites tested, results of CFIA inspections (if applicable), company's corrective action plan, findings from establishment's root cause analysis, follow up, etc.).
  3. Review the test result of the product that was sampled simultaneously under plan D221 (Lm in cheese) from the same production lot and line that revealed unsatisfactory FCS results. If the result for finished product is unsatisfactory for Lm, follow procedures specified under Section 1.8 "Follow-up on Unsatisfactory Finished Product Results". If the finished product is satisfactory for Lm, communicate this result to the manufacturer. The Area Program Specialist is to be consulted and all available data for this case will be assessed to determine recommended actions on all possible affected product. A Health Risk Assessment or formal opinion may be requested depending of the level of concern for the specific situation.
  4. The plant must complete a written action plan and forward it to the CFIA office within 5 working days. This action plan must indicate all the corrective measures they will implement to eliminate Lm in the RTE environment. At a minimum the corrective actions must include:
    • Assessment and possible testing of all production lots produced between the date of the unsatisfactory finding and the date of intensive cleaning.
    • Implementation of intensiveFootnote 1cleaning/sanitation actions;
    • Revision of appropriate sections of the plant's process controls (including GMP's, sanitation procedures, etc.);
    • Verification of environmental conditions as soon as possible following CFIA notification. This needs to include sampling during production and individual testing of FCS, by an accredited lab for three consecutive production runs to ensure that these surfaces are free of Listeria spp.(or Lm) (see Appendix 1). It is recommended that each lot of product should be held and tested for Lm until the results demonstrate that control has been achieved.
    • (The operator should sample the same FCS sites which triggered the unsatisfactory result when performing the first FCS follow-up swabbing. For the second and third FCS follow-up swabbing, there are no specific requirements for sampling sites (as long the operator is targeting the same implicated line).
  5. Review the action plan for acceptability and sign-off in conjunction with the Regional Program Officer or Area Program Specialist. Notify the plant in writing immediately if the action plan is not acceptable or if it is not received on time.
  6. Verify that the establishment has implemented follow-up actions by reviewing records during a follow-up visit. FCS environmental samples can be taken for verification purposes if deemed necessary.
  7. Schedule another FCS environmental sampling (using sampling plan D222D) and finished product sampling on the same packaging line (using sampling plan D221D), within a three month period. It is recommended to swab the same FCS sites which triggered the initial follow-up procedure.
  8. Close the IMS when this follow-up is performed and assessed as satisfactory.

1.8 Follow-up on Unsatisfactory Finished Product (CFIA's or Industry's)

Initiate the follow-up procedure explained below when an unsatisfactory finished product result for Lm is reported to CFIA as part of an establishment's Lm verification procedures or through CFIA's own testing (see Appendix 2)

  1. Create an IMS file to track all activities related to the finding.
  2. Notify industry immediately of the unsatisfactory result. Detain the implicated production lot(s) as per the policies prescribed by the Dairy program.
  3. Determine if the product has been distributed. If the implicated product is in distribution, contact the Area Food Recall Coordinator and the Area Program Specialist to gather information for a food safety recall.
  4. Assess all lots produced since the unsatisfactory finding together with plant's information to determine any need for more sampling.
  5. The operator must take immediate corrective actions and submit an action plan to CFIA within 5 days. This action plan must indicate all the corrective measures which will be implemented to address the root cause and prevent product contamination by Listeria monocytogenes. As a minimum requirement the following points should be covered in the planFootnote 2:
    • Action that will be taken on the unsatisfactory product (recovery, hold and disposition of the product)
    • Verification that no other product is affected by the unsatisfactory result (e.g. all lots produced since date of unsatisfactory finding)
    • Implementation of an intensiveFootnote 3 sanitation and cleaning plan
    • Appropriate corrective action (e.g. review of sanitation program, HACCP/written plan, etc.)
    • Investigative FCS sampling to identify source(s) of contamination (samples should be analyzed individually).
    • Implementation of a product hold-and-test procedure:
      • Finished product (5 sub-samples per lot) from the same implicated production line analysed by an accredited lab until 10 consecutive lots are satisfactory for Lm (2 out of 10 samples are sampled and analysed by CFIA).
      • If a sample test is unsatisfactory during the above hold and test, the cycle starts again from the beginning. The operator must reassess their corrective action plan which should be reviewed with the Regional Program Officer or Area Program Specialist. Repetitive Lm findings may increase frequency of in-depth inspections, GMP's, sampling, etc.
  6. It is important to review the plant's information, as applicable, and pay attention to locations where water/humidity favour microbial growth (e.g. stagnant water, condensation, drains):
    • Complaint files, GMP reports
    • Pasteurization records, deviations
    • Equipment design
    • Equipment maintenance records including calibration records
    • Process control records e.g. aw, pH, preservatives, microbiological testing records, slow fermentations
    • Quality and handling of incoming materials including water, brine, and ripening cultures (washed rind cheeses)
    • Packaging materials (integrity)
    • Sanitation frequency vs. production cycles
    • Pest control records
    • Observation of employee hygienic practices
    • Steps in process flow susceptible to contamination and/or growth (e.g. product returns, production down time)
    • Ripening and smearing cheese practices
    • Post process handling, storage, distribution of finished product (time and temperature)
    • Segregation of raw and finished areas (product and employee flow)
    • Sanitary cutting practices, separation of retail sale counters (e.g. with foot baths)
    • Ventilation (air supply), positive pressure in areas of manufacture
    • Lot determination/definition
  7. Review and sign the action plan if acceptable and keep on file. Notify operator immediately in writing if not acceptable or not received on time.
  8. Verify that corrective actions taken by the operator are implemented during a follow-up visit.
  9. Update and track all results in IMS.
  10. After all 10 consecutives lots are found satisfactory for Lm, schedule another finished product sampling and FCS within a three month period.
  11. Close the IMS when this follow-up is performed and assessed as satisfactory.

1.9 Directed Environmental Sampling

This biased environmental sampling is performed to investigate or verify any suspected problems (i.e. poor GMP or new registrations) in any dairy establishment. Lab analysis will include both Listeria monocytogenes and Salmonella spp. A maximum of ten (10) samples are to be taken (can include FCS and non-FCS sites). Since these are considered surveillance samples, they will be analyzed individually.

1.9.1 Preparation for Environmental Sampling and Selection of FCS and Non-FCS

It is the inspector's discretion to select the sample sites according to the type of establishment and conditions/concerns observed during the visit. As general guidance, it is recommended to select 5 FCS and 5 non-FCS to get a better understanding of the effectiveness of the establishment's control programs. Due to the small number of samples taken in a plant, it is imperative that sampling sites be selected that will generate the most information possible such as sites that may favour microbial growth (water, nutrient and incubation time) and  any area of the establishment or equipment that contains uncontrolled water (roof leaks, standing water or condensate). It is not recommended to swab drains unless they are in close proximity to unprotected product.

It is critical that the inspector avoids contaminating the sampling kit supplies, the samples, the equipment and the product being sampled by following the sampling technique described in section 1.6.3.

1.9.2 Follow-up for Unsatisfactory FCS and Non-FCS Results

An unsatisfactory result for under D212D indicates that the establishment is not operating according to Good Manufacturing Practices (GMP's).

If the unsatisfactory result is linked to a FCS site, initiate the follow-up procedure explained in section 1.7 "Follow-up for unsatisfactory FCS results" (with the exception of steps #3 and #7 which are specific to the environmental monitoring plan D221).

If the unsatisfactory result is linked to a non-FCS site, initiate the follow-up procedure explained below :

  1. Inform the operator of the unsatisfactory test result as soon as possible, either in person or electronically.
  2. Open an IMS file and include all pertinent information and references, (e.g. establishment information, LSTS report, non-FCS sites tested, results of CFIA inspections (if applicable), company's corrective action plan, findings from establishment's root cause analysis, follow up, etc.).
  3. The plant must complete a written action plan and forward it to the CFIA office within 5 working days. This action plan must indicate all the corrective measures they will implement to control Lm in the environment. At a minimum, the corrective actions must include:
    • Implementation of intensive cleaning/sanitation actions;
    • Revision of appropriate sections of the plant's process controls (including GMP's, sanitation procedures, etc.);
    • Verification of environmental conditions including the testing of the non-FCS originally tested and the inclusion of FCS to ensure that these surfaces are free of pathogens (see Appendix 3).
  4. Review the action plan in conjunction with the Regional Program Officer or Area Program Specialist. Notify the plant in writing immediately if the action plan is not acceptable or if it is not received on time.
  5. Verify that the establishment has implemented follow-up actions by reviewing records during a follow-up visit. FCS environmental samples can be taken for verification purposes if deemed necessary.

Appendix 1 Follow-up Procedure to a CFIA Unsatisfactory Result for Lm on FCS

Click on image for larger view
Flowchart - Follow-up procedures to a unsatisfactory result for Listeria monocytogenes on Food Contact Surfaces

Flowchart - Follow-up procedures to a unsatisfactory result for Listeria monocytogenes on Food Contact Surfaces

The food contact surface is sampled (Operator should hold product of sampling day until results are received)

If the results are satisfactory for Listeria monocytogenes, the normal sampling schedule for FCS is followed.

If the results are unsatisfactory for Listeria monocytogenes, then the CFIA's actvities are:

  • Inform operator as soon as possible
  • Open IMS file and record all activities related to the finding
  • Review finished product testing (taken simultaneously with FCS): If productFootnote 4 is found unsatisfactory for Listeria monocytogenes take actions according to Appendix 2.
  • If product is satisfactory for Listeria monocytogenes, communicate this result to the manufacturer. The area program specialist is to be consulted and all available data for this case will be assessed to determine recommended actions on all possible affected product.
  • Request an action plan (it should be received within 5 working days) and assess appropriateness
  • Notify the plant in writing immediately if the action plan is not acceptable or if it is not received on time
  • Sign the action plan if it is acceptable and keep it on file

And the operator's activities are:

  • Determine appropriate action if the finished product is satisfactory for Listeria monocytogenes.
  • Submit an action plan
  • Initiate corrective actions as per action plan (intensive sanitation and cleaning, review processing conditions, etc.)
  • Retest FCS as soon as possible within a maximum of 5 working days, at same sites as the previous test (analyze FCS individually). Continue FCS testing until 3 consecutive satisfactory resultsFootnote 5 for Listeria spp. (or Listeria monocytogenes). It is recommended that each lot of product be held and tested for Listeria monocytogenes.
  • Hold product until results are known.
  • Notify CFIA of all results

Once the activities listed above are completed:

  • Inspector verifies industry's follow up actions by reviewing recordsFootnote 6
  • Schedule another FCS and finished product sampling within 3 month period
  • Complete the IMS file

Appendix 2 Follow-up Procedure to an Operator's and CFIA's Unsatisfactory Lm Finished Product Result

Click on image for larger view
Flowchart - Follow-up Procedures to an Unsatisfactory Listeria monocytogenes Finished Product Result

Flowchart - Follow-up Procedures to an Unsatisfactory Listeria monocytogenes Finished Product Result

The finished product is tested for Listeria monocytogenes (CFIA's or Industry's monitoring controls for Listeria)

If the results are satisfactory for Listeria monocytogenes, release the product and normal sampling schedule for FCS and/or finished product testing is followed.

If the results are unsatisfactory for Listeria monocytogenes, then the CFIA's actvities are:

  • Create an IMS file and record all activities related to the finding
  • Notify industry of the unsatisfactory result
  • Assess if the product has been distributed. Contact area food recall coordinator if product was distributed
  • Assess all lots produced since the unsatisfactory finding together with plant's information to determine any need for more sampling
  • Request an action plan (received within 5 working days) and assess appropriateness
  • Notify the plant in writing immediately if the action plan is not acceptable or if it is not received on time
  • Sign the action plan if acceptable and keep on file

And the operator's activities are:

  • Notify the CFIA of any finished product unsatisfactory finding
  • Identify and ensure that all product(s) linked with the unsatisfactory result is under control
  • Submit an action plan
  • Initiate corrective actions as per action plan
    • Hold and test implemented (10 consecutives lots tested, 8 by operator and 2 by CFIA)
    • If a sample test is unsatisfactory during the hold and test, the cycle starts again.
  • Notify CFIA all finished product results.

Once the activities listed above are completed:

  • Verify industry's follow up actions by reviewing records
  • Update and track all results in IMS
  • Schedule another finished product sampling and FCS within a three month period, after all 10 consecutives lots are found satisfactory for Listeria monocytogenes
  • Complete the IMS file.

Appendix 3 Follow-up Procedure to a CFIA Unsatisfactory Result for Pathogens (Listeria monocytogenes and/or Salmonella spp.) on Non-FCS under sampling plan D212D

Click on image for larger view
Flowchart - Follow-up Procedure to a Unsatisfactory Result for Pathogens (Listeria monocytogenes and/or Salmonella spp.) on Non-food contact surfaces under sampling plan D212D

Flowchart - Follow-up Procedure to a Unsatisfactory Result for Pathogens (Listeria monocytogenes and/or Salmonella spp.) on Non-food contact surfaces under sampling plan D212D

The non-food contact surfaces is sampled (CFIA's directed environmental program)

If the results are satisfactory, inform the operator of satisfactory result.

If the results are unsatisfactory, then the CFIA's actvities are:

  • Inform operator as soon as possible
  • Open IMS file and record all activities related to the finding
  • Request an action plan (it should be received within 5 working days) and assess appropriateness
  • Notify the plant in writing immediately if the action plan is not acceptable or if it is not received on time
  • Sign the action plan if it is acceptable and keep it on file

And the operator's activities are:

  • Initiate corrective actions as per action plan (intensive sanitation and cleaning, review processing conditions, etc.)
  • Verify environmental conditions by re-testing the non-FCS originally tested (analyze them individually) and include testing of FCS to ensure that these surfaces are free of pathogens.
  • Notify CFIA of all results

Once the activities listed above are completed:

  • Inspector verify industry's follow up actions by reviewing records
  • Complete the IMS file
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