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Listeria Management Plan John Holah 2018 v2
Listeria Management Plan John Holah 2018 v2
Management Plans (LMP)
John Holah, Holchem Laboratories Ltd, Lancashire, United Kingdom
Introduction
The latest available food poisoning statistics for Europe (EFSA 2017) show that there were 247
recorded deaths from Listeria monocytogenes in 2016, more than the deaths from all other food
poisoning organisms combined. For many food manufacturers, particularly those producing ready‐
to‐eat products (RTE), L. monocytogenes is thus one of the major hazards to the businesses/brand
that must be controlled.
The control of Listeria in food manufacturing is multi‐faceted and has been controlled historically by
product development, product decontamination and effective cleaning practices. Whilst the overall
incidence of Listeria is low, in the order of a few thousand cases per year in Europe, its incidence in
Europe is increasing, probably due to the expansion of the section of the population above 60 years
of age, the major illness related factor (EFSA 2018). Note, there were 2536 recoded cases in 2016
(EFSA 2017), though this is certainly a small underestimate of the actual total cases.
It can be argued, therefore, that our traditional control methods are not sufficiently robust and that
a new approach to Listeria management is required. HACCP in particular, is not effective in
controlling this organism as the majority of Listeria cases are caused by an excessive load of Listeria
prior to any decontamination process (e.g. in recent cantaloupe cases – CDC 2011, Food Standards
Australia 2018) or cross‐contamination post decontamination process (e.g. the current case in South
Africa associated with cooked meats – NCID 2018). The control of the product decontamination
processes themselves, usually HACCP CCPs, is however, generally excellent with very few published
examples of failures in these systems. As such, Listeria is primarily controlled by HACCP prerequisite
programmes and a better system for risk assessing and managing prerequisites in the food
processing environment is urgently required. One such processing environmental plan (PEP), in
which the potential sources and vectors of Listeria contamination are risk assessed, has been
advocated (Holah et al 2012, Holah 2013). In this plan, the control of sources or vectors of Listeria
contamination that are deemed critical to food safety can be raised to the level of Operational
Prerequisites, which can be then managed in the same way as CCPs (CCPs manage the product and
process, OPs manage the processing environment). This concept has been recognised in US
legislation under the Food Safety Modernisation Act, in which controls critical to managing food
safety are known as ‘Preventative Controls’. Preventative controls can include HACCP CCPs, but also
e.g. sanitation, allergen and supply chain controls (FDA 2018).
A suggested Listeria Management Plan (LMP), which incorporates this new philosophy of managing
food safety based on risk assessment of the food manufacturing process and food manufacturing
environment, has 6 key elements and is shown schematically in Figure 1. Each of these key elements
then contains a series of policies/procedures/plans to support the elements objectives. The LMP
should form part of the food manufacturers overall food safety plan, which will incorporate e.g.
HACCP, TACCP, VACCP, PEP, traceability and product recall studies and a Crisis Management Plan.
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Figure 1 ‐ Schematic Listeria Management Plan
1. Listeria Management Plan
The first key element is the physical plan itself, including its scope, content, documentation,
management and records. To ensure that the LMP is effectively designed and implemented within
the business, it is essential that all staff have training in Listeria, as an organism and as a risk to
consumers, at a level appropriate to their responsibility in the organisation. The LMP recognises
that there are two major components of the plan; a risk assessment of the food product and its
process (key element 2) and the food processing environment (key element 3). These two risk
assessments will lead to a number of controls that are required to manage the Listeria risk and these
will be documented in key element 4, which includes details of how the controls will be validated,
monitored and verified. An essential verification measure will be the analysis of product and
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environmental samples for L. monocytogenes and this is documented in key element 5. Key element
5 also documents how the results of the microbiological sampling will be analysed and reported
internally and to customers. If all appropriate Listeria controls have been identified and are working
as intended, the presence of L. monocytogenes in the product and the processing environment
should be rare. If detected, however, its significance in terms of potential product recalls and plant
decontamination has to be immediately determined and its presence should be investigated to
identify its source and product vectors, and this is documented in key element 6. Lessons learnt
from such investigations should be fed back into the LMP to better manage elements 2 and 3.
From key elements 2‐6, the roles and responsibilities of senior management, management,
supervisory staff and operatives can be discerned and documented. The absolute key message of
the LMP is that Listeria can only be effectively managed by teamwork and senior management,
production, technical, engineering and hygiene functions are all equally responsible for its successful
implementation. Hopefully this will debunk the typical food industry management initial thought
that the presence of Listeria is due to poor cleaning! Element 1 finally contains details of the
necessary LMP meetings and reviews, together with all records, as required to implement the plan.
2. Product and process
The contents of key element 2 are well established and routinely undertaken by food manufacturers.
Product design challenges the formulation of a food product to minimise the presence of Listeria in
the raw materials and/or reduce the chance for any Listeria present in the product post the
decontamination process to survive and grow. Raw material risk assessment is undertaken to
choose ingredients and suppliers that minimises the risk of ingredient agricultural, and primary
processing contamination. The majority of RTE products will have received a decontamination
treatment by the product manufacturer, either as a pasteurisation (6log reduction) or a washing (1‐
2log reduction) process. The design and management of these decontamination processes is critical.
Following decontamination, some RTE products will be designed to prevent Listeria growth (by the
addition of preservatives) or eliminate the organisms in packed product via secondary, in pack
pasteurisation treatments (e.g. high‐pressure processing). For RTE products not preserved or in‐
pack treated, Listeria is likely to be controlled by a chilled distribution and retail chain with defined
times and temperatures, within a shelf‐life determined from practical or modelled trials that ensures
Listeria is unlikely to reach levels that are outside legislative values (EC 2073/2005). Listeria controls
in the product and process are determined by a hazard analysis critical control point (HACCP)
assessment, and it is likely that all decontaminating treatments will be identified as critical control
points (CCPs).
3. Processing environment
The concepts of key element 3 are relatively new and under development. They consist of a basic
Listeria 5‐point control plan and a risk assessment of both the best practice generic Listeria control
prerequisites in place (e.g. cleaning and disinfection) and any potential Listeria sources and vectors
as identified by the PEP plan. Some prerequisite, source or vector controls, following a risk
assessment, may be raised to the level of Operational Prerequisite Controls.
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Figure 2 ‐ Schematic Listeria 5‐Point Control Plan
The basic principles of the 5‐point Listeria control plan are shown in Figure 2, and comprise: ‐
Prevent day‐to‐day entry of Listeria into high hygiene food manufacturing areas using effective
barriers. This may include activities that are undertaken in low risk areas to reduce the challenge of
Listeria at such low/high hygiene barriers. Barriers should control the entry into/exit from the high
hygiene area of product, ingredients, packaging materials, manufacturing utensils and transport
systems, waste products, people, the air, cleaning chemicals and equipment, maintenance
equipment etc.
Ensure the high hygiene manufacturing infrastructure (building structure, equipment and utensils)
cannot harbour and/or allow the growth of Listeria. Harbourage is exacerbated by damage to
environmental surfaces and structures and poor hygienic design/inaccessibility for cleaning of food
production equipment.
Ensure high hygiene production practices limit the cross‐contamination vectors that can carry
Listeria from sources to product or product contact surfaces. Cross‐contamination is exacerbated
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when e.g. product, ingredient, packaging, transport, people and waste flows cross‐over; when space
for operations is limited; when the process or interim cleans use too much water and when there is
no demarcation of operative responsibilities, e.g. production, housekeeping, waste removal, product
QC.
Design an effective cleaning and disinfection programme that will kill or remove any Listeria that has
entered high hygiene areas within the current production time frame. To undertake this task, all
surfaces that could harbour Listeria must be accessible to cleaning fluids and all equipment should
be periodically dismantled to ensure all surfaces are accessed. The cleaning programme should be
scheduled so that Listeria is actively decontaminated or flushed from the food processing
environment rather than being moved from one surface to another (e.g. from the floor to food
contact surfaces) by the cleaning sprays.
Provide an environmental microbiological sampling programme which monitors and verifies Listeria
control procedures and maximises early detection of Listeria in the production environment to
facilitate immediate control. Listeria sampling should be undertaken: ‐
around the barriers during production (is there any evidence that the barriers are failing in
preventing the entry of Listeria into the high hygiene area);
from known or suspected Listeria sources and vectors (are source/vector Listeria controls
working);
from collector points (footwear, cleaning equipment, drains etc. – i.e. maximising the
detection of Listeria to assess whether it is in the high hygiene area),
and post cleaning and disinfection of food contact surfaces to verify the cleaning and
disinfection process.
Following the comment about staff responsibilities in key element 1, and whilst there is undoubtedly
a matrix of responsibilities, Figure 2 indicates that the primary responsibilities are for Senior
Management to coordinate the 5‐point plan, for Technical to establish and manage the barriers and
environmental sampling plan, for Engineering to specify and maintain the manufacturing
infrastructure, for Production to coordinate all manufacturing activities to manage potential cross‐
contamination vectors and for Hygiene to establish and manage the cleaning and disinfection
programmes.
The undertaking of the Processing Environment Plan (PEP) follows the 14 steps of the HACCP plan as
defined by Gaze (2009) and was deliberately engineered as such so that it does not introduce any
new principles into food safety management.
Step 1 Obtain management commitment
Senior management must be committed to providing the necessary resource (including a PEP plan
manager) for the study to be planned, undertaken, implemented and periodically reviewed. For RTE
manufacturers, this will be essential as the outputs of the PEP are likely to be critical in practically
controlling Listeria.
Step 2 Define the scope or the terms of reference
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The processing area(s) for the study should first be determined, typically the high hygiene area. The
PEP plan can be used for most biological, chemical or physical hazards, but for this document, and
secondly, the study would focus on Listeria. Lastly, the types of potential sources and routes
(vectors) of environmental contamination transfer may need defining, particularly if these have
already been considered at the generic prerequisite stage of the HACCP study, e.g. compressed air or
the potable water supply.
Step 3 Select the Environmental plan assessment (PEP) team
As the study will assess Listeria sources and vectors within a given process area, many activities and
events may occur in this area at different times of the day, week, year etc. and the selection of team
members should reflect all of these activities. A PEP team is likely to consist of members of
engineering, production, technical. quality and hygiene, hazard specialists such as microbiologists,
and a scribe. Consultants can be used for their technical knowledge, but they should not write the
plan. The PEP should be owned, written, implanted and managed by the food manufacturer.
Step 4 Describe the environment
All physical and operational parameters of the processing environment under study should be
recorded and/or measured with due regard to activities in adjacent processing areas, adjacent to,
below or above the area of study. The physical properties will include the size and layout of the
processing area; any zones of segregation; entrance barriers into the area; services flowing through
or above the area; air flows, temperatures and humidity; personnel flows; transport flows for
product and packaging and solid and liquid waste streams. Operational activities will include
products processed, production lengths and seasonality; housekeeping, end‐of‐production and
periodic cleaning and disinfection practices; maintenance activities and shut down periods.
With respect to Listeria detections, any historical data from previous routine sampling should be
recovered and reviewed.
Step 5 Susceptibility of the product to be cross‐contaminated
This clause has been modified from the original step 5 of the Gaze HACCP study, which is Identify
intended product use. For this clause, any properties of the product should be determined that
would prevent or restrict Listeria cross‐contamination from the environment. For example, for hot
product entering the high hygiene area from a cooking process, when does the product cool
sufficiently so that any Listeria cross‐contamination would survive on the product surface?
Step 6 Construct flow diagrams
All information collected during step 4 should be recorded in the form of physical maps or diagrams
of the processing area. Ideally this should start with a map of the processing area with the layout of
food processing equipment and services. Overlaying this map can be specific diagrams of e.g.
alternative production equipment set‐ups, air flows, personnel flows, transport flows and waste
flows. At a simplistic level this plan can be achieved by using coloured acetates which can be
overlaid to build‐up a ‘3‐D’ picture of the processing environment, or can be undertaken more
structurally in e.g. CAD software packages
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The diagrams prime purpose is to be used in step 8 to help in the identification of potential cross‐
contamination vectors, though it can also be used to record any subsequently identified Listeria
sources and contamination vectors.
Step 7 On‐site confirmation of flow diagrams
The PEP team should audit the processing area at all processing, sanitation, maintenance and down
times to ensure that the flow diagrams produced are accurate and representative. The flow
diagrams can then be signed off as a true record of the processing area.
Step 8 List all potential hazards, conduct a hazard analysis and consider any measures to
control the identified hazards
Step 8 according to Gaze (2009) equates to Step 1 of the 7 HACCP principles as defined by the Codex
Alimentarius Commission (Anon 1993) and subsequently, steps 9‐14 relate to Codex steps 2‐7.
Within this step the PEP team conducts a thorough investigation, via physical examinations and
microbiological sampling, to identify any Listeria sources and any mechanisms or vectors via which
Listeria could enter the food product directly or indirectly. Sources may be harbourage sites or
growth niches. Harbourage sites are physical areas in which pathogens can lodge and be protected
from external forces such as cleaning and disinfection actions, e.g. poor hygienic design features of
processing equipment or damaged areas of the plants building structure. Growth niches are also
harbourage sites, but which also provide an environment for growth, e.g. nutrients, temperature,
oxygen, water or humidity and lack of competition from other microbial flora.
Listeria may transfer from sources directly to the food product, on product vectors, or indirectly to
other parts of the processing environment via environmental vectors (from which they could then
contaminate the product). There are three prime product vectors: physical contact with a solid
surface (hard surface e.g. a conveyor or belt or soft surface e.g. a human hand), physical contact
with a liquid or settlement and/or impingement from the air (or other gases). There may be many
environmental vectors that can redistribute Listeria around the food processing area including,
footwear, trolley wheels, cleaning equipment, cleaning sprays, toolboxes, leaks etc.
For all identified sources and vectors, any controls should be recorded and if not present, control
actions should be assigned. It is then possible to undertake a risk analysis of the sources and
vectors, both before and after controls have been applied, to understand the severity of the risk of
Listeria contamination from these sources/vectors and the adequacy of the controls. A risk analysis
for a source is the risk of Listeria being present at the potential source and the ability of the Listeria
to be transferred from this source via an environmental and/or product vector. A risk analysis for a
contamination transfer vector is the potential for Listeria to be present on the product vector and
the frequency of the vector. A risk analysis can be undertaken using e.g. a 3 or 5 point scale from
low to high and the presence/spread or presence/frequency scores can be multiplied together to
obtain an overall risk score.
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Step 9 Determine Operational Prerequisites
Control of food product contamination with Listeria is a combination of eliminating or controlling the
number of possible harbourage sites and niches and removing all unnecessary contamination
vectors and controlling those that remain or are intrinsic to the food production process.
However, the control of some sources or vectors (prerequisites) may be more critical to the safety of
the food product than others, dependent on the pre‐control risk score, particularly if controls failed.
For sources or vectors that cannot be eliminated, have high pre‐control risk scores, but effective
controls, the control of these prerequisites can be elevated to the level of operational prerequisites
(OP) (Anon 2005). OPs may also be established on a temporary basis until a source/vector is
eliminated. For example, a broken floor which is known to be a source of Listeria and is currently
controlled by spraying it with disinfectant every 2 hours, may be elevated to an OP until it is
replaced/repaired. As noted previously, OPs can be managed to the same level as CCPs
Step 10 Establish control or operating limits
Wherever possible, control or operating limits should be identified for each OP. These may be
defined in legislation, codes of practice and other guidance documents, though the majority are
likely to be determined from collection of experimental data during trials, e.g. cleaning validation
data. The specific control limits for each OP must be a measurable (e.g. ATP or protein levels after
cleaning, disinfectant levels, flow rates, pH’s, temperatures, pressures, contact times) or an
observable parameter related to the control option. Measurements are preferred but where control
limits are based on subjective data (e.g. visual observations), clear guidance should be provided (e.g.
photographs to define clean surfaces or appropriate wearing of protective clothing). The PEP team
should record details of how the control limit was determined, including relevant sources of
information or experimental/validation trial data.
Step 11 Establish a monitoring system
Monitoring systems describe the methods by which the food processor ensures that the OP’s are
operating within their defined control or operating limits and are thus ‘in control’ and, as a corollary
of this, produce an accurate performance record which can be used for process verification (Step
13). The monitoring system must be able to detect loss of control at the OP in a time frame
sufficient to provide corrective actions which will regain control.
Monitoring systems should ideally be on‐line and could include air and gas pressure, humidity,
temperature, chemical concentration, redox, conductivity or pH probes; UV intensity, flow rate, and
rapid hygiene checks such as ATP, allergen and protein tests. Some on‐line monitoring systems have
a direct feedback system with the ability to directly control (and record) any drift in the control limit,
and these are preferred. Other monitoring checks may be visible and could include an assessment of
cleanliness, an assessment of a personnel clothing changing procedure or whether a procedure is
correctly being followed.
Step 12 Establish a corrective action plan
Practical and achievable corrective actions should be undertaken when the results of monitoring at
an OP detect a situation where a control limit has not been met (deviation) or when a treatment
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system is drifting out of control. Responsibilities for corrective actions should be clearly defined and
any product that could have been contaminated through any loss of control should be placed on
hold following company quarantine procedures to allow authorised personnel to determine its fate.
Step 13 Verification
The verification stage is concerned with three activities: validation, verification and review. The
objective of the validation stage is to ensure that all sources and contamination vectors for Listeria
that could be present in the processing environment have been considered and that the controls put
in place to reduce or eliminate them are technically sound and effective. Identified control actions
should then be validated as appropriate, using best practice techniques.
Verification of the PEP gathers information from routine analytical tests that are used to
demonstrate the effectiveness of the Listeria controls and OP’s in a time frame beyond that of
monitoring (Stage 11). Verification can include microbiological sampling; internal and external
auditing; analysis of customer complaints; trending of monitoring and verification results and a
review of any deviations, corrective actions and any resulting foodstuff disposal.
In accordance with the general principles of food‐safety management, the PEP should be reviewed
at least annually and following any significant change to the food production process or the
processing environment.
Step 14 Establish documentation and record keeping
Accurate, timed and dated records, including the actual as well as any calculated results, should be
retained for at least the shelf life of any foodstuffs and be sufficient to enable records to be available
to support a defence of due diligence.
4. Listeria control management
Key elements 2 and 3 will develop a number of prerequisite Listeria controls, together with
potentially CCPs and OPs, that will need documenting and managing. This traditionally involves,
policies, procedures and work instructions that document the prerequisite task, typically in the
format of a quality or food safety system such as ISO 9001 or 22001 (Anon 2005, 2015). These
policies etc. can be documented in the LMP or integrated into the site Business Management or
Quality system, though if this is the case, their location in the Business Management or Quality
system should be referenced in the LMP. Staff can then be trained against these procedures and
work instructions and appropriate training records maintained. It is important that for the
management of CCPs and OPs, staff have the knowledge, competence and authority to take any
appropriate and stated corrective actions.
It is likely that all Listeria prerequisite controls will need validation. Validation is a structured process
to provide documented evidence of the capability of the prerequisite control to meet its specified
outcome e.g. removal of Listeria from food contact surfaces following an end‐of‐production cleaning
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and disinfection programme. Validation is a best practice GMP and is a requirement to meet retailer
audit standards. There is little guidance available on how this should be undertaken, though the
European Hygienic Engineering Design Group offer advice on the validation of cleaning systems
(EHEDG 2016), the principles of which can be applied to other prerequisite validations. Such
principles include recording the efficacy of the prerequisite control under the worst case operating
scenarios, and on at least three occasions, to ensure it meets its objectives.
Once Listeria prerequisite controls have been validated, they must be routinely applied and
monitored and verified. Monitoring is a planned process of assessment via observations and
measurements that allows relative real‐time control. Verification provides objective evidence of
prerequisite control compliance and has no time frame. All validation, monitoring and verification
records should be retained to provide evidence that the Listeria control prerequisites were fit for
purpose and have been working effectively.
Validation, monitoring and verification should be reviewed following any e.g. changes in product
ingredients, the process, the process equipment, or the prerequisite control methods; after any
indication that the current control method is not performing appropriately or following new
knowledge or legislation (e.g. allergen thresholds).
5. Listeria testing and reporting
Many of the controls identified following the risk assessments in elements 2 and 3, and managed in
key element 4, will require verification by microbiological testing. Due to the significance of the
results of these tests (particularly if L. monocytogenes is identified) all measures should be
undertaken to ensure that microbial test results are reliable.
Microbiological sampling must be undertaken by trained staff and, via support from the
microbiology testing laboratory, there should be evidence that the sampling and transport media is
able to neutralise any disinfectant residues present and support the viability of any Listeria captured,
from the time of sampling to the time of analysis.
All identification and enumeration of Listeria should be undertaken by a laboratory using
internationally approved methods that have been accredited to the requirements of ISO 17025
(2005). If possible, the laboratory undertaking the tests should be part of an approved proficiency
test scheme, in which the detection of Listeria in proficiency samples is part of that test scheme.
Positive controls used by the laboratory particularly if they include L. monocytogenes, should be well
characterised and easily identifiable to ensure that if L. monocytogenes is detected in product or
environmental samples, it can be easily distinguished from the positive control strains.
The number of product and environmental samples taken will be determined by the number of
product SKUs, the complexity of the processing environment, best practice and customer
expectations. However, it is not unusual for medium size food manufacturers producing RTE
products to undertake 100‐200 product, and similarly 100‐200 environmental samples, per month.
Product and environmental results should be continuously analysed and trended. Whilst the
detection of any Listeria species, and L. monocytogenes in particular, will require an appropriate
degree of action, we must be realistic and recognise that as Listeria is an environmental
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microorganism, well adapted to growth in (chilled) food factories, it will be detected. Indeed, if
Listeria is never found in the product or environment the strong likelihood is that there are failures
in the sampling and enumeration techniques, or too few samples have been taken. What is more
important is an understanding of the level of Listeria isolation that has been found, which means
determining the percentage isolation rates of L. monocytogenes in product and the environment.
Best practice is approximately 0.1% detection of L. monocytogenes in high risk product and 0.2‐0.3%
detection in high care products. For environmental samples the isolation rate is variable and
depends on the sample sites; there is much more likelihood of detecting Listeria in drains and
cracked floors than on cleaned food contact surfaces. However, again, isolation rates in the 0.2‐
0.5% range are best practice. So, if a food manufacturer has isolation rates in the above, best
practice ranges, and all results for L. monocytogenes are detected, <10cfu/ml, then the food
manufacturer had good Listeria control practices in place.
An ongoing analysis of Listeria detections may also be useful in determining Listeria sources.
Sporadic detection of Listeria strains may indicate a continuing infiltration of Listeria into the high
hygiene food manufacturing area and may indicate variability in raw material supply or failures of
the low/high hygiene barriers. The continuous detection of the same Listeria species may be
indicative of a Listeria harbourage site in the high hygiene area which is not currently been
controlled. Whether this ‘persistent’ species is the same strain can be assessed by genetic
fingerprinting tools. There is some reluctance by food manufacturers to undertake whole genome
sequencing, as used by public health bodies for the characterisation of strains presenting to the NHS
and in outbreak investigations in the UK, because of potential data protection issues. However,
other simpler genetic fingerprinting techniques are available (e.g. ribotyping, PFGE) that are capable
of allowing an assessment of whether strains are likely, or not likely, to be the same strain.
The success or otherwise of the LMP, as measured by Listeria isolation rates in product and the
environment, will almost certainly have to be reported externally to customers, and likely, any
remedial plans approved. Reporting the incidence of Listeria internally is also highly recommend as
a continuous verification of the LMP and in highlighting the necessity for any remedial plans. Again,
isolation rates are unlikely to be trended downwards without the support of all members of the LMP
and their teams, and good internal communication will be critical to this.
6. Actions following Listeria detection
As the (chilled) RTE market has been well established over a period of >30 years, there is a wealth of
Listeria data to analyse. It is now apparent that the presence of any of the non‐L. monocytogenes
species is not indicative of the likely presence of L. monocytogenes, the strain currently seen as
pathogenic, in product or the environment, and the presence of these strains should not generally
trigger thoughts of product recall. However, the presence of non‐L. monocytogenes strains may be
indicative of poor performance of the LMP, particularly the control of low/high hygiene area barriers
and the presence of unidentified Listeria sources, which may be subsequently able to harbour L.
monocytogenes. As such, the presence of any Listeria strain should warrant attention.
The identification of non‐L. monocytogenes strains should lead to investigations, as detailed below.
Similarly, the detection of L. monocytogenes, at ‘detected <10cfu/g’ in product, should trigger such
23 Apr 2018, ©Holchem 11
investigations if shelf‐life studies indicate that Listeria at this level will not increase to levels in excess
of legislative requirements within the product shelf‐life. The detection of L. monocytogenes in
product at a level that exceeds legislative requirements, or which could grow in product within the
shelf‐life to exceed such levels, would trigger consideration of the recall plan.
If high levels of L. monocytogenes are identified in the product or environment, or there is evidence
that there are significant failings in the LMP and the incidence of Listeria environmental and product
detection is increasing, it may be necessary to decontaminate the food processing environment. A
decontamination plan should be established as part of the sanitation Hygiene Management System
or the Crisis Management Plan, which is over and above what is undertaken in routine end‐of‐
production cleaning and considers the decontamination of all equipment and environmental
surfaces, the air and drainage systems. A successful decontamination plan allows the consideration
of return to production, which is the first business priority, but may inherently remove evidence of
Listeria sources, making route cause analysis difficult.
If L. monocytogenes is detected at or about 0.1% of product samples, and at ‘detected <10cfu/g’ in
product, i.e. best practice, it may not be necessary to undertake any investigations. However, if
there is a trend towards increased detection of L. monocytogenes, or an increase in sporadic strain
detection, in the product or environment, or potentially the persistence of a strain in the
environment, then investigations are required. For Listeria detected in product, these could take the
form of: ‐
Has anything happened within production or the processing area that could directly or
indirectly contaminate the product (e.g. increased production, new products,
maintenance/building work)?
Is there any evidence of a failure of the decontamination process (e.g. times, temperatures,
washing process aid concentrations)?
Is there any evidence of contamination in common product ingredients?
Is there any evidence of contamination from product produced on single process lines or
from single processes?
When is the product first contaminated in the processing day?
Where is the product first contaminated in the process, from the decontamination stage
through to primary packaging?
Following ‘where’ and ‘when’ studies, can a specific piece of processing equipment be
implicated?
If Listeria is found in the product, its presence in the environment is likely to increase due to cross‐
contamination. In addition to the above questions, therefore, for Listeria detected in the
environment, this could take the form of: ‐
Is there any other evidence of high levels of microbial contamination in the environment e.g.
High TVC or Enterobacteriaceae levels?
Has Listeria been found at a specific low/high hygiene barrier? If so, is the barrier
functioning properly, e.g. for a wash tunnel, is the disinfectant concentration, contact time,
line speed, tunnel loading and spray nozzle performance all in specification.
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Has Listeria been detected post cleaning and disinfection. If so, the cleaning and disinfection
records should be analysed and the cleaning instructions reviewed.
If Listeria is found in generic sampling or ‘collector’ points, e.g. cleaning equipment,
footwear, trolley wheels, drains, where did the Listeria come from and where could it be
spread to?
Can a source be identified (e.g. a broken drain/floor interface), isolated or controlled?
Can a vector be identified that could cross‐contaminate product and can this be controlled?
Detection of Listeria in the product or environment is likely to lead to additional product and
environmental Listeria sampling. This should continue until the issue is resolved, or there is no
evidence of further Listeria contamination, and then the product and environmental sampling
should return to routine level.
References
Anon (1993) Codex Alimentarius Commission. Food hygiene basic texts
Anon (2005) ISO 22000:2005 Food safety management systems – Requirements for any organisation
in the food chain (www.iso.org)
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