Strategies for Implementing a Listeria Control Plan The Big Picture

Goals for a Listeria Control Plan  Minimize Listeria contamination coming into the plant  Effective cleaning & sanitation procedures  Find Lm harborages & niches in the plant and eliminate them  Prevent cross-contamination  Processing Surfaces  Finished products  Train Employees and monitor their performance

Elements in a Complete Listeria Control Plan  Sanitation and GMP Controls  Training of Plant Personnel  Plant Environmental Monitoring/Testing  Raw Material Controls

What have we learned?  Controlling Listeria requires a day-to-day, long term commitment  Everyone must be involved  Management  Employees  There are no “magic bullets” at this time  Proper cook process  Prevent cross-contamination

Step 1 - Start by Evaluating Your Situation Some Questions to Consider  Is finished product area susceptible to contamination from the rest of the plant?  Do you have drainage problems in the plant?  Do repairs or upgrades need to be made to the plant or process?  Does the location of specific processing steps or operations make cross contamination likely?

Questions ….. continued  Do you have condensation/ventilation problems?  Do you have consistent sanitation procedures and how effective are they?  Do employees consistently wash their hands & use proper food handling & hygiene practices?  Do you prevent live crawfish from entering the plant other than directly to the cooker?

Step 2 – Assess the Potential for Cross Contamination Assess Your Situation by Observing the Movement of People & Equipment throughout the plant at several different times over several days.  Do employees move back and forth between raw and finished products areas?  Do employees wash their hands, or take any other steps before entering finished product areas?  Do employees come directly into finished product areas from outside the plant?  What policies or procedures can you implement to minimize potential contamination?

Step 2 – Assess the Potential for Cross Contamination … continued  Is equipment like crawfish totes, carts, tubs, packaging materials etc. moved from the raw areas of the plant to finished product areas?  Is it likely to be a source of cross-contamination?  How can you minimize cross-contamination in the finished product area?  Control employee movement?  Boot wash/dip stations?  Are raw and finished products stored in the same cooler?

Build a Plan to Control Cross Contamination  Build a workable plan and policy to control employee movement and inadvertent cross-contamination of finished product areas.  Implement a plan to control equipment movement between processing areas.  Decide what changes need to be made in cooler or freezer storage to prevent cross contamination.

Step 3 – Assess Your Sanitation Procedures  Do employees understand importance of day- to-day cleaning and sanitizing?  What are the current procedures in place?  Are they done properly?  Are these procedures and frequency adequate?  Are they consistently used?  Who is responsible for each cleaning & sanitation task?

Modify Sanitation Procedures as necessary & Develop SSOPs  Use the suggestions provided in the workshop and handouts to help with your assessment. Ask for help if you need it!  You probably have most of the procedures you need already in place. Work now with your sanitation supplier to modify them if necessary.  Write down your procedures to be sure that everyone knows them and agrees on them.

Step 4 – Assess Employee Hygiene and Food Handling Practices  Do all employees wear proper hair covering, outer garments and footwear to prevent contamination?  Do employees wash their hands properly and at the proper times?  Do all areas have adequate hand washing facilities in a convenient location?  Where are additional facilities needed?  Are company policies adequate to ensure that all employees follow proper hygiene & food handling practices? If no, what changes are needed?

Modify Personnel Procedures and/or Policies as necessary  Use the suggestions provided in the workshop and handouts to help with your assessment. Ask for help if you need it!  You probably have many of the procedures or policies you need already in place. Make improvements if they are necessary.  Write down your procedures or policies to be sure that everyone knows them and agrees on them.

Step 5 – Conduct Employee Training Experience has shown that training is more effective and has a greater impact if:  Management has made a commitment to the problem & invested in improvements  Policies & procedures are uniformly and consistently monitored and enforced  Employees understand why the changes are needed and the potential impact on their job

Suggested Training Programs Basic food safety training is needed for all employees prior to starting work Special training for Listeria control could include: 1) Basic overview of Listeria problem and basic hygiene & policies for all employees 2) Specific training for workers in raw and finished product handling areas 3) Hands on training for all employees who conduct cleaning & sanitation tasks  Records should be kept for all training activities!

Step 6 – Implement an Environmental Monitoring/Testing Program  Testing is needed to evaluate and improve the effectiveness of your Listeria control program.  Environmental testing may include drains, non-food contact surfaces, equipment & food contact surfaces in various parts of the plant.  Other testing could include finished products.  Use information provided by your lab, this workshop and handouts to develop a testing program and determine what actions will be taken when results are positive.

SUMMARY  Building a complete Listeria Control Plan will take a commitment of time and resources.  This plan will need to:  Assess infrastructure and equipment needs  Assess Sanitation and GMP controls  Conduct employee training  Implement an environmental testing program  It can be done if you prioritize and implement changes one step at a time!