Pathogen Reduction

Comparison/Contrast n Salmonella u Performed by FSIS n E. coli u Performed by Establishment

Comparison/Contrast n Salmonella u Enforcement begins on same day plant comes under HACCP n E. coli u Enforcement for greater than very low volume plants in January 1997 u Enforcement for very low volume plants in June 1997

Comparison/Contrast n Salmonella u Used as an indicator of process control and sanitary dressing procedures n E. coli u Used as an indicator of process control and sanitary dressing procedures

Comparison/Contrast n Salmonella u Sponge u Whole bird rinse u Product n E. coli u Sponge u Excision u Whole bird rinse

Comparison/Contrast n Salmonella u Carcass Sponge F beef F swine F turkey n E. coli u Carcass Sponge F beef F swine F turkey

Comparison/Contrast n Salmonella u Excision F none n E. coli u Excision F beef F swine

Comparison/Contrast n Salmonella u Whole bird rinse F chicken n E. coli u Whole bird rinse F chicken F turkey

Comparison/Contrast n Salmonella u Raw Product F ground beef, F ground pork F ground chicken F ground turkey n E. coli u Raw Product F none

Comparison/Contrast n Salmonella u FSIS samples u Performance Standards F qualitative F positive or negative F # samples tested (n) F maximum # of positives to achieve standard (c) n E. coli u Plant samples u Performance Criteria F quantitative F m/M F expressed as cfu/cm 2 or as cfu/ml F statistical process control

Comparison/Contrast n Salmonella u Performance Standards F steers/heifers F cows/bulls F ground beef F hogs F broilers F ground chicken F ground turkey n E. coli u Performance Criteria F cattle F swine F chickens

Comparison/Contrast n Salmonella u Performance Standards F expressed as a “positive” or “negative” n E. coli u Performance Criteria F expressed as cfu/cm 2 or as cfu/ml

Comparison/Contrast n Salmonella u Sampling procedures explained in FSIS Directive 10,230.5 n E. coli u Sampling guidelines given in F § and §381.94; F in 2 guidelines; and F in plant written procedures

E. coli Guidelines n Guidelines for Escherichia coli Testing for Process Control Verification in Cattle and Swine Slaughter Establishments n Guidelines for Escherichia coli Testing for Process Control Verification in Poultry Slaughter Establishments

Comparison/Contrast n Salmonella u Sampling frequency F each day product requested is produced F based on compliance history n E. coli u Sampling frequency F based on numbers of animals slaughtered F alternative frequencies an integral part of HACCP plan

E. coli n Basic requirements u Written collection procedure u Collect samples from species slaughtered in greatest numbers u Record results on a process control chart or table

E. coli n Written procedures identify u sample collector u sampling locations u sampling randomness u sample integrity

E. coli n Collect from predominant species only if that species is covered by the regulations F Beef F Swine F Chicken F Turkey

E. coli

n Basic compliance is determined by an E. coli Special Team Member if the plant is not under HACCP n All plants began E. coli testing in 1997 (January and June, depending on plant volume) n When a plant comes under HACCP, then the IIC can perform basic compliance if needed

E. coli n Basic (05A01) u Noncompliance (use Checklist) F Withholding action F Inform plant F Document NR (no trend indicator) and attach Checklist F Notify the DO F If plant takes no action, Compliance is called in

E. coli n Other Requirements u The plant must follow its written procedure u The samples must be analyzed using an AOAC Official Method or other method published by a scientific body u The plant must keep proper records for test results

E. coli n Other (05A02) u Noncompliance with written procedures F Plant not collecting samples in stated location F Plant not sampling with appropriate method F Plant not sampling at required frequency F Plant not sampling randomly

E. coli n Other (use Checklist) u Noncompliance actions F Notify plant F Document on NR (mark “Other” trend indicator) and attach Checklist F No additional action unless plant repeatedly fails to implement the immediate and further planned actions, then IIC calls DO

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

Salmonella n Implementation u Compliance Phase F begins on same date as HACCP starts in plants F enforcement of standards in effect

Sampling Frequency n Normal u daily within a sample set u if more than one shift, randomly determine from which set to take the sample u acceptable to hold the sample overnight before FedExing F carcass, not sponge F ground product already collected

Salmonella n There is no basic or other (05A03) u The IIC takes a sample according to the FSIS Directive 10,230.5 u The sample is FedExed to the lab u The lab analyzes the sample and records the results u OPHS tracks the results

Salmonella n Results u After the sample set is complete, OPHS will the complete results to the F DO F Establishment (if it has provided an address) F Sampling Coordination Team (SCT)

Salmonella n The District Office will notify the u IIC u Establishment (even if OPHS sent an message)

Salmonella n Negative Results u All parties are notified u Sampling continues at normal frequencies for new sample sets

Salmonella n Positive Results u DO will notify plant that it needs to investigate and identify the cause and implement appropriate corrective actions u DO will guide the IIC in documenting the performance standards failure on the NR (no trend indicator, only procedure code)

Salmonella n Positive Results u DO will instruct the IIC in the frequency for sampling further sample sets

Salmonella n Failure to Meet Standards u First time F 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 F IIC issues NR F effectiveness is measured by subsequent testing (within 60 days) F frequency of testing may change

Salmonella n Failure to Meet Standards u Second time F plant must reassess its HACCP plan F IIC issues NR F effectiveness is measured by subsequent testing (within 30 days) F frequency of testing may change

Salmonella n If it fails a third consecutive series: u This would constitute a SSOPand a HACCP systems failure u FSIS will suspend inspection of the product associated with the HACCP system failure

Salmonella n Failure to Meet Standards u Third time F IIC takes a withholding action for all product of the type that failed F IIC issues NR F since the DO notified the IIC, the DO is aware of the situation and will dispatch a Compliance Officer to the plant F frequency of testing other product types may change

Salmonella n Fail Standard u put into a targeted pool u start second sample set for failed product type F within 60 days F sooner if compliance history warrants it

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

Sampling n Small and Very Small Plants u May have both pre-implementation and baseline samples to take u Take both if possible u If not possible, baseline samples take precedence