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Expert Commentary

Regulations & Legislation

FSIS guideline for retail delis on controlling Listeria monocytogenes

By Dennis R. Johnson
July 6, 2015

On June 11, the Food Safety and Inspection Service (FSIS) announced the availability of its updated guidance, “Best Practices Guidance for Controlling Listeria monocytogenes (Lm) in Retail Delicatessens.” (http://bit.ly/NPregleg0715) The guidance addresses operations conducted at retail delis. In the Federal Register announcement, FSIS expressly stated:

Because the requirements, processing conditions and practices are different at retail than in processing facilities, issuing this separate guideline provides the specific information retailers can use to control Lm in the deli area.

There are five key findings in the guidance. Three of these findings apply to the delis themselves: storage temperature, prevention of cross contamination during operations and sanitation of the deli. The other two findings relate to products purchased: use of growth inhibitors and the supplying establishment’s Listeria controls. It is these last two findings that relate to what retail delis might request or expect from their suppliers.

Products Treated with an Antimicrobial

FSIS estimated that if all products in the deli were treated with an antimicrobial to inhibit the growth of Lm, the predicted risk of listeriosis could be decreased by approximately 96 percent. (Page 5 of the guideline.) This one suggestion has the largest single impact on the risk of listeriosis, more than twice the impact of any other suggestion.1

Given the public preference for a more “natural” product, made without ingredients that have chemical sounding names, it will be interesting to see how many retail delis will seek products with these inhibitors. The benefits of inhibitors also may generate supplier interest on identifying alternative, more natural inhibitors.

Control of Contamination at the Supplying Establishment

Although controlling contamination at its source does not provide as impressive a level of risk reduction,2 the guidance states:

If levels of Lm on RTE foods (including foods that do not support the growth of Lm) that the retail deli receives from processing establishments were reduced by half, approximately 22 percent of the predicted listeriosis illnesses could be prevented.

When looking through the five key findings, this one does not affect deli operations nor the product profile. Hence, from the delis’ perspective, this finding may be the preferred way to start addressing Lm.

Based on this finding, one could expect the deli to reach out to suppliers to understand what the suppliers are doing to control Lm. The supplying establishment should be ready to explain its Listeria control monitoring program, as well as the use of any antimicrobials, processes (such as high-pressure pasteurization), or practices at the establishment to address Lm risk.

Although the guidance is labeled as being for retail delis, all inspected establishments should read it to understand the advice FSIS is providing delis. NP

 

  1. FSIS did note the actual risk reduction might be less if the inhibitor is not effective for the full shelf life of the product or if lower concentrations of the inhibitor are used because of flavor concerns.
  2. FSIS predicts a 22 percent reduction in listeriosis for this finding.
     
KEYWORDS: deli operators listeria Listeria monocytogenes

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Dennis R. Johnson is a principal with Olsson Frank Weeda Terman Matz PC in Washington, D.C. Mr. Johnson has 30 years experience in food-safety law and regulation, representing large and small meat and poultry companies.

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