Pathogen Reduction

1. Pathogen Reduction

2. Salmonella Performed by FSIS E. coli Performed by Establishment Comparison/Contrast

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

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

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

6. Salmonella Carcass Sponge beef swine turkey E. coli Carcass Sponge beef swine turkey Comparison/Contrast

7. Salmonella Excision none E. coli Excision beef swine Comparison/Contrast

8. Salmonella Whole bird rinse chicken E. coli Whole bird rinse chicken turkey Comparison/Contrast

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

10. Salmonella FSIS samples Performance Standards qualitative positive or negative # samples tested (n) maximum # of positives to achieve standard (c) E. coli Plant samples Performance Criteria quantitative m/M expressed as cfu/cm2 or as cfu/ml statistical process control Comparison/Contrast

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

12. Salmonella Performance Standards expressed as a “positive” or “negative” E. coli Performance Criteria expressed as cfu/cm2 or as cfu/ml Comparison/Contrast

13. Salmonella Sampling procedures explained in FSIS Directive 10,230.5 E. coli Sampling guidelines given in §310.25 and §381.94; in 2 guidelines; and in plant written procedures Comparison/Contrast

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

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

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

17. E. coli • Written procedures identify • sample collector • sampling locations • sampling randomness • sample integrity

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

19. E. coli

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

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

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

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

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

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

26. Salmonella • Implementation • Compliance Phase • begins on same date as HACCP starts in plants • enforcement of standards in effect

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

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

29. Salmonella • Results • After the sample set is complete, OPHS will e-mail the complete results to the • DO • Establishment (if it has provided an e-mail address) • Sampling Coordination Team (SCT)

30. Salmonella • The District Office will notify the • IIC • Establishment (even if OPHS sent an e-mail message)

31. Salmonella • Negative Results • All parties are notified • Sampling continues at normal frequencies for new sample sets

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

33. Salmonella • Positive Results • DO will instruct the IIC in the frequency for sampling further sample sets

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

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

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

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

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

39. Sampling • Large Plants • May have both compliance and baseline samples to take • Take both if possible • If not possible, compliance samples take precedence

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