Part 4: Corrective Actions

1. Part4: Corrective Actions Lisa Olsen Specialist Adviser, NZ Standards

2. What should you get from this guide? • A clearer understanding of MAF’s expectations if there is a Listeria contamination event • Information which can be used to develop your LMP and help you prepare for a contamination event

3. Definitions • Contaminated product means product that testing has shown to be contaminated with L. monocytogenes. • At risk product means all batches of product that are potentially contaminated with L. monocytogenes • Contamination event is when Listeria and/or L. mono are detected on product contact surfaces and/or in product during routine monitoring, surveys or an illness investigation.

4. How might you receive aListeria Notification? • Routine environmental monitoring • Routine product testing • Customer sampling • Regulatory surveys • Illness investigations

5. Corrective Actions • Halt processing • Isolate affected equipment and areas • Notify verifier, Food Act Officer or MAF within one working day of notification

6. Corrective Actions • Retrieve or recall contaminated and at risk product • Identify and hold contaminated and at risk product

7. Investigate Cause of Contamination • Inspect contaminated process area(s) and equipment • Carry out investigative environmental sampling to identify any environmental contamination source

8. Investigative environmental sampling • Commence within 1 working day of receiving notification • Explore all possible areas of contamination rather than focus on small areas • Review environmental results from other areas to identify areas that may require reassessment of controls • Testing at higher level should continue until source of contamination identified • Thoroughly clean and sanitise once sampling completed

9. Investigate cause of Contamination • Review supporting system and processing records • Sample raw and in-process materials • There is a good chance that more than one thing is the source of problem – it is quite likely to be a combination of things – keep an open mind

10. Clean and sanitise • In a high proportion of cases where Listeria contamination occurs there have been problems with the cleaning and sanitising programme • A person with the appropriate level of expertise should be involved in any review of the programme.

11. Intensive Microbiological Sampling Programme • Testing of at risk product and product contact surfaces at a higher frequency than routine microbiological monitoring • Purpose: • identify any at risk product that may have been contaminated at time of L. mono detection • test at risk product and product contact surfaces once processing resumes.

12. Previously processed product Last clear test from routine monitoring Routine monitoring, positive L. monocytogenes Lab result – L. monocytogenes detected on a sample taken at day 0 0 1 2 3 5 6 7 Days Samples P P P P P P P P P PC P PC P PC P PC P = product sample PC = product contact surface sample What product could be at risk? 4

13. Testing at risk product: around time of the contamination event • What product could be considered at risk? • since last not-detected result for Listeria species • on same processing line • on same day or day before the positive result • between taking the positive sample and notification of Lm • on processing lines close to contaminated line • processed under abnormal conditions e.g. failure at a CCP

14. How can you narrow the range of at risk product? • Process and supporting system records • results from past testing • results from environmental investigation (if available) • knowledge of process flow and production schedules

15. At risk product:around time of contamination event • PCS positive: sample size per batch of at risk product • Product positive: sample size per batch of at risk product

16. Testing onceprocessingresumes • Use results of investigation to date to narrow the range of at risk product • Sample at risk product during processing based on random times or hourly • Sample product and product contact surfaces at the same time • For product with a short shelf life testing may need to occur on trial batches

17. Testing of at risk product and PCS onceprocessingresumes • PCS positive: sample size per batch of at risk product • Product positive: sample size per batch of at risk product

18. Intensive Microbiological Verification • Commences after 3 days of “not-detected” for Listeria at intensive sampling size • Continue for 4 days to give confidence that Listeria has been controlled • Minimum suggested sample sizes given • If a positive returned, resume intensive sampling

19. Continued Detections? • Response to be escalated • Usually indicate bigger more persistent problems • Halt processing on the contaminated line(s) • Engage external expert to review actions and assist in resolution • Where processing continues, all affected product at risk • Consider expanded recall • Continue investigation into cause

20. Sample sizes • Suggestions only but justification expected where smaller sample sizes taken • As number of samples decrease, chance of accepting an unacceptable product batch increases. • Costs involved in sampling and testing weighed against impact of making an incorrect decision • Regulator to be involved in decisions on sample size

21. Micro Testing • For product that will not support the growth of Listeria and that has a limit of 100 cfu/g, having the laboratory enumerate the Listeria could be used to assist in determining product disposition • Lm may be further differentiated to help to determine whether the same or a new type of Lm is contaminating product contact surfaces and/or the product. • By comparing the different DNA patterns you can see if: • there is a recurring ‘house’ Lm which will have established itself in a niche or harbourage site or • there are different DNA fingerprints of Lm it suggests that contamination is being introduced, e.g. from the external environment, ingredients, equipment, personnel.

22. Corrective Actions • Dispose of contaminated and at risk product • Prevention of recurrence and review of LMPafter the event • Documentation, records and reporting

23. Thank you