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• 17. Monitoring Programmes

17. Monitoring Programmes

Monitoring programmes for Listeria have been described in circulars issued by the FIICC. The principles of these circulars should be adhered to in establishing your own Listeria monitoring programme.

It is recommended that all fish packing houses, including those not already covered by FIICC circulars such as oyster and fin fish plants, put in place a Listeria monitoring programme.

The environmental monitoring programme is your verification that the listeria control systems in place are effective.

Environmental Monitoring

General Requirements

• Contamination of product from the processing environment is the most common source of contamination for processed foods.
• For this reason, it is vital to ensure that the processing environment is always protected from contamination using the measures previously described.
• Monitoring of the processing environment (and final product) provides the processor eith an assurance that the control measures are effective.
• Each site should develop documented sampling procedures. In general these should describe;

Sample Site Selection

Positive Results from Zone 1 and 2

• Positive results from zones 1 and 2 are to be expected from time to time. These provide you with;

Recommended Actions for Positive Results in Zones 1 and 2

• Use this positive result as an early warning.
• Resample individual zone 1 or 2 sites (as the case may be) in order to pin-point the source of contamination.
• Reassess:

• You may wish to intensify sampling in zones 3 and 4 to ensure that zone 3 and 4 barriers have not been breached.
• Clean-up and sanitise the affected area to minimise the risk of contamination spreading.
• Resample all sites in the affected zone daily (and composite for testing) until you are sure that the source of contamination has been eliminated.

Positive Results from Zone 3

• Positive results in zone 3 mean that the zone 1 and zone 2 barriers have been breached and contamination has entered the critical hygiene area.

Positive Results from Zone 4

• Positive results in Zone 4 indicate that processing hygiene has broken down enabling product contact surfaces to become contaminated.

Recommended Actions For Positive Results in Zones 3 and 4

Sources of contamination in the critical hygiene area of the fish packing house are not likely to be isolated in one discrete area. It may be necessary to hunt for sources of contamination in areas that so not form part of the normal monitoring programme. Therefore, the sampling policy outlined in the FIICC Circular should be looked upon as the minimum requirement.

Remember, the objectives of any follow-up action are to:

Specific follow-up action should include the following:

• Reassess:

• Intensify sampling in critical hygiene areas to pinpoint the source of contamination. (Individual samples will be needed for test.)
• Clean and sanitise zones 3 and 4.
• Resample all environmental sites in zones 3 and 4 to verify cleaning and sanitising efficiency.
• It is recommended that batch-by-batch sampling and testing of product be carried out of all product in store processed since the date of the last negative test result for either product or zones 3 and 4, and product produced from this point. (See Product Testing below for recommended sampling and follow-up actions in the case of product positive results.)

Product Testing

• It is recommended that a representative sample of finished product, in its final packaged form, be taken each time you sample the processing environment. Include samples of each product type and processing line. This is a good check on the efficiency of your environmental sample site selection.
• Negative results from product samples will provide you with added assurance that your Listeria management programme is working adequately.
• It is wise to hold all product until the test results are available.
• A sample size of 5x25 g sub-samples taken across a batch of product and composited will provide an adequate sample for testing.

Recommended Actions for Positive Product Results

• Refer to relevant FIICC circulars and regulations for more details.
• Product that tests positive for Listeria monocytogenes poses a risk to public safety and must not be offered for sale.
• Each site should have in place a documented procedure for recalling product from the market place. (See the next section Product Recall Procedures).
• All product in store that is "at risk" must be segregated from other product and clearly labelled to indicate its’ status. For example, mark each package with hold labels.
• Reprocessing to destroy Listeria monocytogenesmay be a viable option for treating contaminated product:

• If reprocessing is not a viable option, the product must be destroyed.
• Product disposition options should be outlined in your Product Safety Programme.
• Reassess the environmental sampling programme, access restrictions and processing procedures to determine possible causes of the product contamination.