Pathogen Reduction

Comparison/Contrast

Salmonella Performed by

FSIS

E. coli Performed by

Establishment

Comparison/Contrast

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

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

Salmonella Sponge Whole bird rinse Product

E. coli Sponge Excision Whole bird rinse

Comparison/Contrast

Salmonella Carcass

Sponge beef swine turkey

E. coli Carcass

Sponge beef swine turkey

Comparison/Contrast

Salmonella Excision

none

E. coli Excision

beef swine

Comparison/Contrast

Salmonella Whole bird rinse

chicken

E. coli Whole bird rinse

chicken turkey

Comparison/Contrast

Salmonella Raw Product

ground beef, ground pork ground

chicken ground turkey

E. coli Raw Product

none

Comparison/Contrast 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

Salmonella Performance

Standards steers/heifers cows/bulls ground beef hogs broilers ground

chicken ground turkey

E. coli Performance

Criteria cattle swine chickens

Comparison/Contrast

Salmonella Performance

Standards expressed as

a “positive” or “negative”

E. coli Performance

Criteria expressed as

cfu/cm2 or as cfu/ml

Comparison/Contrast

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

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

Comparison/Contrast 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

E. coli

Basic requirements Written collection procedure Collect samples from species

slaughtered in greatest numbers Record results on a process

control chart or table

E. coli

Written procedures identify sample collector sampling locations sampling randomness sample integrity

E. coli Collect from predominant species

only if that species is covered by the regulations

Beef Swine Chicken Turkey

E. coli

E. coli Control Chart

-200

20406080

100120140

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17

Test Number

E. c

oli c

fu/s

q cm

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

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

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

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

E. coli Other (use Checklist)

Noncompliance actions Notify plant Document on NR (mark “Other”

trend indicator) and attach Checklist

No additional action unless plant repeatedly fails to implement the immediate and further planned actions, then IIC calls DO

Salmonella

Implementation Pre-implementation Phase

take 250 samples per plant in a one-year period

should be completed prior to implementation

no enforcement actions

Salmonella

Implementation Compliance Phase

begins on same date as HACCP starts in plants

enforcement of standards in effect

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

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

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)

Salmonella

The District Office will notify the IIC Establishment (even if OPHS sent

an e-mail message)

Salmonella

Negative Results All parties are notified Sampling continues at normal

frequencies for new sample sets

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)

Salmonella

Positive Results DO will instruct the IIC in the

frequency for sampling further sample sets

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

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

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

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

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

Sampling

Large Plants May have both compliance and

baseline samples to take Take both if possible If not possible, compliance

samples take precedence

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