régis pouillot - fda/cfsan meryl silverman - fsis formerly with the university of maryland, joint...

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Régis Pouillot - FDA/CFSAN Meryl Silverman - FSIS formerly with the University of Maryland, Joint Institute for Food Safety and Applied Nutrition Handling and Preparation of RTE Foods at retail: Observation Studies Interagency Risk Assessment - L. monocytogenes in Retail Delicatessens Public Meeting Washington, DC - May 22, 2013

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Régis Pouillot - FDA/CFSANMeryl Silverman - FSIS

formerly with the University of Maryland, Joint Institute for Food Safety and Applied Nutrition

Handling and Preparation of RTE Foods at retail: Observation Studies

Interagency Risk Assessment - L. monocytogenes in Retail Delicatessens Public Meeting

Washington, DC - May 22, 2013

Food Safety Practices of Food Handlers

• Several studies have assessed food employees’ behavior in food service settings.

• Few have taken place in deli departments.

• Methods used include:– Self-reports in which food employees report past

behavior or estimate future behavior.– Observational designs in which actions are recorded

as they occur.

2May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

Green et al., 2005 (EHS-Net)

• Method:– Telephone survey of food service workers in the U.S.

(n=486).– Asked about performance of four types of behaviors.

• Key findings:

– 40% reported always wearing gloves while touching RTE food.

– 77% reported washing their hands between touching raw meat or poultry and RTE food.

– 67% reported changing gloves between touching raw meat or poultry and RTE food.

3May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

4

FDA Report on Foodborne Illness Risk Factors (2004 & 2009)

• Method– Observed employees

for ~90 minutes at approximately 100 establishments.

– Recorded specific behaviors using a form based on 1997 Food Code.

– Either IN or OUT of compliance.

May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

5

Food workersBehavior Events

A Specific Data Gap for the Risk Assessment Model

May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

Clayton and Griffith 2004 Br Food J 106(3): 211-7

• Method– Observed food employees at catering establishments in South

Wales (n=115).

– Used Notational Analysis which allows for tracking of cross-contamination

– Recorded actions related to hand-washing and cleaning along with whether they were required and/or performed adequately.

– Method also used inGreen et al., 2006 J Food Prot, 69(10): 2417-23

6May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

Study Objectives

• The primary objectives of this study were to identify realistic ranges of:

• Frequency and sequence of contact between any object and the considered product before sale;

• Frequency, procedure and sequence of hand washing and glove changing;

• Frequency, procedure and sequence of equipment, utensil and surface cleaning.

To be used in the L. monocytogenes in retail delicatessens model

7May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

Study Objectives (continued)

– Identify routine cleaning, storage, and preparation practices in deli operations as well as average daily and weekly throughput.

– Develop and validate an observational method.

8May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

Participants

• Nine retail facilities which sell deli meat, cheese, and deli-type salads were selected for the study based on size, location, and other criteria.

– Six were chain retail stores– Three were independent retail stores– Maryland and Virginia

9May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

Object/Equipment Food

DIS – Dish (food container, bowls, platters, tray)

SAL – Salami (chub)

SUR (ST, PL) – Work surface * (Stainless steel, plastic)

CRB – Corned beef

SLI –Slicer* FRT – Fruit

CTB – Cutting board* BOL - Bologna

SK – Sink* KT – Ketchup*

SCL – Scale* RFS – Raw seafood

K – Knife* MY – Mayo*

IM – Ice-maker CHE – Processed Cheese

CL – Reach-in cooler TRK – Turkey

FR – Walk-in refrigerator TM – Tomato

FRH – Walk-in refrigerator handle

BRD – Bread

SPI – Spigot* RCH – Raw chicken

Coding Scheme

• A coding scheme was developed based on common food preparation behaviors and the Food Code requirements.

• The coding scheme was then pilot tested and refined during a visit to a retail facility.

10May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

Example Notational Analysis Chart

10

9

8

7

6

5

4

3

2

1-TIME:

AdequateAttemptedRequiredAction

Specific Food Safety ActionNotesAction SequenceAction No.

10

9

8

7

6

5

4

3

2

1-TIME:

AdequateAttemptedRequiredAction

Specific Food Safety ActionNotesAction SequenceAction No.

P SAL ON SLI #3

10AM

CLS CAS

OPN CAS

WS HDS No soap WS X XPON GLVS

PUP SAL

SL SAL ONTO GLV

11May 22nd, 2013 Interagency Risk Assessment - Listeria monocytogenes in Retail Delicatessens Public Meeting

ResultsChain Independent

No. Employees 25 8

Total time (min.) 885 266

No. Actions 3073 1098

Avg. time (min.)/employee

35.4 33.3

Avg. no. actions/employee

123 137

Avg. no. actions/min.

4.5 5.7

12May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

Sequence of Actions

13May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

Wash hands

Put on gloves

Open deli case

Spray slicer Touch clothes Touch body

Pick up Swiss

Open walk-in

Close deli case

Unwrap Swiss Over trash can On FCS On SlicerOver sink

Sequence of Actions(Alternatives)

14

Bare-hand contact – Hand Washing• No bare hand contact was observed with RTE food.

• Hand washing – when and where according to FDA Food Code 2009

15May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

Frequency of Occasions Hand-washing Actions were Required and Performed

Work activity Chain (n=25) Independent (n=8)

Required

Action

Action

Performed

Required

Action

Action

Performed

After touching body 7 4 3 0

After eating/coughing 1 0 2 1

Before donning gloves

116 56 22 3

After handling soiled equipment

295 0 235 0

To prevent cross-contamination

14 13 1 1

After other activities 2 1 10 2

Total 439 73* 273 4*

*Some actions fulfilled more than one requirement16

Frequency of Hand-washing Actions After Handling Soiled Equipment

Equipment Chain (n=25) Independent (n=8)

Required

Action

Action

Performed

Required

Action

Action

Performed

Deli-case handle 178 0 154 0

Scale 73 0 49 0

Slicer knob 24 0 19 0

Refrigerator handle

16 0 13 0

Fryer 4 0 0 0

Total 295 0 235 0

17May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

Hand-washing Benchmark• Hand-washing benchmark per hour per employee =

• Benchmark observed = 30 times/hour

• Previously reported benchmarks:– Delicatessens = 6 times/hour1

– Schools = 11 times/hour 2

– Restaurants = 29 times/hour2

Reconfiguration of job duties and/or effective sequencing of work tasks3,4

Total # times hands should have been washedTotal # hours observed

1Paez et al. 2007. Food Prot Trends 27(11): 903-908.2Strohben et al. 2008. J. Food Prot 71(8): 1641-16503Clayton and Griffith. 2004 Br Food J. 106(3): 211-74Green et al. 2006 J Food Prot 69(10): 2417-23

May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

Frequency of Occasions Cleaning & Sanitizing Actions were Required and

Performed Adequately

Surface type Chain (n=25) Independent (n=8)

RequiredAction

Action PerformedAdequately

RequiredAction

Action PerformedAdequately

Food contact surfaces/utensils

11 11 0 0

Non-food contact surfaces

0 0 0 0

Total 11 11 0 0

19May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

Surface type Chain (n=25) Independent (n=8)

Attempted Adequate Attempted Adequate

Food contact surfaces/utensils

100 13 11 0

Non-food contact surfaces

11 0 0 0

Total 110 13 11 0

Frequency of Additional Occasions Cleaning & Sanitizing Actions were Attempted or

Performed Adequately

20May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

Frequency of Additional Cleaning & Sanitizing of Food Contact Surfaces/Utensils

Surface type Chain (n=25) Independent (n=8)

Attempted Adequate Attempted Adequate

Work surface 24 0 4 0

Cutting board 1 0 2 0

Dish 1 0 0 0

Utensil 5 0 0 0

Knife 6 1 1 0

Slicer 62 12 4 0

Sink 1 0 0 0

Total 100 13 11 0

21May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

Conclusions

• Notational analysis enabled recording and identification of common sequences of actions (as well as deviations) for deli meat, deli cheese, and deli salad preparation to be used in a risk assessment model.

Directly implemented in the L. monocytogenes in Retail Delicatessens Risk Assessment model

22May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

23 23May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

Conclusions (continued)

• Results demonstrated that food employees engaged in a large amount of contact between objects, gloved hands, and RTE food highlighting potential risk mitigation measures.

• To better understand variability in actions (inter- and intra-store), a larger study is needed with: – A larger sample of stores (both chain and

independent) distributed in a wider geographical range and

– Multiple coders

24May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting

• Supported by – Joint Institute for Food Safety and Applied Nutrition

– University of Maryland

– an appointment to the Research Participation Program at the CFSAN administered by the ORISE through an interagency agreement between the U.S. DOE and the U.S. FDA

• Thanks to– Food Marketing Institute– Caren Kieswetter, FDA/CFSAN

May 22nd, 2013Interagency Risk Assessment--Listeria monocytogenes in Retail Delicatessens Public Meeting