FSMA Fridays: FDA Listeria Guidance (Part Four Of Five)

View the entire webcast or read part one, part two, and part three of this series

In part three of FSMA Fridays: FDA Listeria Guidance, SafetyChain Software’s VP of Marketing, Jill Bender and The Acheson Group’s (TAG) CEO and Founder Dr. David Acheson discussed the FDA’s Listeria Guidance as well as zones one through four in controlling environmental pathogens. Here, in part four, Bender and Dr. Acheson will continue their conversation detailing the FDA’s Listeria Guidance.

Jill: Will the FDA offer a free pass on the first Zone 1 positive?

David: Yeah, this is to me a very interesting question that the FDA's brought up into the guidance document. Let me back up a little bit; for those of you who haven't read it, there are a couple of very nice flow charts in the guidance document and what to do if you get a non-food contact surface positive. They've got this nice flow chart which gets at that. They've got some good information around what to do with that. Then there is an interesting section on what do you do if you get a positive on a food contact surface. And one of the tables and figures that are in the guidance documents gets into this and it kind of leads you through, progressively, what you would do if you got a food contact surface positive.

One of the questions that pops up is this: if you're doing routine sampling, you've got a positive on a food contact surface for Listeria species, and yeah, everything been going fine. You're following the guidance and you've tested a Listeria Zone one during a production run. And the general tenor of the guidance document is, as I've said, the FDA is encouraging us to test Zone one. They're not, in my opinion, encouraging us to test Zone one and hold the product. They're kind of saying "Test Zone one and let it go." And in their flowchart, supposing you get a food contact surface Listeria species, just differentiate, Listeria species positive, first positive. And the recommendations they make are totally appropriate, logical, make sense. You clean the area and you retest the food contact surface, surrounding area, during the next production cycle and you conduct a comprehensive investigation.