A "Listeria Control Manual for Smoked Seafood Processors" was developed and adopted in the Association of Food and Drug Officials' Model Code for Cured, Salted and Smoked Fish Good Manufacturing Practices. Six full-day workshops were held across the country from 2003 to 2006 that reached 300 individuals from RTE seafood or other food-processing firms to help them identify effective controls. A follow-up evaluation was conducted to assess what Listeria control practices 25 RTE seafood processors had actually implemented. Of those surveyed, 80 percent of the firms had implemented new Listeria controls or enhanced existing controls in the six-to-eight month period after the 2003 workshops. All firms conducted employee training, and 80 percent changed or implemented new sanitation procedures critical to Listeria control. Half of the firms modified their processes, upgraded equipment or processing areas, or made changes in their Listeria testing program. Eleven firms of various sizes reported investing from $1,200 to $75,000 on new Listeria controls, and estimated that the average annual cost for their Listeria control program would range from $6,000 to $84,000. Seven research papers have been published in the Journal of Food Protection from 2002 to 2006, and evaluation data was published in Food Protection Trends in 2006. Technical assistance was provided to an FDA team conducting a Listeria risk assessment for smoked seafood in 2005 and 2006, including a site visit to a New York fish plant. Ken Gall and Martin Wiedmann were both invited to give technical presentations on Listeria control at the International Smoked Fish Conference held in Anchorage, Alaska, and attended by 100 seafood businesses and regulators in 2007. In February 2008, the FDA issued draft guidance for the control of Listeria monocytogenes in ready-to-eat foods. This guidance outlines control measures for industry that are very similar to the ones that we developed for the smoked seafood industry.
In 2011 Dr. Weidmann and I were invited to provide an expert technical review of a draft of FDA’s Quantitative Assessment of the Risk to Public Health from Listeria monocytogenes in Smoked Finfish Draft Report and Model. Technical comments on FDA's risk model, its inputs and recent advances in Listeria controls were provided to the agency for consideration prior to issuing a final risk assessment report.
impact statement issue
Listeria monocytogenes is a bacterial pathogen that is widespread in the environment and can cause severe illness and death in high-risk consumers. Over the past decade regulatory programs have intensively sampled these foods, and manufacturers have had to institute costly recalls when Listeria monocytogenes has been found in their products. A number of New York firms and others around the United States have not survived the expense and regulatory scrutiny associated with these events. In order to remain in business, processors of RTE seafood and other food products must implement specific new procedures and policies to prevent contamination during the handling and processing of these products. Up until the mid-1990s, little was known about the ecology of Listeria monocytogenes in the food processing plant environment, making the implementation of effective control strategies difficult and largely ineffective.
impact statement response
A series of research projects and outreach extension initiatives were conducted by New York Sea Grant's seafood specialist Ken Gall and Cornell University food science professor Martin Wiedmann from 1998 through 2006 to help smoked seafood and other processors of RTE seafood products understand the ecology of Listeria in the processing environment. Four consecutive research projects that have utilized DNA molecular subtyping methods used in Wiedmann's Food Safety Laboratory at Cornell have helped smoked fish, crab, and crawfish processors understand the scope of this problem and identify effective control strategies. At least 16 different processing plants around the country have directly participated in these projects to characterize the Listeria contamination pattern in their plant environment and evaluate the effectiveness of various prevention and control strategies. Funding support for these initiatives was obtained from New York Sea Grant and from the National Food Safety Initiative of the Cooperative State Research Education and Extension Service of the USDA. Other collaborators included colleagues from two industry trade associations, the Food Processors Association, and the National Fisheries Institute, and colleagues at the University of Delaware, University of Maryland, Virginia Tech University, and Louisiana State University.
impact statement summary
Listeria monocytogenes is a bacterial pathogen that is widespread in the environment and can cause severe illness and death in high-risk consumers. This pathogen is a particular concern for processors of ready-to-eat (RTE) seafood products, such as smoked fish. Current state and federal government regulatory policy does not allow Listeria monocytogenes in any RTE food. A series of research projects and outreach extension initiatives were conducted by New York Sea Grant's seafood specialist Ken Gall and Cornell University food science professor Martin Wiedmann from 1998 through 2006 to help smoked seafood and other processors of RTE seafood products understand the ecology of Listeria, food processing, and effective controls. The Association of Food and Drug Officials adopted the control strategies that were developed in collaboration with the smoked-fish industry. The results of this work were shared with RTE seafood processors in a series of five workshops conducted across the United States in 2003, and workshops were conducted in 2006 and 2007. A follow-up evaluation to the 2003 workshops documented the types of controls and resources that RTE seafood firms had adopted as a result of this effort. Technical assistance was provided to an FDA team that is conducting a special Listeria risk assessment for smoked-seafood products in 2005 and 2006.
