cies slaughtered. Companies slaughtering more than one species must test the species with the largest volume slaughtered. Laborato- ries that conduct the analyses must use analyt- ical methods approved by a recognized scien- tific body. Results are recorded and charted in terms of CFU per surface area. If needed, FSIS takes corrective actions based on the results. Pathogen Reduction Performance Standards: Sampling to Test for Acceptable Levels of Salmonella At the regulated companies, FSIS sampling is conducted to test for acceptable levels of Salmonella in red meat and Salmonella and Campylobacter in poultry (Contamination With Microorganisms, 2023; Subpart K— Post Mortem Inspection, 2023b). These stan- dards are based on nationwide microbiologi- cal data collection surveys on these classes of products. The Oce of Public Health Science (OPHS) within FSIS determines which com- panies are to be tested and the frequency of testing based on previous company perfor- mance data. The number of samples taken for each sample set depends on the product class. Only a specified number of the samples, listed in the regulations, can test positive for Salmonella . If the first set passes, no more samples are taken at that time. If the first set fails, the company must take immediate cor- rective action, and then a second sample set is taken. If the second set of samples shows failure, the company is to reassess their haz- ard analysis critical control point (HACCP) program and take corrective action before a third set is taken. If the third set of samples fails, FSIS acts according to its Rules of Prac- tice (2023). Directed Microbiological Sampling At a frequency determined by OPHS, CSIs and public health veterinarians (PHVs) are directed to collect and process specific prod- uct samples produced by the companies and express mail the samples to FSIS laboratories. These samples could be raw ground beef to test for E. coli O157:H7 and other pathogenic E. coli , or final, finished, and packaged ready- to-eat, fully cooked products to test for Sal- monella and/or Listeria monocytogenes . Occasionally, CSIs and PHVs are directed to collect product or sponge samples of beef, pork, and poultry carcasses for national base-
line studies and/or for verifying the eective- ness of the food safety systems. The com- panies are to hold the product lots that the sampled product represent in case of positive results. In the event of a positive result, the aected product is disposed of or recondi- tioned by the company. Then that same prod- uct is on test-and-hold restriction until five compliant results occur, after which the plant may produce the product without testing. Samples Taken for Listeria monocytogenes Control Verification L. monocytogenes is an environmental patho- gen that can contaminate ready-to-eat prod- ucts after the pathogens have been addressed at a previous lethality step (e.g., usually the cooking step). If ready-to-eat products have cooled and remain exposed until packaged and the surrounding environment contains L. monocytogenes , the ready-to-eat product could be contaminated—but it gets pack- aged and dispensed into commerce. As a result, the consumer unknowingly consumes the contaminated product (without cooking and therefore killing the L. monocytogenes ) because the product is labeled as ready-to-eat. This concern led to FSIS requirements that detail procedures companies must implement in the food safety system to address this issue (Requirements for Specific Classes of Prod- ucts, 2023). Essentially, companies choose from among three alternatives: • Alternative 1: Use of both post-lethality treatment and an antimicrobial process or agent. • Alternative 2: Use of either the post-lethal- ity treatment or an antimicrobial process or agent. •Alternative 3: Use of sanitation mea- sures only. The companies choosing alternative 2 or alternative 3 must have provisions in writ- ing for product hold-and-test procedures and actions to take on positive results of prod- uct and swab samples. Companies choosing alternative 3 and producing deli or hot dog products have the greatest risk for L. mono- cytogenes contamination. Alternative 3 is the least safe of the alternatives. Therefore, FSIS requires FSIS-directed product sampling at companies that use sanitation measures only. Companies are not under regulation to fol- low these alternatives if they cook the prod- uct inside cooking bags and the products are
then cooled, packaged, labeled, and shipped while remaining inside the bags. In this man- ner, the product never contacts other food contact surfaces that could be contaminated by L. monocytogenes . The bags are opened only after purchase by the consumer. If a company continually fails tests for L. monocytogenes , an enforcement investigation and analysis ocer (EIAO) could be sent to the company to perform an assessment that could result in the recommendation of inten- sified verification testing (IVT) for L. mono- cytogenes . Then, EIAOs enter the company unannounced shortly after the company has executed the corrective actions for remedy of the L. monocytogenes contamination. The IVT is conducted to ensure that the company’s corrective actions are eective in preventing contamination by L. monocytogenes of ready- to-eat products. National Antimicrobial Resistance Monitoring System The National Antimicrobial Resistance Moni- toring System for Enteric Bacteria (NARMS) is a national surveillance system to moni- tor antimicrobial enteric bacteria that could enter the human food chain (Centers for Dis- ease Control and Prevention, 2023). When directed by the Public Health Inspection Sys- tem (PHIS), a PHV schedules a time to collect a sample of ceca contents from the cecum/ large intestine of freshly killed livestock. This sample is sent to a FSIS laboratory for analy- sis of Salmonella , generic E. coli , Campylo- bacter , and enterococcus species. NARMS is a collaborative eort of FSIS, the Food and Drug Administration (FDA), and the Centers for Disease Control and Preven- tion. In addition to monitoring antimicrobial susceptibility, microbiological and epidemio- logical research is conducted to better under- stand antimicrobial resistance. The results of these samples are nonregulatory, and as such, companies do not hold the carcasses and oal, and the results are not provided to PHVs or the companies.
Chemical Sampling
National Residue Program: Residue Sampling of Carcasses The National Residue Program is a collab- orative eort with FDA, the U.S. Environ- mental Protection Agency, and FSIS (USDA,
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