Food Protection Trends - March/April 2021 - 188

TABLE 2. Sanitation practices used in each of the three facilities in Group 1 that had no
Listeria spp. detected in FDA environmental samples
Facility

Written
sanitation
procedures

Foot-baths

Flow of processing
to prevent crosscontamination

Yes

Full cleaning and sanitizing of food contact and
environmental surfaces throughout production and at
end of each production day with varying cleaning and
sanitizing chemicals.

Not observed

Yes

End of production debris removed, and food contact
surfaces scrubbed with brushes, warm water and
soap. Cleaning and sanitizing conducted again before
production. Utensils and removeable parts cleaned and
sanitized. Floor drains foamed three times a week.

Not observed

Yes

Not observed

Cleaning and sanitation practices

Entire area cleaned every four hours with foaming system.
Equipment disassembled washed, rinsed and sanitized.
Fixed equipment rinsed to remove debris, foamed,
scrubbed, hot water rinsed and sanitized.

Observations
Group 1, sanitation controls. All three facilities in group
1 (A, B, and C), which had no Listeria spp. detected in the
environmental samples, routinely conducted environmental
and finished product testing. All three facilities also provided
frequent training for their employees on CGMP and food
safety. Table 2 summarizes additional sanitation practices
used in these three facilities.
Facility A had the most practices to minimize crosscontamination among the three facilities in group 1. The flow
of raw materials, finished product, and employees through
the facility was controlled by sanitation procedures. The
raw material receiving area, rinsing and salting area, curing
cooler, and smoking room were separate from the smoked
fish blast chiller and smoked fish processing area. Employees
were restricted from moving among the various processing
areas. Employees wore facility-provided boots, hair nets,
and gloves in processing areas. To verify sanitation controls,
facility A collected environmental samples weekly from six
food contact surfaces and analyzed them for Listeria spp.
The investigator's review of the facility's own environmental
results showed no positives for Listeria spp. Facility B cleaned
by scrubbing equipment with brushes and detergent and
then by sanitizing both before and after production.
Group 1, insanitary conditions. Facility C had condensate,
a common source of Listeria, dripping from a cooling unit
onto exposed RTE finished product of cold-smoked salmon,
which is an egregious sanitation deficiency. As an immediate

188

Food Protection Trends March/April

corrective action, product was no longer stored under the
condenser and management contacted a contractor to assess
the cooling unit. The processor promised further corrective
actions. The investigator did not describe the final disposition
of the product; however, the adulterated product should have
been destroyed or diverted to a nonfood use.
Group 2, environmental sample locations. The environmental
sample results from the five facilities in group 2 (D, E, F, G,
and H) showed that Listeria spp. were detected without
L. monocytogenes; this indicated that nonpathogenic stains
of Listeria were isolated from sites that were in close contact
or direct contact with product. These sites consisted of a fish
brine rack, pin bone remover belt, handles of dry cure mixer,
a basin of a stainless steel sink used for rinsing fish, and a
crack in a processing room floor.
Group 2, sanitation controls. Facility D had the most
documented practices to minimize cross-contamination
among the 15 facilities inspected and sampled. The cleaning
and sanitizing program included written procedures for
equipment, coolers, tables, floors, walls, ceilings, drains,
condensers, drip pans, etc. with monitoring records for
specific daily, weekly, and monthly tasks. The food contact
surfaces in the processing rooms were wiped down with 200
ppm of quaternary ammonia before employee breaks and
lunch, with a full wet cleaning and sanitizing after production.
Coolers were emptied and then cleaned and sanitized weekly
(floors and walls) and monthly (ceilings and evaporators)
by a designated cleaning crew. Employees wore clean lab

Food Protection Trends - March/April 2021

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