IKE Scenario 02-03 Sampling Ready-to-Eat (RTE) Products:
FSIS is committed to assuring both food safety and food security in all meat and poultry products. This includes collecting samples whenever the in-plant inspection personnel receive a sample request form.
Due to the large number of calls on the new RTE directive received by the TSC, this IKE was written to help clarify information concerning RTE sampling.
You are the IIC of an establishment that produces a variety of ready-to-eat (RTE) products. You have just received a sample collection request (FSIS Form 10,210-3 Requested Sample Programs) with the instructions to collect a RTE product sample. Being an avid IKE reader, you are familiar with the definitions provided in FSIS Directive 10,240.3 (please review IKEs # 18-02,19-02, 20-02,and 21-02) and have a good working understanding of the directive and flowcharts. However, you are still unsure of what product you should best sample because the plant makes products that you believe should be in the intensified sampling program. You decide to contact the Technical Service Center (TSC) for clarification.
After introducing yourself and explaining your question, the Tech Center staff officer walks you through a series of questions you can ask yourself to better prioritize which product(s) to sample:
The first question the staff officer poses is whether or not the establishment produces “non-targeted” product. You reply that, yes, these types of product are produced-but not exclusively. The staff officer then reminds you that these non-targeted products should not be collected as samples, but since the establishment produces other RTE products, a sample does need to be collected. The staff officer also reminds you that at this point in time the policy is to collect a sample any time a RTE sample is requested, regardless of any verification testing done by the establishment. The TSC representative then assures you that you will be informed, in the event of any policy change in the future.
The second question the TSC staff officer asks you is whether the establishment produces any products that are not formulated or distributed in a manner to prevent the growth of Listeria monocytogenes (Lm). The staff officer reminds you that these would be considered higher risk products than products that were controlling Lm in this manner. You inform the TSC representative that the establishment does produce such products.
The TSC then asks you to keep these products in mind and to break the products down into three categories: Deli or deli-type, hot dog or hot dog-type, and all others (except non-targeted). The staff officer explains the risk of the product is reduced in the above order, i.e., deli (-type) products are riskier than hot dog (-type) products, which are riskier than any of the other RTE products. The staff officer further explains that you should follow through with this thought process because we want to sample the RTE products that pose the highest risk. You inform the staff officer that this establishment produces several deli products that are not formulated or distributed in a manner to prevent the growth of Lm and that you now understand that these products are the types of product that you should be sampling in this facility.
However, another establishment in your patrol only produces frozen entrees. According to the above thought process, this would fall under the “other” RTE products that are distributed in a manner to prevent the growth of Lm. They also have a science-based program and share their data with you. You are not sure whether you should collect a sample in this facility if you get a sample request. The TSC again explains that the current policy is to always take a RTE sample of the product posing the highest risk that the establishment produces when you receive a directed sample request. And, in this case the inspector should submit a sample of the frozen entrée when they receive a sample request form.
In wrapping up the phone conversation, the TSC staff officer reminds you of two other things. The first being that you should remember to enter the unscheduled procedure in your electronic PBIS schedule under the 05B02 code. The second thing that the TSC reminds you of, is if the sample does come back positive, you are to inform the plant, document a NR (under 03 procedure code), and notify your supervisor. Your supervisor will work with the District Office and OFO Headquarters in determining a verification testing procedure for that establishment to verify the corrective and preventive measures. Finally, the staff officer thanks you for your call and offers their services if you have any further questions.
Note: The Technical Service Center can be reached at (800) 233-3935 and is available form 6:00 a.m. to 5:00 p.m., Monday through Friday, except on government holidays.