Scenario 03-02: Salmonella Performance Standard Sampling: 02/27/02
PART 1: The Office of Public Health and Science (OPHS) schedules Salmonella Performance Standard testing. The Pathogen Reduction Enforcement Program (PREP) sends a schedule report to the District sampling coordinator notifying them of all the establishments within their jurisdiction that have been mailed forms and supplies for the Salmonella compliance testing program. The IIC (yourself) at an establishment receives supplies (shipping containers and sampling supplies) from the Eastern Laboratory for Salmonella Performance Standard sampling set for cows/bulls. Two weeks go by without any FSIS 10,210-7 forms arriving.
What do you do?
First try to call the 1-877-709-1982 supply number. Following the directions on the voice mail recorder, you provide the information necessary to inform authorities that the forms have not been received and could be missing. A few days go by and you discover that forms have not arrived, nor have you received a phone call from anyone regarding the situation. You attempt to call the supply number again but this time you receive a recording that indicates the mailbox is full.
What do you do next?
Call the District Inspection Coordinator to report the problem. The District Inspection Coordinator contacts the Technical Service Center to inform them of the problem with the supply number. The Inspection Coordinator and Processing Staff Officer begin to trouble-shoot by reviewing PREP and PBIS information related to the establishment and discover a difference in the mailing address*. OPHS is contacted and a new set of forms is immediately generated and "FedEx’d" to the IIC’s attention at the establishment. The PREP database is corrected to reflect the proper mailing address to ensure that forms will be received appropriately in the future.
|Note: There are many reasons why sample request forms may not have been received such as: the mailing contractor incurred a problem that went undetected, the plant misplaced the inspector’s mail, or a relief inspector filed the forms and forgot to leave a note for the IIC, etc.|
PART 2: The new set of forms arrives on Friday. This establishment is a large beef (cows/bulls) slaughter plant with two shifts. Monday is a holiday. The establishment is slaughtering today and Saturday. As the IIC, you randomly select when the daily carcass sample for the Salmonella Performance standard testing will be collected. The random time selected for the sample to be collected is on second shift, which is after the last Federal Express pickup for Friday.
When do you collect the samples? When do you mail the
You select your sample as described in Section Three of FSIS Directive 10,230.5 on Friday and perform the sponge sampling the next business day that overnight shipping can occur. In this case that would be Tuesday as Monday is a Holiday and Federal Express has no Sunday delivery.
How do you complete the collection form?
If you record the actual date the carcass* was selected in the collection block on the form, the sample will be discarded as "Sampling Instructions Not Followed" (i.e., sample not shipped the same day as collected). You record the date the carcass was swabbed in the collection block, rather than the date the carcass was selected.
|Note: Any time the carcass is not swabbed at the time of selection, the carcass would be held under your (FSIS's) official control in the cooler until sampled.|
For tracking purposes, remember to always use sample request forms sequentially by ascending numerical order. Considering weekend logistics, you know multiple samples will be submitted on Tuesday. For tracking purposes, it is important to record the actual times the samples were collected (swabbed). You sign the forms and send the three samples* to the appropriate lab as described in FSIS Directive 10,230.5.
|Note: Although three sample request forms (for Friday, Saturday, and Tuesday) were submitted with the same collection date, the lab will analyze all three samples because they are aware that multiple samples can be submitted by inspection personnel with the same collection date, especially following weekends and holidays.|
Once completed set reports are issued, inspection personnel can correlate multiple samples with the same collection date, sequentially, simply by the form number, i.e., Friday’s sample will have the lower form number of the three samples submitted.
What do you do next?
As required by FSIS Directive 10,200.1, log onto the LEARN application within 24 hrs. to determine whether the samples you submitted were received and not discarded. You continue to sample until you receive notification of a full set. *
|Note: PREP generates a Full Set Report when enough samples have been received at the laboratory to complete the set. Occasionally samples may be discarded after receipt due to laboratory technical problems. Although infrequent in occurrence, these technical problems may require additional samples to be collected after the Full Set Report is generated. The forms and supplies should be sent back to the laboratory when the completed report is reported via LEARN.|
PART 3: The completed set is posted on LEARN and this "first set" or "A set" has failed. This is the second "A set" failure at this establishment. The prior set or "B set" passed with two positives in the fifty-eight-sample set. The District Office sends you (IIC) a copy of the letter addressed to establishment management indicating that the establishment failed to meet the performance standards.
You know the Establishment has made minor modifications to the pathogen intervention steps in their process, but they continue to have problems with the staffing of their slaughter lines. Their generic E.coli testing results indicate a continual problem with maintaining process control.
What do you do next?
As the IIC, you decide to assess the data available and create an action plan. You review the NRs* in the file, PBIS Establishment summary data, PREP data, and plant records associated with SSOPs and HACCP. You evaluate the data to determine if trends exist to direct your subsequent actions. You correlate with your in-plant inspection team to ensure that they understand the action plan you have developed.
|Note: You want to pay particular attention to the ISP procedures and elements 05A02, 03J, 01B, 01C. You also want to carefully analyze the corrective actions the establishment has implemented to date and what the establishment proposes to do in the future to prevent recurrence of failures related to the food safety system.|
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