Food Protection Trends - January/February 2018 - 60

cross-contamination on fresh pork. Delhalle et al. (12)
reported concentrations of E. coli/coliforms ranging from
0.2 to 1.2 log10 CFU/g on fresh pork cuts from Belgian meat
plants. Mann et al. (24) validated time and temperature
combinations that prevented Salmonella growth during
cold storage, reporting no increase of Salmonella in pork
cuts or ground pork held below 4.4°C for 72 h, or in ground
pork held at 10 and 7.2°C for 24 and 32 h, respectively.
Smaller processors conducting fabrication operations at
non-refrigeration temperatures must ensure that fabricated
and processed product is moved to cold storage as quickly as
possible to limit microbial growth.
Pork carcass and product chilling is critical to inhibiting
bacterial growth. Nonetheless, nearly the same number
of establishments reported storage of finished products
alongside raw products in facility refrigeration areas (9/19;
47.4%) as reported that raw and finished products were not
stored alongside one another (10/19; 52.6%). Pork carcasses should be chilled rapidly, ideally to below 4°C surface
temperature within 0.5 to 2 h. The FSIS has recommended
that coolers be capable of lowering carcass internal temperatures to 4.4°C within 24 h of the carcass being moved into
the cooler (44). Bolton et al. (9) reported increases (0.7 to
0.9 log10 CFU/cm²) in total viable counts (P < 0.05) during
chilling of post-eviscerated, washed carcasses. These and
other researchers have indicated that several parameters of
chilling, including air temperature and humidity, air velocity,
carcass ingoing temperature, and spacing between carcasses, should be controlled to maximize chilling rate so as to
obtain the greatest microbial growth inhibition, and may be
executed as a CCP within a HACCP plan (9, 34). The U.S.
Food and Drug Administration (FDA) considers many fresh
meat items, including fresh cut pork and some cured and
uncured sausages, as requiring time/temperature control for
food safety, in alignment with USDA-FSIS-recommended
procedures for sanitary production of these products (15, 37,
38). Best practices for the storage of fresh beef products and
further processed ingredients directs processors to account
for the storage of fresh/raw meat and non-meat ingredients
versus finished product storage, indicating that finished products not in final packaging should be separately stored from
carcasses and fresh products (4). Pork processors producing
NRTE products should provide systems to prevent/reduce
such cross-contamination between carcasses or fabricated cuts,
and further processed pork products, whenever possible.
Microbiological sampling for carcasses and
finished products
The incorporation of routine carcass and/or product
microbiological sampling has been described for beef safety
management as an effective food safety systems component,
through the assessment of microbiological hygiene status
of carcasses as well as the identification of harvest/process
environment sanitary conditions (6). Such testing assists in

Food Protection Trends January/February

the development of microbiological baselines, thus allowing
companies to apply testing data to determining process control (5). Only two of 19 (10.5%) respondents indicated that
carcasses were routinely sampled for human pathogens or
indicator organisms; these establishments reported sampling
for E. coli and Listeria, although, frequencies of carcass sampling were not provided. A slightly higher number of facilities
(3/19) reported regular sampling of finished products for
microbial pathogens and/or indicator organisms (data not
shown). Pathogenic and indicator organisms sampled for by
respondents included L. monocytogenes, Salmonella, and E.
coli. In all cases, respondents identified non-detectable (< 1
CFU/sample) as the acceptable outcome of pathogen testing
for finished products. Only one facility detailed corrective actions for non-conforming finished product microbiological
sampling results: re-cooking of product or product condemnation/destruction. The number of facilities engaged
in finished product sampling that reported using company
personnel and facilities for microbiological sample analysis
was equal to the number of those contracting a third-party
firm (17.6%; 3/17). The majority of firms (57.9%; 11/19)
did not indicate that finished product testing was applicable
to their firm's operations, or chose not to provide information (data not shown).
In a microbiological baseline assessment of pre-evisceration and post-chilled pork carcasses, USDA-FSIS reported
Salmonella prevalence of 1.66%, whereas generic E. coli were
detected on 96% and 12% of pre-evisceration and post-chill
carcasses, respectively (40). Thus, Small and Very Small
establishments conducting testing for pathogens may utilize
testing for indicator organisms to determine the antimicrobial impacts of food safety interventions. Routine testing for
microbiological organisms (indicators, pathogens) may be
useful for allowing establishments to verify process control to
regulatory agency officers (41). Additionally, although only
a small number of respondents indicated testing for L. monocytogenes on finished product, USDA has recommended that
Salmonella testing be utilized when conditions warrant such
data collection in Small and Very Small facilities producing
RTE products. Such recommendations could be applied to
manufacturers of NRTE further processed pork products as
well, to determine process control or impacts of processing
and/or interventions on finished product safety (43).
CONCLUSIONS
In April 2015, FSIS released guidance designed to
assist small meat and poultry plants to meet validation
requirements of Title 9 of the Code of Federal Regulations
(CFR) §417.4 (47). FSIS noted that some establishments
had not completed adequate initial validation with
respect to translating the critical operating parameters
(COPs) from scientific and technical resources used in
HACCP plans to validate interventions and prerequisite
programs. Establishments were directed to engage in

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