Food Protection Trends - May/June 2020 - 210

earlier), opening up more potential for liability. To mitigate
risk, Hermida recommended being proactive by implementing
strong and effective preventive programs for microbiological
pathogens and taking (and documenting) aggressive corrective
actions when pathogens are found.
Break-out group exercises
After the formal talks, the symposium participants were
divided into groups to participate in exercises. The goal of
these exercises was to apply what they had learned during the
day by discussing microbiological testing programs that could
be developed and used as part of a FSMA food safety plan for
an RTE food product. Each group was assigned a different type
of RTE food product (frozen cheesecake, fresh-cut melon, dry
dairy powders, deli salad) and instructed to perform a hazard
analysis for biological hazards, discuss preventive controls, and
then consider criteria for a microbiological testing program.

An example of the conclusions reached by one of the groups
(facilitated by Michelle Danyluk) is shown in (Fig. 6).
Beyond their conclusions (such as those shown in (Fig. 6)
the group exercises were informative in other ways:
*	 Conducting a hazard analysis and identifying preventive controls is not trivial, and even experts require
significant time and background resources to complete
these activities.
*	 There can be many different "right" answers for how
microbiological testing can be useful in a food safety
plan, and even those with considerable experience
with a particular product type might come up with
different strategies.
*	 The cost, time, and practicality of preventive controls and
microbiological testing strategies are important factors
that might be ignored in a theoretical exercise but must be
considered in real-life.

RTE fresh-cut fruits (e.g., cut melon, sectioned grapefruit, sliced pineapple)
Question 1. What principles and criteria should a company apply in determining the need for and in designing an
effective microbial testing program to verify that processes are effectively controlling microbial pathogens?
a.	 What pathogens are associated with the food or ingredients?
There is variability in the pathogens (hazard) and prominence (likelihood of occurrence) that is dependent on
a number of factors, including commodity, farming system, region and other variable events (such as season or
weather); poor worker hygiene practices can contribute to viral or parasitic risk.
b.	 Are the ingredients likely to be contaminated?
Yes, again depending on commodity type and its attributes (i.e., pH, water content, rind, etc.)
c.	 Are there robust processing control procedures such as a kill step or other reduction methods/controls?
No
d.	 Is there a potential for recontamination from the handling or the environment?
Yes
e.	 Does the product support survival or growth?
Depends on the pH of the product
f.	 Is this product meant for higher risk population?
Product is made for the general population, but high-risk populations may purchase or be served in hospital or
nursing home facilities.
g.	 What is the shelf life of the product?
The typical shelf life of the product is 1 to 2 weeks.
Question 2. Are there situations in which testing other than for pathogens or indicator organisms (e.g., enzymes),
would be an appropriate verification activity?	
Yes, monitoring of cold chain for fresh-cut produce for which time and temperature have been identified as needed for
food safety and verification and monitoring of wash systems.
Question 3. Are there situations where (microbial) verification testing would not be necessary if there is evidence that
the appropriate treatment was, in fact, applied?	
Not likely, since there is no "kill step applied." Supplier verification may include pre-harvest testing or testing at receipt
for presence or absence of pathogens (as per commodity type and other considerations).

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Food Protection Trends May/June
Food Protection Trends - May/June 2020

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