No more hot dog recalls. Unrealistic? Maybe, but the effort to eliminate Listeria monocytogenes from such products is gaining momentum up and down the supply chain. The government's new listeria-control regulations that took effect Oct. 4 require processors of ready-to-eat meat products to take strict measures to control the pathogen or face increased inspections and testing by the U.S. Department

No more hot dog recalls. Unrealistic? Maybe, but the effort to eliminate Listeria monocytogenes from such products is gaining momentum up and down the supply chain. The government's new listeria-control regulations that took effect Oct. 4 require processors of ready-to-eat meat products to take strict measures to control the pathogen or face increased inspections and testing by the U.S. Department of Agriculture's Food Safety and Inspection Service.

That's good news for retailers and their customers.

Indeed, retailers told SN that anything that makes the foods coming into their stores safer is welcome. Some particularly applaud the new FSIS rules because they're aimed at consumer packaged goods such as hot dogs and summer sausages, a category that has been prone to recalls in the past.

"Anything anybody in the industry can do to reduce even the small chance of listeriosis, and it is a rare disease, is something we all have to work toward," said Cas Tryba, food safety manager at 52-unit Big Y Foods, Springfield, Mass. "So certainly retailers are supportive of the processing industry in its efforts to add inhibitors and to make certain products listeria-static. Their efforts are well appreciated."

Tryba, who is former chairman of the Food Marketing Institute's Food Protection Committee, sees the new regulations as underscoring and amplifying the steps already taken by manufacturers.

"What processors have been doing themselves has given us a dramatic reduction in listeriosis over the last 10 years, and in the incidence of Listeria monocytogenes." Indeed, the FSIS released a report on Oct. 17 that shows a one-year, 25% drop in the percentage of samples testing positive for Listeria monocytogenes and a 70% decline compared to years prior to the implementation of the Hazard Analysis and Critical Control Point system.

That most recent, dramatic drop is the result, in part, of a directive the FSIS issued about this time last year, according to FSIS spokesman Steven Cohen.

"The directive was something we could do until the regulations [of Oct. 4] went into effect. The rules that just went into effect are consistent with the directive, and with the direction the agency has taken toward listeria," Cohen said.

He explained that processors have options, under the regulations, as to what measures they will take to prevent contamination. They can add inhibitors as ingredients or use a post-pasteurization treatment, or both. They also can add the information that they have done so to their product labels.

Interestingly, manufacturers are not mandated to take these steps under the directive. However, if they rely solely on sanitation measures to prevent contamination, they face heavier scrutiny and increased inspections and product testing by the FSIS.

Listeria monocytogenes, having first made itself known in the 1980s, is a particular threat to the food supply because it can survive at cold temperatures, and can actually create its own protective covering, making it invulnerable to many sanitation practices.

"If processors do use an inhibitor and a post-lethality treatment, that will make a big difference in the risk of Listeria monocytogenes contaminating the products they produce. It depends somewhat on what they produce as to what they'll do," Cohen said.

There has been some talk in the industry that the regulations aren't necessary because manufacturers are already operating with HACCP programs, and have proper procedures in place. On the other hand, some retailers have said the rules for processors are not stringent enough. Those who talked to SN, however, view the rules positively.

"I think the regulations are a good thing," said Mary Mulry, senior director of product development and standards, at 101-unit Wild Oats Natural Marketplace, Boulder, Colo. "The controversy, I believe, has been about the rules being overkill, going beyond HACCP, but it's an additional step that's necessary since [the industry] continues to have potential safety problems with listeria."

Mulry, as did Tryba at Big Y, pointed out that the responsibility is big at the retail level, too. Those responsibilities include making sure the vendor is following proper procedures.

"The new ruling will give us additional assurance. We're pretty comfortable with the vendors we have. We have a relatively small group of vendors we deal with, though, for natural meats. So we're pretty familiar with the universe of suppliers that are out there that meet standards," Mulry said.

Tryba seconded that thought.

"The retailer has the responsibility to contract with reputable vendors and, on our end, to handle the product properly, and ultimately we have the responsibility to educate the consumer on proper handling of high-risk foods," Tryba said.

"Many people think it's impossible to get rid of [L. monocytogenes] entirely, but having said that, we must certainly be on top of it. The best way, in my opinion, to reduce listeriosis is to eliminate the source of initial contamination. That's done by due diligence, cleaning and sanitizing hot spots, to keep it out of post-processed packages. The key element for the processors is post-processing to make sure the product doesn't get recontaminated through packaging or handling and certainly at retail, we have to make certain that things we make don't get recontaminated."

Most sources said the retailer's responsibility should involve checking out the actual manufacturing and processing facility and environment.

In fact, Tom Ford, vice president, Kay Chemical, Greensboro, N.C., said as a retailer his major concern would be identifying the pathogen at its source before it ever gets into the store. And Ford was a retailer for many years.

"That was my job at Jewel. What I used to do when I was at Jewel and at Harris-Teeter -- and what my [retailer] peers in the industry are doing now -- was work with suppliers to eradicate [pathogens] before the product gets into the system. That's the key. It means driving your own expertise back to the supplier," Ford said.

Ford, who said he sees such partnering efforts becoming more common, was corporate microbiologist at Jewel Food Stores for 12 years, and later, Harris-Teeter's food safety director. He said that assurance that the manufacturer was taking the correct steps to eradicate Listeria monocytogenes and other pathogens was clearly a major factor in whether those retail chains bought a product.

Partnering with manufacturers to ensure safe food is fairly prevalent today in the industry, other sources told SN.

The meat processors themselves are not protesting the Oct. 4 rulings, at least not vigorously. In fact, both the American Meat Institute, Washington, and the National Meat Association, Oakland, Calif., representing manufacturers, have taken a positive stance on the regulations.

"We've long advocated effective intervention and the use of inhibitory ingredients as well as post-packaging treatments. The biggest impact will be the encouragement of post-packaging intervention. It's another good process, another layer of safety," said Dan Murphy, spokesman for the AMI.

Murphy added the FSIS directive issued prior to the rules allows for more flexibility when a company is trying to identify the source of a pathogen. It aggressively encourages a manufacturing company to, in fact, look for the source, working with an FSIS inspector, Murphy said. There had been a punitive measure that was instituted if L. monocytogenes were found a certain number of times at a manufacturing site. Those previous disincentives to identify the pathogen have been eliminated in the new rules.

Rosemary Mucklow, speaking for the National Meat Association, said the rules are a positive step and she praised the FSIS for the amount of accompanying information it has provided.

"The listeria regulation is based on science. While we regret that it took USDA longer than anticipated to get the information to the industry, they worked hard to meet with small and very small firms, and to explain exhaustively how the new rules would be applied. I attended a day-long meeting in Oakland, on Saturday, Oct. 4, with senior FSIS officials leading the presentation and discussion. The room was jammed with nearly 200 people. The officials answered every last question -- we were there till 5 o'clock, which is unprecedented," Mucklow said.

FSIS held five such meetings across the United States, and has made other outreach efforts during the last few months.

Mucklow, however, said the USDA has not, in any of the meetings, addressed the subject of recontamination at retail level.

"I am concerned about service delis," she said. "Listeria is ubiquitous, and [having] raw products alongside RTE products presents a great opportunity for this organism that continues to grow at refrigerated temperatures."

Where's L. Monocytogenes?

Luncheon meats historically have had the highest prevalence (%) of L. monocytogenes contamination among all ready-to-eat meat and poultry products:


Cooked, Roast Corned Beef

Sliced Ham & Luncheon Meats

Hot Dogs/Small Cooked Sausages

Large Cooked Sausages

Cooked Poultry Products



































































SOURCE: USDA Food Safety and Inspection Service