The whole is greater than the sum of its parts. Every once in a while, issues so broad and so important span different food groups and prompt the various trade associations to join forces to more effectively tackle a task too daunting for any one association to address alone. In this case, it’s Listeria monocytogenes. Again.
In 2003, a group of trade associations (http://bit.ly/1O0r6jf) were experiencing common struggles in helping their members address L. monocytogenes. Recognizing their common interests and concerns, they formed the Alliance for Listeriosis Prevention (ALP). The goals were for the food industry to work together to prevent listeriosis, and alliance activities had included comments to the FDA and USDA as well as citizen petitions to allow a tolerance of 100 cfu/g in foods that do not support the growth of Listeria in alignment with international (Codex) standards.
Fast forward to 2016. Have we solved issues with Listeria? No. L. monocytogenes and listeriosis have resurfaced as a major issue for food producers and regulators due to continuing outbreaks, as well as outbreaks in previously unrecognized vehicles such as ice cream and caramel apples.
Further, there have been multiple recalls associated with products sampled at retail, including several that are not considered “ready to eat” (such as frozen vegetables).
THE VALUE OF THE ALLIANCE
As FDA and USDA continued to evolve their policies on L. monocytogenes, trade associations began revamping their efforts to increase member education and vigilance on the issue and to discuss policy concerns with regulators. Within a single week in June 2015, GMA’s Science and Education Foundation, the Produce Marketing Association, and the International Dairy Foods Association all held meetings on L. monocytogenes.
While the meeting topics were complementary, we quickly realized the value in combining efforts. Thus, the idea to re-establish the Alliance for Listeriosis Prevention (ALP) was suggested. Acting as one voice would present a more powerful message, as well as better allocation of our resources. It facilitates the sharing of information so that members of our respective organizations can stay up to date on the best ways to address Listeria and keep food—and consumers—safe.
A small group rapidly reached out to our association colleagues and support for the alliance was strong. Associations representing all sectors—from meat to produce and snack foods to seafood—are actively participating. At this point, more than a dozen associations are involved.
But given the amount of work to be done, membership is not limited to associations. Individual companies also are participating, and the alliance has reached out to the Association of Food and Drug Officials (AFDO) and the National Association of State Departments of Agriculture (NASDA) in addition to FDA and USDA’s Food Safety and Inspection Service (FSIS), so that we can engage in a productive discussion about regulatory policies and enforcement.
The group operates primarily through monthly conference calls, and takes advantage of opportunities to meet during food safety meetings. The American Frozen Food Institute (AFFI), which serves as the secretariat, is updating the website (http://www.listeriosisprevention.com) with fresh information.
ALP is centered around collaboration and is an information-sharing coalition; both consumer and industry resources are being shared through the forthcoming revamped website. Previously, ALP developed and submitted comments and assisted with the development of industry guidance on Listeria.
Currently, the alliance has identified several ways to collaborate, engage its members, and work collectively in order to address the challenges posed by L. monocytogenes.
Areas that have been identified include:
- Collaborating on policy issues as appropriate, for example submitting joint comments and working together on issues that have cross-cutting interest, such as definitions of ready to eat and non-ready to eat (RTE/NRTE).
- Establishing a liaison with FDA and USDA to represent the alliance.
- Working with FDA to explore the possibility of conducting a monthly or quarterly FDA/industry meeting.
- Reestablishing the ALP website and populating it with tools that the food industry can use to manage L. monocytogenes (e.g., educational materials and guidance documents).
- Sharing educational materials, tools, and information about workshops and resources.
- Working together to determine research needs and identify resources and experts to conduct research.
GMA LISTERIA CONTROL ACTIVISM
In addition, GMA submitted comments (http://1.usa.gov/1O0rQoD) on behalf of the alliance to FSIS on “Control of L. monocytogenes in Ready-to-Eat Meat and Poultry Products” (Docket No. FSIS-2014 0033) to support FSIS’ approach on environmental testing to help combat L. monocytogenes.
Specifically, we applauded the use of Listeria spp. as an indicator that allows establishments to implement an aggressive “seek and destroy” approach. We also commended the monthly FSIS/industry meetings that allow for communication between top FSIS management and the food industry.
A second letter was submitted to FDA to share these views as well as to offer assistance as FDA revises its guidance on the management of environmental L. monocytogenes.
When the FDA Food Advisory Committee met in December 2015, GMA delivered oral comments on behalf of the alliance supporting the agency’s inclination that their policies regarding testing product-contact surfaces served to discourage the robust testing the agency desired. Several individual trade associations submitted comments that echoed the themes offered by the alliance.
In the upcoming GMA Update of QA magazine’s March/April 2016 issue, we will provide additional information on this meeting and the important implications it has for industry.
Although CDC data suggest that we’re nearing the Healthy People 2020 goal for rates of listeriosis, the continued outbreaks and recalls show that we can’t let our guard down; we need to actively address this pathogen. As such, ALP provides a forum for discussion of the policies and the science related to Listeria and will house resources that industry can use to support their food safety efforts.
The authors: McEntire is GMA vice president, science operations; Hayman is GMA director, microbiology.