Industry Listeria Group Response to EC Consultation on L. monocytogenes (Lm) Criterion 1.2b

Digital download of the Industry Listeria Group  (established by CFA in May 2021) response to EC Consultation on L. monocytogenes (Lm) Criterion 1.2b, submitted on 1st May

The Technical Summary is co-badged with CLITRAVI, ECFF, EUCOLAIT, Industry Listeria Group and CFA.

This is a free digital download.  The submission references documents within the CFA Listeria Collection

Summary text response:

Current law is effective when enforced. It is assured by enforcing adherence to HACCP-based principles/GHP/Guides/guidance and best practice (including shelf life), action plans, and requires continuous compliance verification by FBOs, customers, third party auditors and CAs. This means that foods produced in this way will automatically fall under 1.2a and not 1.2b. Epidemiology shows clear food safety benefit of this and is, we contend, sufficient to fill any perceived legal gap, so no new legal Lm limit is necessary. The proposals are a move by EU away from risk- to hazard-based law & from science, taking no account of differing virulences of Lm strains, published QMRAs or multifactorial listeriosis mitigation analyses.

Proposal text clarifications needed:

•             Footnote (2): ‘absence’ must change to ‘not detected’ (ND). Non-detection does not guarantee absence. This is a technical wording error

•             ‘the values observed’ referred to are those from by CA testing, not done by the FBO. Any detection by the FBO needs to be supported by evidence of criterion 1.2a compliance

•             Methods for FBOs can be validated alternatives to ISO-11290-2 or ISO-11290-1

We propose instead of 1.2b ND throughout life that:

1.      Current law must be enforced at all stages of supply and distribution as this is known to be effective in reducing listeriosis (One Health data for Ireland & UK)

2.      Failing this, a quantitative limit of 10 or 20 cfu/g as defined by EN/ISO 11290-2 throughout life would reflect public health and sustainability policy needs without disincentivising FBOs from carrying out monitoring testing so reducing control.

See our [Industry Listeria Group’s] Technical Summary document appended for more detail including on enforcement and compliance issues (e.g. reformulation to achieve 1.2b compliance leading to criterion 1.3 being applicable), best effective practice production environment controls and efficacy verification, and shelf life differences for comparable products on the European market.