Almost all plants responded to the Notice by reviewing their HACCP plans and discussing the Notice internally among plant personnel.

In addition, over half of the plants reviewed their test data and conducted tests for Lm.

Almost all plants are now listing Lm contamination in their hazard analyses for all their RTE products.

Close to two thirds of the plants modified their hazard analysis. For example, Lm was featured and listed for examination in more places in the process. Assessment and control measures on Lm or Lspp. were added. Sanitizing of areas for final product preparation was added.

Almost all plants responded to the Notice by documenting their reassessment in their hazard analysis.

The majority of plants also discussed their determinations with FSIS inspection personnel.

About one-fourth of the plants decided not to modify their HACCP plans after the reassessment, basing this decision most commonly on their in-plant testing data. That is, plants felt that Lm was under control with their current operations. However, most of these plants have found Lspp. or Lm in their testing since the reassessment; FSIS product testing at one plant was positive. Only the plant that had a positive finding through FSIS product testing reassessed its HACCP plan. (Plants found their positive results in environmental testing, rather than in product testing. The latter finding requires corrective and preventive action and possibly reassessment.)

Some plants also determined that they had sufficient preexisting CCPs to control for microbial contamination and did not need to modify their HACCP plans specifically for Lm.

Some plants determined that Lm contamination was a sanitation issue that did not need to be addressed in the HACCP plan. In fact, one plant conducted a hazard analysis and determined that there may be a possibility of Lm contamination, but after review at the corporate headquarters, management determined that Lm was adequately addressed in their SSOPs.

More than a third of plants found, in their own testing, Listeria contamination since they had reassessed their HACCP plans to comply with the Notice in 1999.

Half of those plants that found Listeria contamination (L spp.) after the original reassessment did not again reassess their HACCP plans.

Over two-thirds of the plants had reviewed their SSOPs, with some rewriting their SSOPs. Few moved sampling for Listeria from their SSOP to their HACCP plan; in fact several moved Listeria testing from their HACCP plan to their SSOP, as they felt comfortable that it was under control.

FSIS personnel supplied a list of plant actions taken outside the HACCP or SSOP plans. Almost half of the plants had taken actions, including: training; testing of environments and products (by over two-thirds of the plants) ; adding sanitizers; developing abatement programs; adding floor foamers and citric acid; modifying packaging rooms; footbaths, handwashing, and special clothes; repairs to improve sanitation; new construction; and increasing anti-microbial additives in products.

Only a very small proportion of plants used additives as anti-microbial agents in their products.

Only one out of the five plants that used additives addressed this use in their HACCP plans.

FSIS personnel supplied information on all the ways each plant sampled for Listeria. Over two thirds of the plants conducted environmental testing for Listeria. This testing was most frequently done once per week (although some plants performed tests about two or three times per day).

Less than two-thirds of the plants conducted product testing. The testing was most frequently done by plants once per quarter (although some plants conducted tests as frequently as three times per week and as infrequently as once per year). In some cases, plants would only perform product tests if environmental tests proved positive.

Only one of the plants does not test for Listeria, and cites a scientific article to support this position. Plant personnel determined that, since they exceeded the time and temperature requirements for beef jerky production, testing for Lm was not needed.