Your question is very perceptive.
The issue of permission with respect to 100 listeria per gram is generally qualified with a statement that the listeria cannot grow in the products in which 100 are allowable, so whether it's 100 at the beginning of shelf life or 10 days later, it's only going to be 100. For those products in which listeria can grow, the Canadian regulation is exactly the same as the American regulation--zero.
Now, as of the first week of February 2008, the USDA published in the Federal Register a notice that it would allow the presence of 100 listeria in ready-to-eat products in which the organism would not grow. In the United States, as you well know, they have two agencies responsible for inspection. We only have one, thank God, at the federal level, the CFIA. They have the FDA and the USDA. The USDA is responsible for meat and poultry, and the FDA is responsible for dairy and fish, so in USDA-approved products, or registered products, you can have 100 listeria per gram, but not in FDA products.
As for the threat associated with that number of organisms, I think the Canadian position was far more mature, because when you consider a zero tolerance for listeria in food, it's just as you said: wherever you look, you'll find listeria. In fact, if we have more than 10 people in here, one of us--well, maybe more than one of us--is carrying listeria. What?
You know, this really annoys me. We are moving more and more and more towards end-product testing. We cannot inspect safety into food. We can't test safety into food. We have to synthesize it into food. We have to produce the food that we know is safe. The American car manufacturers learned a long time ago that preventive programs that they put in place--the Japanese learned it very well--yielded cars that were safe when they hit the road. That's the way the food has to be produced, by using HACCP programs. That way, you know when the product comes off the line that the product is safe to eat.
In terms of end-product testing, when you have an organism like listeria that occurs in foods at 0.1%, in order for end-product testing to be of any value whatsoever, you have to test at least a thousand in order to find one.
What the devil is that going to tell you? Stop the problems from developing in the food safety system, so that the end products are safe to eat. When you don't suspect there's a problem, you're not going to be able to test those products and get any indication of what proportion of the total is likely to be contaminated.
This traceability issue is another one that's not an excuse for laxity in food safety systems. Recalls and traceability are after the fact, folks. Let's build safety into the food we manufacture, each and every day.
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