Thank you once again for the opportunity, particularly to update the committee on the government's progress on food safety.
Here with me today from the Public Health Agency of Canada is Dr. Mark Raizenne, the DG of our Centre for Food-borne, Environmental and Zoonotic Infectious Diseases.
This morning I'd like to provide a bit of context just to get started, along with a brief overview of what we've been seeing over the past year and where we are headed.
First, Canada has long had one of the safest food supplies in the world, but as with any area of public health, responsibilities for safe food and safe eating go beyond governments and industry to every one of us. The vast majority of food poisoning occurs at home from unsafe handling or preparation of food, even when the food supply is safe. From the farm to the kitchen, outbreaks can and will happen, as well as from the kitchen to the table.
[Translation]
On top of all this, we know that nature is constantly inventive and always has new surprises for us.
[English]
To ensure that we're prepared for all of these threats, we need strong links in every part of the chain, from regulation, inspection, and surveillance to education and safe individual practices. Every step on the farm-to-fork continuum is critical. For the government's part, when a national food safety threat poses a risk to Canadians, as it did in 2008, the health and agriculture departments and agencies at all levels of government must work together closely to respond to that risk.
Today I'll speak to the agency's role specifically. The Public Health Agency of Canada provides support to a province or territory conducting its own outbreak investigation, upon request, but when an outbreak of food-borne illness spreads beyond a province, territory, or country, the Public Health Agency assumes the lead to coordinate the outbreak investigation and the response with its partners. For example, when our national lab in Winnipeg linked listeriosis cases in provinces other than Ontario, where the outbreak started, the agency took the lead in coordinating the national investigation and response.
[Translation]
So, hopefully this provides some context. I'll move on now to a brief surveillance update.
[English]
Generally speaking, there are approximately 1,000 cases of E. coli reported each year in Canada. Based on our surveillance data, there has been a decline in the number of these cases. Most of these cases are also isolated and not part of an identified widespread outbreak. In 2009 the agency was involved in the investigation of 50 food-borne illness outbreak issues and it led nine of the investigations. These illness outbreaks implicated multiple provinces, or were international in scope.
So far in 2010, there have been a total of 12 investigations, and the agency has led three of these. All outbreaks are complex events involving a variety of players. Fortunately, they do not always result in the number of deaths that we saw in the listeriosis outbreak in the summer of 2008. But that experience showed us that no matter how much we apply from our past experience, more can be done.
[Translation]
Each event presents new lessons and new, emerging challenges.
[English]
While past lessons have led to Canada becoming among the safest food suppliers in the world, we all need to continue to be open to learning as we move forward. In this way, collaboratively, we can become even more efficient in managing new and emerging risks to human health due to food-borne illness.
Following the 2008 outbreak, the government immediately took a number of actions to prevent and reduce those risks, guided further by the Weatherill report in 2009. Working in collaboration with our partners in Health Canada and at the Canadian Food Inspection Agency, PHAC continues to work forward on the Weatherill recommendations and is making progress. The most senior levels of the responsible government partners are collaborating to address improvements to Canada's food safety system.
With regard to governance structure, the Clerk of the Privy Council gave Deputy Minister Knubley of Agriculture Canada the responsibility to chair a committee of deputy heads in 2009. Part of this work includes an oversight role in the coordination of actions by CFIA, Health Canada, and PHAC in relation to the Weatherill recommendations. I'm a member of this committee and am pleased to report that we've been meeting regularly for the last six months. The committee is supported by ADM- and DG-level committees as well as a full-time secretariat at Agriculture Canada.
The food-borne illness outbreak response protocol guides federal, provincial, and territorial collaboration in response to outbreaks. This key technical and operational protocol has been extensively revised in consultation with implicated government players, including the Public Health Agency, Health Canada, CFIA at the federal level,
[Translation]
and all provincial and territorial health and agriculture ministers.
[English]
The protocol has been endorsed by chief medical officers of health and by provincial and territorial deputies. The agency recently led a federal, provincial, and territorial review of the FIORP. This review has resulted in updated and clarified roles for responsibilities and collaborative processes and the articulation of clear guidelines for all involved during a food-related outbreak. FIORP 2010 will allow public health and food safety authorities across Canada to respond faster, more efficiently, and more effectively.
[Translation]
Along with the modernization of the protocol, the agency has been making progress on a number of other fronts.
[English]
Two major executive appointments have been made within the agency--namely, it now, as you know, has an associate deputy minister and an assistant deputy minister for emergency preparedness and response in corporate services. These appointments increase the agency capacity for flexible and timely response. We're working with provincial and territorial partners on a national public health surveillance tool called Panorama to improve our surveillance in early detection of outbreaks. We've expanded our participation in PulseNet, a national network of laboratories linking federal and provincial labs. PulseNet fingerprints bacterial samples from humans and food, facilitates coordination between food and clinical labs, and improves our ability to detect and respond to contaminated food products.
The agency is developing a comprehensive risk communication strategy to guide how it communicates to Canadians during a national outbreak, and we're also currently pilot-testing a model for rapid-response surge capacity. This will mobilize public health experts during food-borne outbreaks. All of this progress has been made possible by the allocation of approximately $18 million to the agency as its share of the government's three-year $75-million investment.
These initiatives address the recommendations of the Weatherill report as well as the concerns of the federal Standing Committee on Agriculture and Agri-Food. They highlight what the agency has been doing, although, as I say, we're only one part of a very large network of partners responding together when an outbreak occurs.
I'd be pleased to answer your questions. Merci.
:
Thank you, Madam Chair.
Honourable members, I would like to thank you for giving me the opportunity to speak with you today about Health Canada's efforts.
[English]
Before getting into my remarks, I'd like to introduce Dr. Samuel Godefroy, who is our director general of the foods directorate, under whose responsibility this issue of listeriosis lies, as well as Dr. Jeff Farber, who is the director of our bureau of microbial hazards; he was directly involved at the time and continues to be very involved with these issues.
To continue from what Dr. Butler-Jones has said, let me begin by saying that protecting and promoting the health and safety of Canadians, their families, and communities are of paramount importance to Health Canada. At the federal level, Health Canada's primary responsibility in terms of food is prevention. We set standards and policies for the safety and nutritional quality of all foods sold in Canada and work as part of the wider global food safety network to increase our understanding of food safety risks as well as sharing early warnings of potential food safety incidents.
During food-borne illnesses and outbreaks we work as part of the team, part of the Public Health Agency, and with the Canadian Food Inspection Agency in a supportive role, and with our provincial, territorial, and local public health partners to confirm the source of the food-borne illness, to provide laboratory services, and to conduct health risk assessments in an efficient and expeditious manner.
[Translation]
It is within these parameters that I would like to illustrate the progress that Health Canada has made towards fulfilling the recommendations set out in Ms. Weatherill's report.
[English]
As mentioned by Dr. Butler-Jones, we have organized our work under three key themes: reducing food safety risks, enhancing surveillance and early detection, and improving emergency response.
Under the theme of reducing food safety risks, we must continually review and adjust our food safety standards, policies, operational procedures, and legislative framework so that oversight continues to be effective in these risks.
In terms of listeria, Health Canada has revised and strengthened its listeria policy, which includes all ready-to-eat foods. We have held targeted stakeholder consultations to guide the revision, and the revised policy was released for public consultation on our website from March 22 to May 3 of this year.
Stakeholder comments and feedback received through this consultation are currently being analyzed by Dr. Jeff Farber and his team in order to refine the policy. We expect it to be finalized by the fall of this year.
[Translation]
In the Weatherill report, it was recommended that Health Canada review its approval processes and fast track, where appropriate, new food additives and technologies that have the potential to contribute to food safety giving particular attention to those that have been scientifically validated in other countries.
[English]
Health Canada is doing exactly that. Guidelines to assist industry are being developed using established criteria that would allow us to prioritize and fast-track approvals of food safety interventions that have proven health benefits. We anticipate that these guidelines will be finalized by the fall of 2010. In the meantime, we are already implementing these processes internally.
[Translation]
As an example, Health Canada used this process to approve the use of sodium acetate and sodium diacetate as preservatives in the preparation of meat and poultry products, including cooked and cured meats.
[English]
This process will also help us to address other food safety and nutrition issues, which could include, for example, finding alternative fats and oils to help reduce trans fat in our food supply, and therefore Canadians' consumption of this harmful substance.
[Translation]
In her report, Ms. Weatherill also noted the differences in perspectives regarding the quality and strength of evidence on which to base recall decisions.
[English]
To address this issue, Health Canada, in collaboration with its national and international food safety partners, has developed a draft guidance document on the weight of evidence needed to support appropriate and timely actions to protect consumers during food-borne illness outbreak investigations.
The weight of evidence takes into consideration all the information gathered through food sample testing and human illness reports, as well as the investigation of farms and/or food premises. Federal, provincial, and territorial counterparts have reviewed the draft guidance document, and it will be shared with a number of Health Canada's international counterparts later this month.
Health Canada is also enhancing our standard operating procedures in support of CFIA's food safety investigations. This includes clarification of timelines in the health risk assessment processes as well as improving the quality of our risk assessments with improved methodologies. The department will continue to add specialized expertise and is in the process of training more staff to conduct health risk assessments in order to continue to provide 24/7 coverage and enhance surge capacity preparedness.
Under the theme of enhancing surveillance and early detection, Health Canada is working in collaboration with CFIA to improve and validate detection methods for listeria and other hazards in food to reduce testing time and enable more rapid response during food safety investigations.
For example, we have an enhanced method for detection of listeria, which will lead to results being available in five to seven days, rather than the ten days that it took us previously. This has been developed by Health Canada, and we're currently validating it for different food commodities and categories. We've also begun working with the National Research Council on a multi-year project to develop even faster lab results, which will allow for the detection of listeria within 48 hours. A first-generation prototype is anticipated for mid-2011.
Under the final theme, improving emergency response, Ms. Weatherill called for targeted communication efforts for particular vulnerable segments of the population. The government recognizes the importance of providing information to Canadians on how to handle food safely to help avoid food-borne illness. Efforts to provide this information are ongoing, and target those populations that are at greater risk of complications from food-borne illnesses--for example, older adults, pregnant women, and those with weakened immune systems.
In March of this year we launched the first stage of a social marketing campaign targeting at-risk populations. This included the publication and distribution of booklets. We brought copies of these, which we'd be happy to share with all of you.
:
Thank you very much, Madam Chair. Thanks to the witnesses for being here today.
Ms. Ballantyne, in your brief, you told us that guidelines to assist the industry are being developed and that you expect to have the final version of those guidelines in the fall of 2010. You also told us that the department will continue to increase its capacity by adding specialized expertise and by training more staff to conduct health risk assessments in order to continue to provide around the clock coverage and to enhance preparedness in crisis situations. I feel that we have to underline the words “crisis situation”.
If I understand correctly, your problem is the way in which responsibilities are shared between Agriculture Canada and Health Canada. You are actually only responsible in crisis situations. Prevention is a problem. In the mid-90s, Agriculture Canada put in place a large number of food inspectors, and it created a kind of imbalance.
There are a lot of inspectors in my constituency. I recall them telling me that, previously, there were preventive inspections. Inspectors went into supermarkets almost every day to conduct checks and surprise inspections. Some were done at industry level. Today, there are precious few anymore.
As a result, there is precious little prevention anymore. You are dealing with this problem because you only get involved in crisis situations. As I understand it, you ride to the rescue at the last minute. It is all very well to adopt guidelines and develop plans. But if there is no prevention on site, if there are no inspectors, if you cannot hire any to do the checking before a crisis begins, you will always have to be managing the situation from crisis to crisis rather than doing basic prevention so that the crises never arise. Am I mistaken?
:
Yes. It's root cause analysis: you do sampling, let's say, of the environment, to find out where it is, and once you find that it is there, you take steps to eliminate it.
We've made a number of changes to the overall policy from the previous 2004 policy. I can give you just a few examples.
We've strengthened the end-product compliance criteria in terms of the numbers of organisms we allow in a food; we've actually strengthened that.
We've also stated, as I mentioned, that an environmental monitoring program should be used in all plants. We've also brought up the whole issue of trend analysis, so that a plant is not just doing tests and then putting the results in the drawer but is looking at the whole continuum of results over a period of time, as with trend analysis data. That's what companies have already started to do.
It also very importantly lists and encourages the use of post-processing inhibitors. For example, if you put a chemical in that can inhibit the growth of the organism, basically you're reducing your risk to near zero. We're encouraging companies to use technology, such as adding chemicals, maybe using processes such as ultra-high pressure, which a number of companies have already started to use. This high pressure can burst a cell and inactivate cells with listeria monocytogenes.
We also have an increased focus on outreach with the federal-provincial community to increase awareness of the risks of food-borne listeriosis. We've worked very closely with the CFIA on the policy as well. We've had excellent feedback from them. We have had excellent feedback also from the provinces.
So we feel we've come up with an improved policy and we have already had excellent comments back from industry as well on our efforts.
:
Thanks very much, Madam Chair.
Thanks very much to our presenters for being here. You're becoming very familiar faces around this table.
I see in the document that was handed out, “Progress on Food Safety As of March 31, 2010”, that the government is going through the response. They certainly are moving forward on the recommendations. From what we've heard this morning, there has been a great deal of progress made. It also says that the recommendations and the way forward are being put into three different categories: reducing food safety risks, enhancing surveillance, and improving emergency response.
As I glance through this and I see the different categories, I wonder if you could outline for us this morning how you're moving forward on those three categories and how you may be cooperating with Agriculture, which I think has been expressed as a bit of a red herring but a bit of a problem, too, because the issue does fall under two different departments. I think there is cooperation and collaboration, but maybe you could just point out the different ways you're doing that.
:
It happens at multiple levels. Part of it is the clarity around the pieces. In general terms, as it relates to the human health impacts of food, it's Health Canada, in terms of the guidelines, standards, etc., working very closely. CFIA manages the farm to the store, or the distributor kind of thing. For us it's the overall engagement around prevention, but also, when there are outbreaks or human health concerns, making sure there's a public health perspective to that.
What supports that are a number of committees at different levels, as well as day-to-day ongoing collaboration and consultation, discussion, to make sure we are taking into concern--so CFIA and agriculture--human health issues and are considering how the system works, so that we have an understanding of it and so that it moves as seamlessly as possible. So clarity in roles has been very helpful and is very important.
As I mentioned, there is a deputy ministers committee that meets regularly that I'm part of. It looks at the overall work plan to ensure we're making progress on each of the items. There are also ADM and DG committees that support that work, and then those who are actually doing the work themselves. So we meet regularly to go over where we are, what we have accomplished, what we still need to do, what other issues we're facing, etc.
It's a huge collaboration, but I must say it's very effective and useful. Generally, having been in public health now for too many decades, it really is gratifying to see the level of collaboration across departments federally, but also with other jurisdictions in terms of the desire, the willingness, the interest, and the capacity to work together to solve these problems. None of us owns them alone, and all of us are necessary to create the solutions.
I've never seen anything as good as this. There's still a lot we can learn, but I'm quite gratified.
:
Thank you, Mr. Chair. Good morning and thanks to the witnesses for being here.
Ms. Ballantyne, after your presentation, three questions occur to me. I am going to ask you those three questions and anyone who wants to can reply.
You mentioned a policy on listeria monocytogenes. We are well aware that there are a number of bacteria and we really do not know which one will cause the next outbreak. Does this policy just apply to listeria monocytogenes? Can we move away from listeria monocytogenes and apply it to various kinds of bacteria that might cause a similar problem to the one that occurred in 2008?
You also said that, using the process that you are putting in place, we will be able to find replacement oils that can reduce the amount of trans fat, which we know to be harmful. That is what you are saying. My question is simply this: with the work you are doing and the process that you are currently putting into place, will we really find a definitive solution to the problem of trans fat in food?
Now for my third question. You say that Health Canada is also working to improve its operational methods to support Canadian Food Inspection Agency investigations. We know that, in report after report, the Auditor General has pointed to ongoing problems with information management and internal communications in that agency. Given those problems raised by the Auditor General, I just wonder how you have been able to establish links to ensure that communication between Health Canada and the Canadian Food Inspection Agency is really effective.
:
What you're describing is what will always be a certain amount of local variability in terms of the application of principles.
Having been a local medical officer, taking over a health unit where steelworkers who had no sick-leave plan would be put off work until they were clear of giardia, even though it was no threat to anybody in a steel workplace...but again, interpreting the rules very strictly. As another example, people were not allowed to have cream in a mug; it had to be in the little packets, even in a four-star diner. So that is local application and interpretation.
The way we need to address this is through education as much as possible, whether through the Public Health Association and its work or through the inspectors and sharing information so there is more consistent application of the principles, so it can be respectful of some of these things. There are just so many examples. I remember schools wanting to have muffin programs, and you had to have three sinks and you had to have this and you had to have that. Well, that's silly. So we worked out, with the inspectors, the school boards, and the communities, some simple ways to make that food safe, without getting stuck in the same rules that apply to major restaurants and vendors.
One of the challenges is making sure that people have an understanding not only of the rules and what we're trying to do but also the principles and approaches, and how you can accommodate that. That's like when you see laws being interpreted by one policeman a little bit differently from another. And that's why there are rights of appeal, and all these kinds of things.
We hope to see more and more education, more and more engagement in these issues, and more and more understanding. The decisions that are made locally will be more consistent because they will have a more consistent understanding of the principles, the objectives, the processes, and what really is a big risk versus a small risk. The whole HACCP approach, which is really looking at risk-based things, has facilitated that much more than let's say 20 years ago when people were often focusing on the wrong things. There was a regulation for the height of a railing. It was a quarter of an inch short. And they weren't focusing on the fact that they were leaving food sitting out too long. So it really is something that requires both education and engagement.
Just to pick up on Monsieur Malo's point very quickly, we are looking at all forms of food poisoning.
[Translation]
We are looking at all viruses, bacteria and parasites.
I would say that all of these recommendations—there are 57 of them—present their own challenges in terms of how you move it forward, because you are coordinating across jurisdictions and across the industry sector, governments, and consumers. As we've learned, protecting health and safety is a shared responsibility and all of us have to do our part. We were talking about the local communities, and consumers have to do their part in terms of making informed choices. Industry has to do its part in terms of making sure that the products are safe to begin with, and utilize all the processes that are necessary. Government also has to do its part, through the regulations, but through the standards-setting and policies and procedures that we have.
My view would be that we're making great progress on these recommendations. We're aiming to implement them all by September 2011. But as we continue, some of them are going to take longer to implement and to make sure that we get these principles entrenched in ourselves: it's only now that we're learning that we shouldn't leave cut fruit or cut tomatoes out for longer than two hours, for example.
Food safety has become an increasing part of our psyche and we are, as a population, absorbing the things that we can do as Canadians. All those things take time to permeate.
In doing the consultation on the revisions of the FIORP, it was very clear that, as was mentioned, every province deals with food-borne outbreaks in various ways. In some cases, it's the chief medical officer of health who actually manages everything; and in other places, it's managed very much on the agriculture side and on the health side in separate ways.
It was clearly identified that what we wanted to do with the FIORP was bilaterals. We'd actually do it province by province.
We've already done Ontario. We've had a very good first pass with Ontario.
We actually also did a tabletop exercise with all of the epidemiologists and laboratory leaders in Winnipeg, in May, to see how it would resonate as a collective. The plan is, in the fall, to systematically go to each province, where the province would like us to look at their provincial FIORP process, and then bring everybody together at one point.
:
Thank you very much, Madam Chair.
Again, I want to thank you all for being here.
I must say, today, after listening to you, I'm very impressed with the action you're taking with the investments the government has made to implement these recommendations. I'm also impressed with how you've improved the communications and working collaboratively. I think all of us here understand from the lessons we've learned how difficult it is with the communications locally, provincially, federally, with industry and with the public, and how difficult it can be sometimes to respect all these different jurisdictional challenges in Canada.
I was wondering if you could take us through the process now with what you've learned.
Dr. Butler-Jones, you made an interesting comment at the beginning. I think you said that over 20,000 Canadians per day can have symptoms of something such as listeriosis, or whatever will come around in the future. If you look at listeria in general, it's very common. Much of this is handled at the local level.
I was wondering if you could walk us through just a little bit of the process of what you've learned and what we've seen in improvements in terms of how to take something that's locally at a doctor's office to, here we go, now we have to take a look at this as a bigger-picture type of spectrum.
:
Surveillance is going on all the time in the sense that if someone is ill, they go to the hospital or the doctor's office. They may or may not be tested. If they are tested, then that will eventually end up in the lab. If it's one of the organisms we're interested in, then local public health will get a report. If they identify that it's more than just a one-off, all of them will be inspected in the sense of is this a family issue, is it a bigger issue? If you have 30 cases of the same bug, then you get concerned.
Sometimes it's even far less than that. For example, we had half a dozen cases of cryptosporidium, which prompted the boil-water advisory in North Battleford, because where else could it have come from? Then rumours of other people.... Part of it, at the end of the day, is that whether you need a food recall or not, there are also public health interventions in terms of advice, etc., in the beginning.
So we get these samples. In the case of listeria, listeria is ubiquitous in the environment. Most of us don't ever get sick from it, even if we're eating it on our lettuce or whatever. But for vulnerable people, it can be a very nasty disease, as we saw a couple of summers ago. In that case, what happened is that we got lab samples. Ontario recognized that they had a couple more cases than they would expect. We were able through the PulseNet system to identify that we had one strain of this particular bacteria, which meant that it had a common source. We didn't know at the time what the common source was, but it forced us to go looking, and with CFIA to go looking. At the same time, there was a nursing home outbreak with a couple of cases--not dozens, but a couple of cases--that had the same pattern. By tracing what they'd been eating, etc., we were able in fairly short order to identify that it had come from that particular Maple Leaf plant, and to make the connection.
While at the end of the day we had lots of people being ill, and deaths, at the time that we recognized it we'd actually had only a handful of cases, but the recognition was that they were common and they had a common source, so we needed to pursue that. Again, because listeria has such a long incubation period, it meant that even though we had identified it, at that point these were people who actually had eaten it many weeks before so there would be more people. But once you recognize it, you can reduce the risk of anybody else eating it, and as a result reduce ultimately the number of people affected and reduce the number of deaths.
:
I'll get started from a public health standpoint and then leave it.
One thing that OECD and others.... Some 90% of Canadians have confidence in the food safety system in Canada. But it's interesting that a little less than half of them think you can tell food is bad by looking at it. Unless it's really rotten, you just can't. It's growing things in the fridge. So we still have a lot of work to do locally as well in education, understanding, and application.
In terms of how we're doing, everything is about relative risk. If you drink too much water, you die; if you don't drink enough water, you die. It is about the balance. Clearly turkey, leaner cuts, etc., from a general health standpoint are safer. But if you happen to be someone who's immunocompromised, then you want to make sure it's cooked, because of the risk. It is always about balancing risk. Not everybody is going to have a problem with listeria; in fact, the vast majority of us won't. All of us are potentially susceptible to salmonella, so cook your chicken. If you have hamburger meat, most of us are susceptible to E. coli 0157 or other toxigenic E. coli, so cook your hamburger all the way through. Those are very practical things.
But for a lot of us, our tolerance, our immune systems, are quite adequate to deal with deli meats. I wouldn't want everybody switching from turkey to pepperoni, just from the obesogenic aspects of it, if nothing else.
I'll turn it back over.
:
Thank you very much for the question.
The two departments, CFIA and Health Canada, actually get involved. The vaccine you're talking about was produced by a Canadian company. What it does is reduce the shedding of E. coli in the feces. It is one tool that can be used in the overall arsenal to try to reduce the load of E. coli 0157 in the food supply.
From what I remember, some of the difficulty is in showing the public health benefit of this. For example, with the use of this vaccine, can you actually show that you've had a reduction in the number of cases of E. coli 0157 in the human population? That is quite difficult to do because of the complexities of the system.
I agree with you that it is a good tool, but it is just one of the tools. There are other things that have been used—for example, bacteria flushes—to inactivate cells of E. coli.
So it's a good tool and one that can be used, but its efficacy in reducing the burden on public health due to E. coli 0157 is very difficult to ascertain.
I'll address your question related to listeria policy. It's a very good question.
As I was mentioning before, listeria is a very unique organism. With respect to the policy we have in place, there are some things that would encompass the reduction of all bacteria--for example, the use of good manufacturing practices, especially the sanitation. Increased emphasis on sanitation would definitely reduce all bacteria, not specifically listeria. As well, the use of the hazard analysis critical control point approach would also be generalized for all bacteria in a plant.
One thing you need to realize in terms of this organism is that because it is so very widespread we can use environmental testing to track different species of listeria in a plant. If we had something like salmonella, where it's not as widespread, we'd have to use totally different techniques.
Another thing that's very specific is the type of foods. As we mentioned, it's those foods that have a long shelf life, that are refrigerated and can support the growth, that are an issue. That would be very specific for listeria. Spices, for example, would not even be an issue for listeria, so that's not included in the policy. But it would be an issue for an organism like salmonella, which we know has caused problems in spices.
What this really relates to is the infectious dose for humans. For listeria, we know you need quite a high number of cells in order to cause infection; whereas for an organism like salmonella or E. coli 0157, sometimes as little as one cell that's present in the food can cause disease.
Some of the other specific things we have in the policy are criteria for looking at the absence and presence of listeria. This would be very specific for listeria because it relates to the infectious dose I mentioned. To give you one example, for standards for salmonella in a ready-to-eat product like meat, we would never have different tolerance levels like we have for listeria, where we allow 100 cells per gram of food in certain foods. We would never do that with salmonella or E. coli 0157 because in contrast to listeria we know that very low levels of those organisms can actually cause disease.
The other specific things we mentioned--for example, the addition of inhibitors like sodium diacetate--would be very specific for the inhibition of listeria and they would not necessarily inhibit a lot of the other pathogens we talked about. To get even more specific on the distinction between viruses and parasites, they cannot even grow in a food--they just don't grow.
There are very specific things in the policy specific to listeria, but some of the general concepts in it could actually reduce the total counts you would find in a food.