Commentary

FIGHT FOR FOOD SAFETY

Are we over-investigating Listeria?

FOOD INDUSTRY COUNSEL LLC

By Shawn K. Stevens

Why the meat and poultry industry remains stuck in battle mode.

For the past decade, the ready-to-eat meat and poultry industries have been in a constant state of alert for the presence of Listeria monocytogenes in the processing environment. The industry is swabbing more zones than ever, sampling more aggressively with each passing day and, in some cases, sending more isolates to contract labs for subtyping. Despite this unprecedented surge in environmental monitoring, however, the number of Listeria-related recalls and confirmed outbreaks has not necessarily decreased in proportion to the sampling intensity. If anything, the data suggest the opposite: we are not improving significantly on the numbers of total recalls for the presence of Listeria.

The one question no one wants to ask out loud is “whether we are over-investigating Listeria?”

The pressure to swab is real and multifaceted. FSIS has steadily raised expectations for Zone 1 and 2 sampling. Some retailers now require environmental data as part of supplier approval. And, overlaying all of the “to sample” or “not to sample” quandary is whole genome sequencing (WGS). This quiet game-changer has turned every environmental isolate into a permanent genetic record. No plant wants to be the facility whose “resident strain” matches a clinical isolate five years from now. As a result, companies stay in a constant state of battle mode, doing more testing in more places, more often. But, is the increased testing yielding the desired results?

But, more data doesn’t necessarily equate to more safety. Many isolates recovered through routine surveillance come from niches that arguably pose minimal direct risk to food contact surfaces. Cracks in floors, forklift wheels, drain trenches, door tracks, and condensation catch-points can harbor Listeria without ever realistically threatening production. Yet each discovery launches a costly, time-consuming investigation with root-cause mapping, resampling, aggressive sanitation cycles, and risk assessments. Plants can’t simply ignore these positives – the regulatory culture doesn’t allow it – but they also can’t operate efficiently when every environmental swab is treated as a crisis.

One unintended consequence of this “always swabbing” mindset is that plants may actually overlook the real risks. When teams are buried in environmental positives that have little to no product exposure, they have fewer resources to focus on airflow management, employee traffic patterns, equipment hygienic design, and true harborage points that may actually matter more.

None of this means we should relax our standards. Listeria monocytogenes remains one of the most lethal foodborne pathogens affecting the ready-to-eat food supply, and the industry’s commitment to control has likely reduced illness. But the industry’s approach to environmental monitoring may need recalibration. Instead of broad, routine over-sampling, processors may benefit from a more targeted, risk-based strategy that prioritizes zones and conditions most predictive of product contamination. Pairing smarter sampling with rapid vectoring, more rational corrective actions, and better use of historical data might reduce noise without reducing safety.

The industry isn’t over-reacting because its required – it is likely over-reacting because the regulatory, legal, and WGS environment has pushed plants into a posture where finding Listeria feels just as dangerous as missing it. But as we look toward the next decade of food safety modernization, it may be time to ask whether we need more swabs … or just better ones.

Opening image credit: GettyImages / SyhinStas / Getty Images Plus

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www.provisoneronline.com   |  december 2025