The USDA FSIS is rolling out a new Listeria sampling program which adds two food-contact surface and two nonfood-contact surface samplings at establishments producing post-lethality exposed RTE products. The four new environmental swabs will be collected concurrently with the existing routine product sampling and will be analyzed for both Listeria monocytogenes (Lm) and non-Lm Listeria species. Coupling this program with the January FSIS directive on inspector testing for non-LM Listeria species makes it clear that establishments’ environmental monitoring and control programs are becoming increasingly critical and non-Lm Listeria species are also a hazard.
The goal of the increased sampling is to give inspection teams more frequent, science-based checks of sanitation effectiveness and potential Listeria harborage sites; verify that establishments are effectively controlling Lm; provide a better understanding of Listeria trends across all RTE establishments; and enable enhanced warnings of sanitation issues and potential harborage sites. By integrating the new swabbing into the existing program, FSIS will gain a more comprehensive view of environmental conditions without creating duplicative steps or visits.
Currently, FSIS conducts microbiological testing of all RTE meat, poultry, and egg products for Lm and six Salmonella serotypes through product and environmental swab sampling under various programs. In FY 2026, FSIS performed a pilot that paired food contact and non-food contact surface environmental swabs with product samples collected at establishments producing RTE post-lethality exposed products. As a result of the outcome of the pilot, conducted in the Alameda, Chicago, and Raleigh districts, FSIS is initiating a phased implementation of the sampling across all nine districts, starting with Alameda and Atlanta in January 2027.
FSIS emphasizes that the change is meant to work with testing conducted by establishments, not replace it, and notes that through analysis of the sampling data, the agency can work with establishments to ensure their corrective actions effectively address the root cause or harborage sites. Thus, FSIS is training all inspectors in the sampling, including those that don’t work with RTE facilities.
The tentative timeline set for a phased roll out to the nine districts is:
- January 2027 – Alameda and Atlanta Districts
- February 2027 – Raleigh, Springdale and Denver Districts
- March 2027 – Chicago, Philadelphia, Des Moines and Dallas Districts
Before and during implementation, FSIS will also host listening sessions.
The new program follows a directive issued earlier this year that not only instructed inspectors to test for non-Lm Listeria species in RTE facilities, but also required that establishments take corrective action on samples found to be positive for non-Lm Listeria spp. even if negative for Lm. This is because a Listeria spp. finding can still indicate that the sanitation program is ineffective at preventing conditions where Lm may occur and that conditions (including lack of sanitation and poor hygiene practices) exist that allow Listeria spp. to thrive, thus Lm could also thrive.
As stated at the beginning of this article, the increased emphasis of FSIS on Listeria – both Lm and non-Lm species – is making environmental monitoring and control programs ever more critical. Not only is a comprehensive program essential to ensuring regulatory compliance, but, even more importantly, it is critical to ensuring consumer safety.
Although listeriosis has been cited as occurring less frequently than many other foodborne illnesses, Listeria is the single largest bacterial cause of USDA meat and poultry recalls by volume, and it is the third leading cause of foodborne illness deaths. Listeriosis can have severe consequences, particularly for pregnant women, newborns, older adults, and people with weakened immune systems. Thus, while USDA is sampling your establishment, they will not only be looking for Listeria, they will also be reviewing the application of all your processing and environmental strategies to determine how well these are protecting your product.
Whether you have concerns about the efficacy of your environmental programs or simply want to ensure they are the best they can be, TAG can help! We have recently added a new offering that further enhances our current services. TAG’s new Sanitation and Hygienic Design Group, led by industry authority on sanitation Joe Stout is now taking clients to assist food facilities in optimizing your sanitation processes for food safety.
In summary, there are two food-contact surface and two nonfood-contact surface samples at establishments producing post-lethality exposed RTE products, being added to the new Listeria sampling program by the USDA FSIS. The goal of the increased sampling is to give inspection teams more frequent, science-based checks of sanitation effectiveness and potential Listeria harborage sites; verify that establishments are effectively controlling Lm; provide a better understanding of Listeria trends across all RTE establishments; and enable enhanced warnings of sanitation issues and potential harborage sites. FSIS emphasizes that the change is meant to work with testing conducted by establishments, not replace it, and notes that through analysis of the sampling data, the agency can work with establishments to ensure their corrective actions effectively address the root cause or harborage sites.
