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Listeria: Health Canada Updates RTE Policy

As a widespread pathogen that can grow at refrigeration temperatures and survive in food processing plants for months to years, Listeria monocytogenes is a serious food risk, particularly for ready-to-eat (RTE) foods. With control of this deadly pathogen being of critical concern, Health Canada has updated its “Policy on Listeria monocytogenes in Ready-to-Eat Foods,” superseding the 2011 version which will expire October 1, 2023.

A key aspect of the updated Listeria monocytogenes (Lm) control policy is its emphasis on environmental sampling in post-process areas where ready-to-eat (RTE) foods are exposed to the environment prior to packaging. The overarching goals of the policy are to enable early identification of persistent Listeria species in the food processing environment; allow for the assessment of the effectiveness of control measures; and ensure that RTE foods are safe for consumption.

In comparison with the 2011 version (which remains in effect until October), the 2023 update focuses on:

  • Presentation of concepts, including the legislative and regulatory context of the Listeria policy, in a new order for better readability and refined for improved clarity.
  • The current outcome-based regulatory landscape for domestic manufacturers, importers, and exporters of RTE foods.
  • Updates and increased detail on specific food businesses, activities, and foods for which the Listeria policy does not apply.
  • A decision tree, with a series of questions to help determine the categorization of ready-to-eat foods that are subject to the policy, to facilitate the industry’s categorization of RTE foods.
  • Modification of the definition of RTE foods with certain refrigerated or frozen processed foods labelled on the package with validated cooking instructions now excluded from the Listeria policy. However, additional recommendations for vulnerable individuals should be taken into account, as they have an increased susceptibility.
  • More detail on foods specifically produced for consumption by vulnerable populations.

A key aspect of the policy is the categorization of foods, based on their potential to support Lm growth.

  • Category 1: Those which support the growth of Lm under reasonably foreseeable conditions of distribution, storage and stated shelf-life. As such, process monitoring, environmental sampling and end-product testing should be conducted more frequently, and Lm detection in sampling and testing may trigger a serious “Health Risk 1” concern, requiring risk management actions.
  • Category 2 contains 2 subgroups, for which validation may be necessary to demonstrate that control measures are effective to limit or prevent Lm growth.
  • 2A Foods. RTE foods in which the growth of Lm may be limited to levels not exceeding 100 CFU/g under reasonably foreseeable conditions of distribution, storage and use throughout the stated shelf-life. 
  • 2B Foods. RTE foods in which Lm growth will not occur under reasonably foreseeable conditions of distribution, storage and use throughout the stated shelf-life.
  • If there is uncertainty regarding the categorization of a RTE food, the relevant regulatory authority should be contacted.

Regardless of the food category, the Listeria policy takes into account the potential for Listeria growth as well as the presence or levels of Lm in RTE foods as factors to determine the health concern that such foods pose to consumers. The intended consumers of the RTE foods (for example, vulnerable populations) are also considered in determining the health concern.

With Listeria being more likely to cause death than other bacteria that cause food poisoning, and foodborne outbreaks of listeriosis linked primarily to RTE foods that are not normally further prepared before consumption, control of this lethal pathogen is essential. While Canadian food processors, and importers, have until October 1 to comply with the new policy, it is critical that businesses begin now – both to ensure compliance by the deadline and to further protect consumers.


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