First, the letter points out that FDA found 19 Listeria positive environmental samples with 7 of those being food contact surfaces including a chiller water system (that did not have sanitizer). These samples were linked via Whole Genome Sequencing to clinical isolates. While the firm corrected the facility issues, FDA stated that this was not enough. "While we acknowledge these are appropriate actions to be taken, we are unable to fully evaluate the adequacy of these actions at this time without further details, documentation and results of your corrective actions." So basically, they want to see results from extensive sampling, including when the plant is operating, that the organism is not present.
On GMP issues, the facility was found to be not as clean as it should have been. While the plant indicated it trained the employees, FDA found the response lacking. ."your response did not provide any details as to the content of this training or how you will ensure this training is effective by assessing and monitoring employee performance and adherence to the training."
The facility had many condensation issues, which is not good from controlling Listeria. While the facility responded that they fixed sources of condensation, FDA responded "how you will assess whether this correction and the [fixes] are effective in minimizing the condensation above food and food contact surfaces. Your response does not address how to you will prevent future recurrence of this violation, such as through increased monitoring and assessment."
The facility had poorly made food contact surfaces that would provide harborage. While the facility had repaired the surfaces, FDA responded "you provided no documentation or details on how you will ensure the repairs are adequate. Your response does not address how you will prevent future recurrence of this violation. "
In addition, there were steam ventilation issues and general facility issues. Again, fixes were made, but the outcome of those fixes and measures to prevent reoccurrence were not addressed.
FDA Warning Letter
Oregon Potato Company 7/15/16