The Kellogg Company is struggling with the “…presence of a persistent strain of L. monocytogenes…” in its Augusta, Georgia manufacturing facility, according to a warning letter released today by FDA.

Kellogg inherited the cookie manufacturing facility when it acquired Keebler in 2001. The company manufactures several brands and varieties of cookies at the facility, including Pecan Sandies, Chips Deluxe, Famous Amos, Pecan Swirls, Cinnamon Swirls, and Lemon and Raspberry Sandies. In 2009, Kellogg expanded the facility, adding Girl Scout cookies, Kashi, and a new Keebler cookie to the product mix.

In January 2010, FDA inspected the Augusta production facility and found Listeria monocytogenes in environmental swab samples collected during the inspection. More than one year later – in February 2011 – the identical strain of Listeria monocytogenes was still present in the manufacturing plant.

FDA found L. monocytogenes in fifteen environmental samples taken during the 2011 inspection. Seven of the positive samples were from direct food contact surfaces. While FDA acknowledges that the finished products may not support growth of L. monocytogenes, the presence of this persistent pathogen is a clear signal that the company’s cleaning and sanitation program is inadequate. According to the warning letter,

“The presence of a persistent strain of L. monocytogenes in your facility between January 2010 and February 2011 is significant in that it demonstrates that your cleaning and sanitation efforts were inadequate to remove this organism. We note that although your finished product cookies may not support the growth of L. monocytogenes, the positive environmental swabs are indicators of insanitary conditions in your facility and demonstrate a failure of cleaning and sanitation operations that may allow for contamination of foods with filth or pathogens.

Bacteria may enter and/or be transported through a food plant by a variety of routes that include, but are not limited to: roof leaks; the shoes of employees, contractors, and visitors; the wheels of fork lifts, pallet movers, and moveable equipment; soiled pallets; soiled raw material packaging; raw ingredients; and by various pest vectors. Once established on production area floors the organism can contaminate food and food-contact surfaces through either human or mechanical means.”

In addition to the persistent presence of L. monocytogenes in the production plant, FDA inspectors noted several other sanitary concerns during their inspection. These included:

  • Multiple pipes were wrapped with material/insulation that appeared to be saturated with condensation.
  • Pooling water due to drips from condensate was observed above mixers…, behind an unwelded splash guard; the pooled condensate was observed dripping directly into an open upright mixer bowl.
  • Pooling water was observed below the in-feed of spiral cooler…
  • Pooling water was observed at the in-feed of spiral cooler…; the pool had a build-up of product debris and a black substance.
  • Pooling water was observed in spiral cooler … on the southwest corner below the mesh conveyor.
  • Approximately twenty flies were observed exiting a drain located near spiral cooler … and making contact with food contact surfaces.
  • Approximately thirty flies were observed swarming in proximity of the flour sock of mixer …
  • Approximately eighty flies were observed after the back panel of mixer … was removed.

This is not Kellogg’s first brush with a Listeria monocytogenes contamination problem. An October 2009 inspection of the company’s Eggo Waffle production facility in Atlanta, GA found L. monocytogenes in the plant environment. The 2009 inspection was initiated after the Georgia Department of Agriculture found L. monocytogenes in an Eggo Buttermilk Waffle finished product sample during a routine inspection. The contamination was detected before the Eggo’s were shipped; however, as a precaution, Kellogg recalled two other products that were manufactured at the same facility as the Eggo’s.

The Eggo contamination is unrelated to the problems reported in the Augusta facility.

The most significant health risk at the Augusta plant is not the presence of Listeria monocytogenes – although that is bad enough. The real concern – as the FDA warning letter points out – is that the plant’s cleaning, sanitation and pest control programs are ineffective, and might allow other pathogens, such as Salmonella, to gain a foothold.

It’s easy for a company to become complacent, especially when its products are “shelf-stable.” Other companies, such as McNeil Consumer Healthcare (part of Johnson & Johnson), have paid dearly for their complacency.

Kellogg! Put your Keebler elves to work, and clean up your production environment.