Sometimes you just want to put a problem behind you, but it just sticks around like duct tape.

A new “Warning Letter” from the U.S. Food and Drug Administration to the Kellogg’s Company raises questions about whether the Listeria problem at its Atlanta Eggo plant is truly resolved.

On a routine inspection of the Kellogg’s frozen food manufacturing facility on Bucknell Road in Atlanta, last Aug. 31st, the Georgia Department of Agriculture found Listeria monocytogenes in a sample of buttermilk Eggo waffles.

Battle Creek, MI-based Kellogg’s shipped none of the product from the contaminated lot, and recalled some of its other Eggo products.  No illnesses were associated with the incident, but Kellogg’s shut down the plant for “hygienic restoration.”

Then rains that hit Atlanta last year were so severe that storm and sanitary sewers over-ran in many parts of town.  Flooding in the area south of I-20 and west of I-285 near Thornton Road where the Kellogg’s plant is located was significant, and required another clean-up

The result: a nationwide Eggo shortage.

FDA inspected the plant from Oct. 22-29, 2009, taking a variety of samples of both finished and in-process samples and environmental swabs for its own testing.  Those results were also positive for Listeria.

FDA inspectors also found “significant deviations” from current Good Manufacturing Practice regulations at the Kellogg’s plant.  FDA’s Acting Atlanta District Director LaTonya M. Mitchell, in the Jan. 27 letter, said Kellogg’s violations mean products from the Atlanta plant are “adulterated.”

Mitchell’s letter to Kellogg’s President and CEO, David Mackay, was released Tuesday.  The FDA wrote:

“During the FDA inspection, investigators collected environmental samples from various areas in your facility. Five environmental swabs tested positive for L. monocytogenes. Pulsed Field Gel Electrophoresis (PFGE) testing results determined that three of the environmental swabs had a
 PFGE pattern that was indistinguishable from the positive sample collected by the GDA. This is significant because these three swabs were taken from three different locations in your facility and the swabs’ indistinguishable PFGE pattern was found in your firm’s finished product, Eggo 
Buttermilk Waffles. The PFGE results reveal that L. monocylogenes may have been transported throughout your facility and may have established niche areas to colonize. One of the aforementioned environmental swabs was taken from the wheels on a forklift observed in the packaging area. The presence of L. monocylogenes on the wheels of a forklift is a concern as the organism is likely to spread when the forklift moves throughout the facility.

“Two of the positive environmental swabs had PFGE patterns that were distinguishable from the other three environmental swabs and the positive sample collected by the GDA. One of these samples was collected from the floor at the walk-through door to the battery changing room. The other sample was collected from the bottom of a grey tote located at the end of the (b)(4) conveyor,” Mitchell wrote.

“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 movaeble equipment; soiled pallets; soiled raw material packaging; raw ingredients; and by rodent vectors.

“Once established on production area floors, the pathogen may contaminate food and food-contact surfaces through either human or mechanical means. L. monocylogenes differs from most other foodborne pathogens because it is widely distributed, resistant to diverse environmental conditions, including low pH and high NaCl concentrations, and grows under refrigeration conditions,” she added.

FDA went on to document conditions inside the plant that may lead to product contamination.

The agency acknowledged receipt of a letter from Kellogg’s dated Nov. 18, 2009 in response to the positive results for Listeria found during the inspection.

“Although your response lists a number of corrective actions directly associated with the positive test results, including sanitizing certain equipment and limiting employee access to certain processing areas, it is essential to identify all areas of your facility where L. monocytogenes is able to grow and survive (niche areas) and to take such corrective action as necessary to control the organism,” FDA added.

It also said Kellogg’s still needs to address sanitation controls and its deviations from current Good Manufacturing Practices.

“The safety of our foods is of utmost importance to Kellogg Company.  While the FDA letter was filed publicly today, the situation described in the letter relates to inspections conducted in October after the plant was closed for enhanced cleaning and the flood in Atlanta that affected our facility,” said Kellogg’s spokeswoman Kris Charles.

“Before opening the facility, we worked cooperatively with both the Agency and the Georgia Department of Agriculture, and we completed comprehensive testing and monitoring. We have made a variety of enhancements in our facility, and have fully addressed all of the observations in the letter. We will be filing our response with the FDA to this effect shortly,” she added.

Kellogg’s Atlanta plant resumed operation in late October, trying to work down that Eggo shortage, which was also impacted by maintenance at another Kellogg’s plant in Rossville, TN.

The company, which reported sales of $13 billion last year, has 15 working days to respond to FDA’s letter.