In a March 29 warning letter the FDA formally notified Gate Gourmet Inc. owners that the classification of their airline catering facility in Erlanger, KY, has been downgraded from approved to provisional.

In November of 2017 Gate Gourmet found Listeria in its Los Angeles kitchen at LAX airport, and several airlines including American, Delta and Virgin Australia suspended their use of the air catering service until the problem could be resolved.

During the FDA’s Nov. 29 and Dec. 1, 2017, inspection of the Gate Gourmet airline catering facility in Kentucky, the agency noted issues of noncompliance with the Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food regulation, and sections of the Interstate Conveyance Sanitation regulations.

The observed violations caused the food products held at the firm’s facility to be adulterated because they were prepared, packed, or held under insanitary conditions whereby they may have become contaminated with filth or rendered injurious to health.

The FDA’s requires food facilities to identify and implement preventive controls to provide assurances that any hazards requiring a preventive control will be significantly minimized or prevented, and the food manufactured, processed, packed, or held by the facility will not be adulterated.

The FDA noted the following significant CGMP violations:

• The firm failed to exclude pests from their food plant to protect against contamination of food’
• Evidence of apparent cockroach activity and lack of effective measures to exclude cockroaches and other pests from the manufacturing and processing areas was observed during the inspection on November 29, 2017 and consisted of the following:
  • One apparent live cockroach was observed on the interior side of the oven door located in the hot production kitchen and one apparent live cockroach was observed on the floor beneath the mechanical flight-type dishwashing machine (Machine #1) in the dishwashing room.
  • Dead apparent nymph and adult cockroaches too numerous to count were observed inside the storage compartment to the four-burner gas range in the hot preparation kitchen.  Additionally, multiple dead apparent nymph and adult cockroaches were on floors near drains and behind cooking equipment in the hot preparation kitchen and on glue traps in the employee cafeteria.
  • Unsealed water pipe penetrations with heavy apparent cockroach fecal markings were observed in the wall underneath the 3-compartment pot wash sink in the hot preparation kitchen.
  • Non-operational cooking equipment, which could serve as harborage sites for pests, were located along the cookline in the hot preparation kitchen. These pieces of equipment had apparent old food and grease deposits throughout.

• According to the firm’s contracted pest service operator’s reports, cockroach activity was observed in and around food cooking equipment such as ovens and stoves, around manual ware washing sinks, inside and around mechanical dishwashing equipment, inside void areas of portable plastic food carts and around the employee cafeteria food lines during service inspections by a licensed pest control operator spanning from June 2 to November 2017;
• Furthermore, the firm contracted pest service operator’s reports indicated sightings of 75 (6/12/17), 100 (7/17/17), 100 (9/22/17), 100 (10/2/17), and 200 (10/24/17) “German Roaches” located throughout the whole building during service visits on the specified dates; “During this timeframe, your firm continued to operate as an airline caterer providing meals, snacks, and beverages to commercial airlines;”
• The firm failed to maintain equipment in an adequate condition through appropriate cleaning and sanitizing; “In addition, you failed to conduct operations under conditions and controls necessary to minimize the potential for growth of microorganisms and contamination of food;”
• A heavy build-up of more than a day’s accumulation of grease, food deposits, and general filth was observed on non-food contact areas of cooking equipment in the hot preparation kitchen; “The cooking equipment included:  ovens, ranges, tilting skillet, gas grill, deep fat fryers as well as the associated components to the cooking equipment such as gas/water piping, electrical wiring, and metal structural supports;”
• Additionally, apparent food soil and filth was observed on legs and shelves to portable food transport carts and casters on moveable equipment in this area;
• Floors underneath equipment and walls in difficult to reach areas in the hot and cold preparation kitchens and dishwashing areas were soiled with apparent old food residue and filth;
• Additionally, standing water was observed in an approximate 12” X 12” section in the floor near the gas ranges where floor tiles were missing;
• Interior and exterior sides of black plastic dust pans were stored within five feet of food preparation counters and food products in the preparation kitchens with apparent build-up of food and liquid residue;
• The firm failed to clean all food contact surfaces, including utensils and food contact surfaces of equipment, as frequently as necessary to protect against contamination of food;
• Apparent food residue was observed on the blades to the large metal can openers in the hot and cold preparation rooms;
• Apparent food soil and grease deposits were observed along the juncture of the cutting board and metal housing of the gas grill in the hot preparation kitchen;
• Additionally, the cutting board was in poor condition and appeared stained and soiled with food residue;
• The firm failed to have adequate sanitary facilities and accommodations in their plant;
• Water leaked from plastic drainage piping on the underside of the mechanical flight-type dishwasher (“Machine #1”) and pooled on the floor below;
• A metal floor drain in the cold preparation kitchen had a build-up of apparent old food waste and general filth inside the drain’s catch basket; “According to the General Manager, the covers to most of the floor drains including this drain, are unable to be removed due to the age of the drain in order to clean out food caught in the catch basket;”

The FDA reported it received a “response letter” from Gate Gourmet describing several corrections. However, the FDA noted that inspectors cannot evaluate the adequacy the measures because the firm did not provide evidence to show it is now in compliance.

“You did not provide pest control records showing no evidence of pests, photographs of clean equipment or a sealed water pipe,” according to the warning letter. Because the of this, the FDA said the “reported corrections” will be evaluated during a subsequent inspection of the firm.

Food companies are given 15 working days to respond to FDA warning letters.

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