Measures taken by Estonian authorities following a Listeria outbreak have improved the fish control system, according to the European Commission.

A remote DG Sante audit, in October 2020, looked at checks to ensure smoked fish meets microbiological food safety criteria, as well as measures taken by authorities in non-compliances.

Eight Rapid Alert System for Food and Feed (RASFF) reports for Listeria monocytogenes in smoked fishery products from Estonia have been issued since 2015. All but one concerned the same establishment.

A multi-country outbreak of 22 listeriosis cases linked to cold-smoked salmon and trout pointed toward M.V Wool, an Estonian processing company as the manufacturer of these fish products. This was based on traceability information and a match between the outbreak strain and samples on the processing line and in four batches of the final product. Five countries were affected from 2014 to 2019 and five people died.

DG Sante found measures put in place by authorities following this outbreak strengthened the official control system, with some areas still being addressed during the audit. The use of whole genome sequencing gave the authority additional tools to verify food firm controls and deal effectively with alerts.

Response to outbreak
At the time of alerts in 2018, authorities focused on ensuring that smoked fish in the RASFF notifications was traced and recalled from the market but some delays in action taken at the regional level were noted.

Results of whole genome sequencing in 2019 indicated the persistence of a Listeria strain in the premises of the company linked to the RASFF alerts for several years.

During controls in 2019, authorities noted the hot smoking treatment was not sufficient to address the Listeria hazard. They started to take environmental samples and detected Listeria after cleaning and disinfection. Shelf-life studies also didn’t take into consideration reasonable foreseeable storage and distribution conditions. The company voluntarily suspended activity and took steps to address the issues.

Auditors said several steps had been taken to follow up on the 2019 outbreak at the establishment level, but also to strengthen the official control system and support companies to prevent similar incidents.

These include guidance for dealing with Listeria non-compliance and assessing shelf-life studies, training, increasing product, and environmental sampling, and a recommendation for sites that process fish to do random environmental sampling.

Still work to do
Official controls over fishing vessels, landing sites and transport are carried out by the Environmental Inspectorate (EI) of the Ministry of Environment, which does not have enforcement powers. EI inspectors draw up an assessment form and send it to the regional VFB or county inspector.

The Veterinary and Food Board (VFB) had not verified the effectiveness of EI controls since 2017. In 2021, VFB and the Agricultural Board merged into the Agricultural and Food Board.

“The limited VFB verification of EI controls and of the VFB controls following the multi-country Listeria outbreak undermines the ability of the system to ensure consistency and effectiveness of these controls,” said auditors.

Estonian officials said internal audits are planned in 2023 to assess EI checks and official controls in fishery establishments.

In 2019, 277 unscheduled environmental samples were taken during official control related to the outbreak. In 2020, environmental samples to detect Listeria were part of the official control plan.

During the audit, Estonia was dealing with a RASFF report for Listeria in smoked fish produced by another company. The DG Sante team noted that officials were using the experience gained in dealing with the multi-country outbreak to handle the incident.

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