FSIS

Best Practices Guidance for Controlling 

Listeria monocytogenes (Lm) in Retail 

Delicatessens

June 2015

This guidance document provides specific 

actions that retailers can take in the 

delicatessen (deli) area to decrease the 

potential for Listeria monocytogenes (Lm) 

growth or cross-contamination. In 

particular, the guidance covers:

• Actions identified by the Interagency 

Retail Lm Risk Assessment (see page 

3) that can decrease the predicted risk 

of listeriosis from deli products;

• Information from the U.S. Food and 

Drug Administration (FDA) Food Code, 

scientific literature, other guidance 

documents, and lessons learned from 

meat and poultry establishments that 

retailers can use to control Lm;

• Steps retailers can take to help ensure 

that deli products are maintained under 

sanitary conditions that do not allow 

Lm adulteration of the product; and

• A self-assessment tool that retailers 

can use to determine what practices 

they are currently using and what new 

practices to adopt to control Lm. 
Table of Contents

Purpose 1

Introduction 1

Regulation of Meat and Poultry Products at Retail

The Interagency Retail Lm Risk Assessment Findings

2

3

How to Use this Guidance 6

Product Handling

 

7

Cleaning and Sanitizing

 

9

Facility and Equipment Controls

 

11

Employee Practices 12

Deli Self-Assessment Tool 

References and Resources

14

15

ii
Purpose

This guidance document provides specific recommendations for actions that retailers can take 

in the delicatessen (deli) area to control Listeria monocytogenes (Lm) contamination of ready-toeat (RTE) meat and poultry products. These materials highlight recommendations that are 

based on an evaluation of retail conditions and practices in the Interagency Risk Assessment--

Listeria monocytogenes in Retail Delicatessens (Interagency Retail Lm Risk Assessment). In 

addition, FSIS has included information from the Food and Drug Administration (FDA) Food 

Code, scientific literature, other guidance documents, and lessons learned from Food Safety 

and Inspection Service (FSIS) verification sampling and review of sanitation programs for Lm in 

meat and poultry processing establishments. 

This version of the guidance document replaces the previous version of the document which 

was issued and announced in the Federal Register (79 FR 22082; April 21, 2014). FSIS 

updated this guidance based on comments received during the public comment period, which 

closed on June 20, 2014. FSIS made the following changes in response to comments:

• Clarified that food processing equipment should be disassembled during cleaning and 

sanitizing. 

• Added a recommendation that retailers scrub surfaces during cleaning to prevent biofilm

formation. 

• Clarified that retailers should rotate (change) sanitizers to help prevent Lm from 

establishing niches in the environment and forming biofilms.

Although comments will no longer be accepted through regulations.gov on this guidance 

document, FSIS will update this document as necessary, should new information become 

available.

Introduction

Lm is a bacterium that is found in moist environments, soil, and decaying vegetation and can 

persist along the food continuum. Transfer of the 

bacteria from the environment (e.g., deli cases, 

slicers, and utensils), employees, or raw food 

products is a particular hazard of concern in RTE 

foods, including meat and poultry products. 

Listeriosis is a serious infection usually caused by 

eating food contaminated with Lm. Controlling 

Lm has long been an objective of the public 

health community. The Centers for Disease 

Control and Prevention (CDC) estimates that 

infection with Lm causes about 1,600 illnesses, 

1,500 hospitalizations, and 260 deaths in the 

United States each year. Listeriosis is rare, but 

its fatality rate is very high (about 16 percent, compared with 0.5 percent for either Salmonella

or E. coli O157:H7) (Scallan et. al., 2011). It primarily affects older adults, pregnant women, 

newborns, and adults with weakened immune systems. 

Lm can survive and grow at cool temperatures (as low as 34 ̊ F/1°C). Because of its growth and 

survival characteristics, Lm is usually persistent in the environment and is commonly referred to 

The CDC estimates that Lm causes a high 

level of deaths compared to other 

foodborne pathogens. Deli products have 

been shown to be a major contributor to 

these illnesses. Retailers can help 

decrease the risk of illness by controlling 

Lm contamination in the deli.

1
as a harborage organism (i.e., it can form niches and grow to high numbers in the environment; 

niches provide an ideal place for Lm to establish and multiply). It can cross-contaminate food 

contact surfaces and foods. Improper sanitation, product handling, and employee practices can 

lead to the transfer of Lm to RTE meat and poultry products at retail causing them to become 

adulterated (see Regulation of Meat and Poultry Products at Retail below).

RTE meat and poultry products do not require cooking prior to being consumed and are often 

held at refrigerated temperatures. Once contaminated with Lm, RTE food products may provide 

an ideal environment for this harmful bacterium to grow. A variety of retail surveys of deli meats 

and a number of risk assessments of Lm in deli-sliced versus pre-packaged deli meats have 

analyzed the risk of listeriosis associated with deli prepared meat and poultry products. The 

FSIS Comparative Risk Assessment for Lm in Ready-to-eat Meat and Poultry Deli Meats (May 

2010) estimated that of listeriosis illnesses attributed to deli meat, 83% are associated with deli 

meat sliced and packaged at retail (Endrikat et al. 2010). 

Safe food handling practices, thorough cleaning and sanitation procedures, maintenance of the 

facility and equipment, and good employee practices are key components that may prevent or 

reduce the likelihood of RTE foods becoming contaminated in retail delis. 

Regulation of Meat and Poultry Products at Retail

FSIS shares jurisdiction with FDA and with State, local, and tribal authorities for meat and 

poultry products at retail. FDA makes recommendations regarding retail practices through the 

FDA Food Code. The Food Code is used by the State and local agencies as a model to 

establish regulations, ordinances, and actionable policies that can be enforced in their 

jurisdictions. Operators of retail establishments are required to comply with the conditions of the 

permit or license under which they operate. 

The Federal Meat Inspection Act (FMIA) and Poultry Products Inspection Act (PPIA) apply to 

meat and poultry products produced in federally inspected establishments and other entities 

producing or handling meat and poultry, including at retail. Although retail firms are generally 

exempt from FSIS inspection, retailers are required to maintain sanitary conditions and 

otherwise not produce adulterated or misbranded product (21 U.S.C. 623(d) and 464(e); 9 CFR 

303.1(f) and 381.10(d)(4)). The types of operations that are traditionally and usually conducted 

at retail stores can be found in 9 CFR 303.1(d)(1) and 9 CFR 381.10(d)(1).

FSIS provides instructions to its personnel for surveillance activities at retail in FSIS Directive 

8010.1. The purpose of in-commerce surveillance is to ensure that FSIS-regulated meat and

poultry products distributed in commerce are:

• Safe, wholesome, and not adulterated;

• Correctly marked, labeled, and packaged;

• Secure from intentional acts of contamination, and 

• Legally imported and properly exported. 

When performing in-commerce surveillance, FSIS verifies that: 

1. Meat and poultry are wholesome and not adulterated; 

2
2. Sanitary conditions are such that meat and poultry will not become contaminated with filth or 

rendered injurious to health; 

3. Hazard controls are adequate to prevent meat and poultry from becoming adulterated; 

4. Meat or poultry not intended for use as human food are properly denatured or otherwise 

made inedible as prescribed by Federal regulations; and

5. All records are kept and maintained in a manner that fully and correctly discloses all 

transactions involved in the business activity that is subject to the provisions of the FMIA and 

PPIA. 

This guidance does not replace the FDA Food Code, State, tribal or local, or FSIS 

regulations. This document can be used along with the 2013 FDA Food Code to help retailers 

ensure that meat and poultry products are not prepared or sliced under insanitary conditions in 

the retail deli area, which can lead to Lm contamination and outgrowth of the organism on the 

product. 

The Interagency Retail Lm Risk Assessment Findings

The Interagency Retail Lm Risk Assessment was jointly developed by FSIS and FDA, and in 

consultation with the CDC, to help guide food safety 

efforts to minimize the public health burden of 

listeriosis in the U.S. The risk assessment was 

conducted to better understand how retail practices 

(e.g., temperature control, sanitation, worker 

behavior) influence the public health risk of listeriosis 

associated with eating deli products (e.g., meats, 

cheeses, and salads) sliced or prepared in retail. It 

also examines how effective various interventions 

are in limiting the survival, growth, or crosscontamination of Lm.

The risk assessment is based on observations of:

• Deli employees' work routines; 

• Concentrations of Lm on incoming products and in the deli environment; 

• Studies on the ability of Lm to spread in retail delis, such as from a slicer to food; and 

• An existing dose-response model. 

The study was designed to apply to a range of deli establishments, from small independent 

operations to the deli departments in large supermarkets. 

The risk assessment also reinforces the importance of FDA's Food Code recommendations to 

operators of retail delis. State, local, and tribal jurisdictions can do their part to reduce listeriosis 

by enforcing all relevant provisions of the 2013 FDA Food Code as part of their own food safety 

requirements. 

The risk assessment found that certain practices are needed to effectively prevent crosscontamination and limit Lm growth in RTE foods handled or prepared in retail delicatessens, 

including:

No single action or practice will control 

Lm contamination of retail foods. 

Instead there are many steps that 

retail deli operators and their suppliers 

can take to help reduce the risk of 

listeriosis.

3
• Proper storage, 

• Adequate sanitation, and 

• Effective employee practices.

NOTE: This guidance document includes key findings from the Interagency Retail Lm Risk 

Assessment and provides an overall summary of the data for typical retail deli settings. More 

detailed information regarding the findings is in the Retail Lm Risk Assessment Report. 

4
Key Findings

The following are key findings of the Interagency Retail Lm Risk Assessment for typical retail 

deli settings.

• Storage Temperature. If all refrigerated RTE foods are stored at 41°F (5°C) or below, as 

the 2013 FDA Food Code (3-501.16(A)(2)) recommends, approximately 9% of predicted 

listeriosis cases caused by contaminated deli products prepared or sliced in the retail deli

could be prevented.

• Growth Inhibitors. If all deli products that support Lm growth were reformulated to include 

growth inhibitors, approximately 96% of predicted listeriosis illnesses caused by RTE 

products prepared or sliced in the retail deli could be prevented. While this finding is 

significant, the actual benefit may be smaller in part because the concentration of the growth 

inhibitor used may not be sufficient to be effective throughout the shelf life of a food or may 

not be used in high enough concentrations because the inhibitors can adversely affect the 

flavor of the product.

• Control Cross-Contamination. The predicted risk of listeriosis dramatically increases in 

retail delis as a result of cross-contamination. In particular, slicers are key sources of crosscontamination in retail delis. Eliminating all points of cross-contamination in the deli 

(including slicers) would decrease the predicted risk of illness from the consumption of RTE 

products prepared or sliced in the retail deli by approximately 34%. Cross-contamination is 

particularly difficult to control completely; however, the risk assessment shows that proper

product handling, cleaning, sanitizing, and glove use help prevent cross-contamination.

• Control Contamination at its Source. Increased levels of Lm from incoming products and

the environment (including potential niches), directly increases the predicted risk of illness. 

Therefore, elimination of environmental niches in the deli area will reduce the predicted risk 

of listeriosis from the consumption of RTE products prepared or sliced in the retail deli. 

Additionally, if levels of Lm on RTE foods (including foods that do not support the growth of 

Lm) that the retail deli receives from processing establishments were reduced by half,

approximately 22% of the predicted listeriosis illnesses caused by contaminated deli 

products could be prevented. This finding suggests that continued efforts to prevent low 

levels of Lm contamination during processing, even on products that do not support growth 

of the pathogen, reduces the predicted risk from these products and other RTE foods that 

can be subsequently cross-contaminated in the retail delis.

• Continue Sanitation. Sanitation practices that eliminate Lm from deli food-contact surfaces 

reduce the predicted risk of illness. Cleaning and sanitizing food-contact surfaces reduces 

the predicted Lm levels in the deli area. Employees not wearing gloves while serving 

customers increases the predicted risk of listeriosis from the consumption of RTE products 

prepared or sliced in the retail deli by approximately 5%.

5
How to Use this Guidance

This guidance provides practical recommendations that retailers can use to control Lm

contamination and outgrowth in the deli area based on the findings of the Interagency Retail Lm

Risk Assessment, available scientific knowledge, the 2013 FDA Food Code, as well as lessons 

learned from controlling Lm in meat and poultry processing establishments. Retailers can use 

this best-practices guidance to help ensure that RTE meat and poultry products in the deli area 

are handled under sanitary conditions and are not adulterated as defined in the FMIA and PPIA. 

While these practices are designed to control Lm specifically, they also may help control other 

food borne pathogens that may be introduced into the retail deli environment and other facilities 

where consumers take possession of food. 

The best practices are divided into four sections: (1) product and product handling, (2) cleaning 

and sanitizing, (3) facility and equipment controls, and (4) employee practices. Practices

identified by the risk assessment that can significantly decrease the predicted risk of foodborne

illness are highlighted in each section. The other practices that are based on scientific

knowledge or lessons learned also will help retailers increase Listeria control in the deli area. 

For example, although floors and drains were not considered as a source of crosscontamination according to the Interagency Retail Lm Risk Assessment, FSIS data has shown 

that floors, drains, and items like floor mats tend to be harborage points in FSIS establishments. 

Providing this information can assist retailers in controlling Lm in the deli area. A selfassessment tool, starting on page 14 of this guidance, is provided for deli operators to help 

them identify the best practices they are using and to assess whether they need to adopt others. 

By following the best practices in the guidance and the 2013 FDA Food Code, retailers can help 

ensure that RTE products are not adulterated with Lm, and that the potential for listeriosis is

decreased. 

NOTE: Retailers should be aware that the recommendations in this guidance, especially those 

based on the 2013 Food Code may be requirements in State, local, or tribal regulations. 

Questions on this guidance may be submitted through AskFSIS. 

6 
Product Handling

The Interagency Retail Lm Risk Assessment found that using practices that prevent bacterial 

growth in the product substantially reduced the predicted risk of listeriosis. In addition, while the 

risk assessment showed that the risk from incoming Lm-contaminated products that do not 

support growth is low, it also showed that these products can cross-contaminate RTE products 

that support growth, and when they do, the risk 

increases substantially. The formulation of RTE 

products with antimicrobial agents prevents 

growth of Lm in RTE foods both at retail and 

during consumer home storage, leading to an 

overall reduction in the predicted risk of 

listeriosis. The 2013 FDA Food Code (3-

501.16(A)(2)) recommends keeping RTE 

products at or below 41°F (5°C), which slows 

the growth of Lm in the deli and decreases the

predicted risk for listeriosis. Other scientific 

studies also have shown that preventing product 

contamination reduces the risk of foodborne 

illness.

Therefore, it is important for retailers to adopt 

practices that protect RTE product from 

contamination with Lm and to use strategies to 

prevent or limit the growth of Lm in deli products. 

Below are a few such strategies. 

• Use products formulated with 

antimicrobial agents (e.g., acetic acid, 

sodium diacetate, lactic acid, citric acid) 

when possible, to eliminate or prevent 

the growth of Lm in RTE products. In 

some cases, the addition of antimicrobial 

agents may not be possible because of

the adverse effect on the flavor of the 

products. Retailers can read the 

ingredients statements on the labels to 

see whether the products in the deli have 

antimicrobial agents and can contact 

their suppliers to determine whether 

products formulated with antimicrobial 

agents are available.

NOTE: As stated previously, the 

Interagency Retail Lm Risk Assessment 

estimated that if antimicrobial agents are 

used in all products in the deli, the 

predicted risk of listeriosis from the 

consumption of RTE products sliced or 

prepared in retail departments could be 

decreased by approximately 96%.

Things to Consider at Retail

 Are the deli products being sold 

formulated with antimicrobial 

agents? 

 Is RTE product properly identified 

and labeled?

 Are RTE products identified with 

the date the package is opened? 

 Is RTE product discarded if it is 

past the recommended discard 

date?

 Is there a process to routinely 

remove RTE products that are not 

suitable for sale from the retail 

case? 

 Are RTE meat and poultry 

products promptly refrigerated 

after use? 

 Are RTE products prepared and 

stored adjacent to raw product?

 Is the retail deli case maintained at 

41°F (5°C) or below to prevent 

pathogen growth?

 Is RTE product covered, wrapped, 

or otherwise protected after 

opening?

 Are RTE products placed on the 

same contact surfaces as other 

RTE product, e.g., cheese, 

vegetables, seafood?

7
• Use products that have been treated to reduce pathogens (e.g., through high pressure 

processing (HPP)). This information can be determined from certificates of analysis 

(COA), letters of guarantee (LOG), or other information from suppliers. Separate 

products that support growth from products that do not support growth (when possible) 

to help prevent cross contamination. 

NOTE: As stated previously, the Interagency Retail Lm Risk Assessment found that if 

current levels of Lm in RTE foods (e.g., meats, cheeses, and salads) received by the 

retail deli were reduced by half, the predicted risk of listeriosis from the consumption of 

RTE products sliced or prepared in retail deli departments could be decreased by 

approximately 22%.

• Monitor the shelf life of an RTE product that is opened, prepared, and held in a retail 

setting for more than 24 hours. To monitor shelf life of the opened product, retailers 

should date-mark the product (e.g., clearly mark it with the date of opening and the 

discard date) as recommended by the 2013 FDA Food Code (3-501.17). Products also 

should be properly identified and labeled. RTE products that are past their shelf life 

should be discarded. 

• Do not pre-slice products in the morning, after cleaning. Retailers should slice the 

product at the time it is requested by consumers.

NOTE: The Interagency Retail Lm Risk Assessment found that pre-slicing the product 

increases the predicted risk of listeriosis from the consumption of RTE products sliced or 

prepared in retail deli departments by approximately 6%. 

• Remove products that are filthy, putrid, decomposed, slimy, rancid, or in off-condition, 

which are considered adulterated, from the deli area as soon as possible. Thoroughly 

clean and sanitize areas that were contacted by the affected product to prevent any 

cross-contamination.

• Promptly return RTE products to refrigerated units, after slicing, to prevent pathogen 

growth. Maintain refrigeration units at or below 41°F (5°C) to slow the growth of Lm, as 

recommended by the 2013 FDA Food Code (3-501.16(A)(2)). RTE products should be 

covered, wrapped, or otherwise protected to prevent cross-contamination when not in 

use. 

NOTE: The Interagency Retail Lm Risk Assessment found that storing the products at or 

below 41°F (5°C) decreases the predicted risk of listeriosis from the consumption of RTE 

products sliced or prepared in retail deli departments by approximately 9%. 

• Store and handle RTE products in separate areas from raw products. RTE products that 

are prepared, held, or stored near raw products can become contaminated (e.g., 

because of aerosolization or dripping). The 2013 FDA Food Code (3-302.11(A)(1))

recommends that retailers separate RTE foods from raw foods. If storage space is 

limited, wrap the products and store RTE products above raw products. When 

wrapping, unwrapping, and slicing products, take care to prevent cross-contamination 

from the outer wrapper, other products, and unclean surfaces and utensils. Raw 

8
products (e.g., chicken used for frying or rotisserie) prepared in the same area as RTE 

products can increase the potential for cross-contamination.

• Clean and sanitize surfaces between RTE items when using the same equipment to cut, 

slice, or otherwise reduce the size of large RTE products (e.g., ham, seafood, and 

vegetables).

• Ensure that grinders, dicers, or other equipment are maintained in sanitary condition 

when preparing deli salads. 

Cleaning and Sanitizing 

The Interagency Retail Lm Risk Assessment 

found that following the sanitation practices in the 

2013 FDA Food Code aid in controlling Lm on deli 

area food contact surfaces and reduces the 

predicted risk of listeriosis. The 2013 FDA Food 

Code (4-602.11(C)) recommends cleaning 

equipment and utensils at least every 4 hours. 

Below are some key issues to consider when 

cleaning and sanitizing. 

• Develop written sanitation procedures that 

describe how utensils and equipment (e.g., 

slicers) will be cleaned and sanitized prior 

to use. Ensure employees are familiar with 

and follow these procedures to reduce the 

risk of contaminating RTE products with 

Lm. Insanitary conditions (e.g., flies, 

rodent droppings, mold, or dirty surfaces) 

should not be present in retail areas. 

Retailers should document the actions 

they perform to ensure that sanitation 

procedures are performed on a regular 

basis.

NOTE: The Interagency Retail Lm Risk 

Assessment found that the predicted risk 

of listeriosis from the consumption of RTE 

products sliced or prepared in retail deli 

departments increases by approximately 

41% if wiping, washing, and sanitizing 

activities are not performed.

• Clean and sanitize utensils and equipment 

used to handle, prepare, and store RTE 

products frequently (e.g., at least every 4 

hours as recommended by the 2013 FDA 

Food Code (4-602.11 (C)) to maintain 

sanitary conditions throughout the day. 

Things to Consider at Retail

 Are sanitation procedures 

documented?

 Are RTE product contact 

surfaces cleaned and 

sanitized prior to use?

 Are routine cleaning and 

sanitation procedures 

performed in areas where 

RTE products are handled, 

stored, and sold?

 Is RTE equipment 

disassembled before cleaning 

and sanitizing?

 Are surfaces scrubbed during 

cleaning to prevent biofilm 

formation?

 Are sanitizers used at the 

recommended 

concentrations?

 Are sanitizers rotated on a 

periodic basis?

 Are cleaning cloths rinsed or 

soaked in sanitizer between 

uses?

 Are only low-pressure water 

sources (hoses) used during 

cleaning to prevent 

splashing?

9
Clean and sanitize items that employees routinely handle, such as on/off switches, slicer 

handles, display cases, cooler handles, and similar surfaces.

NOTE: As stated previously, the Interagency Retail Lm Risk Assessment found that 

slicers are sources of Lm cross-contamination to RTE foods. Control of Lm crosscontamination at all points (including slicers) during retail preparation and handling of 

RTE foods will reduce the predicted risk of listeriosis from the consumption of RTE 

products sliced or prepared in retail deli departments by approximately 34%.

• Disassemble RTE food-processing equipment when cleaning and sanitizing equipment 

as recommended by the Food Code to ensure that hard to reach areas where Lm can 

hide are addressed. For more information, see the FDA poster: Keep Commercial Deli 

Slicers Safe. 

• Scrub surfaces during cleaning to prevent biofilms from occurring. Biofilms are thin 

layers of microorganisms that adhere to product contact surfaces. Lm and other 

bacteria can adapt to the environment over time and form biofilms. Biofilms are difficult 

to remove, and they may protect Lm from the effects of sanitizers.

• Follow the manufacturer’s recommendations for sanitizer strength and application to 

ensure it is effective. Many sanitizers, when used as recommended, are effective 

against Lm, including those containing quaternary ammonia compounds, chlorine 

solutions, and organic acids. Generally, increasing the sanitizer strength above the 

recommended levels will not increase the efficacy of the sanitizer and may result in 

harmful levels of the sanitizer in foods. 

• Rotate (change) sanitizers as needed to provide more effective bacterial control. 

Alternating sanitizers (e.g., quaternary ammonia and bleach) may help prevent Lm from 

establishing niches in the environment and forming biofilms. For example, retailers can 

use quaternary ammonia on the week days and bleach on the weekends when rotating 

sanitizers. 

• Develop a procedure to sanitize cleaning aids or have single-use items that are 

discarded after use. Cleaning cloths, brushes, sponges, mops, and similar cleaning aids 

can become contaminated with bacteria and then can spread the bacteria to every 

surface they contact. Therefore, they should be cleaned of visible material and soaked 

in clean sanitizer between uses. Retailers should monitor sanitizer strength and change 

the sanitizer as needed so that food particles do not overwhelm the effectiveness of the 

sanitizer.

• Use low water pressure when cleaning in the deli areas. Splashing and overspray from 

high-pressure hoses can aerosolize microorganisms and distribute them into the air and 

onto nearby surfaces.

• Use separate sinks for hand washing and cleaning product or equipment (as 

recommended by the 2013 Food Code (2-301.15 and 4-501.16)). Hand washing can 

cause the sink to be contaminated with Lm and other pathogens, which can be spread to 

any other items cleaned in the sink. 

10
• Eliminate or remove unnecessary items (e.g., supplies and equipment) from the deli 

area. Organize supplies and equipment to facilitate thorough cleaning. 

Facility and Equipment Controls

As stated on page 4, the Interagency Retail Lm Risk Assessment found that increasing the 

level of Lm and the potential of cross-contamination increases the predicted risk of 

listeriosis. The 2013 FDA Food Code (6-101.11(A)(1)) recommends that floors, walls, and 

ceilings be smooth, durable, and easily cleanable. 

Facilities, equipment, and utensils should not 

contribute to product adulteration or contamination. 

Here are some areas to check and some insanitary 

issues to avoid.

• Do not allow conditions in the retail facility that 

could cause the product to become adulterated. 

These conditions could include condensation 

dripping on exposed product, construction dust 

on product or food contact surfaces, or broken 

equipment which could harbor Lm.

• Ensure that walls, floors, drains, and overhead 

structures in the RTE deli and cooler areas are

smooth, durable, easily cleanable, and in good 

repair. Rubber floor mats and other items used 

on the floor may be harborage sites for Lm. 

Clean them as often as necessary to ensure

that sanitary conditions are maintained.

• Do not perform construction (e.g., replacing 

floors, walls, or ceilings) when exposed RTE 

product is present in the deli. Lm can be 

harbored behind the walls and carried by dust. Therefore, the product and equipment

should be protected during construction, and the deli area should be cleaned and 

sanitized after construction and before use. 

• Maintain tables, slicers, and other food contact surfaces so that they are easily 

cleanable. Rough surfaces created by welds, cracks, and other defects can be difficult 

to clean and can create areas where bacteria can hide. Replace worn, missing, or 

degraded seals or gaskets because they may become contaminated with Lm. 

• Clean overhead structures as often as necessary to keep them free of condensation and 

ensure that sanitary conditions are maintained. Overhead items (e.g., cracked light 

fixtures) can be Lm harborage points. Condensation on overhead structures can lead to 

contamination of food or food preparation surfaces.

• Keep water from pooling on the floor or other surfaces within the deli area. Doing so will 

reduce the likelihood that splashes could contaminate food products or food contact 

surfaces. Standing water can serve as a vehicle for Lm and other pathogens.

Things to Consider at Retail

 Is the facility structure in 

good repair to prevent 

contamination or 

adulteration of products in 

the deli area?

 Is the equipment nonporous 

and free of cracks, pits, and 

rough welds?

 Is the overhead structure in 

the deli area free of 

condensation?

 Is the deli area free of 

standing water on floors or 

product contact surfaces?

11
Employee Practices 

As mentioned previously, the Interagency Retail Lm

Risk Assessment found that wearing gloves while 

serving customers reduces the predicted risk of 

listeriosis. The 2013 FDA Food Code also 

recommends that employees wear gloves or use other 

suitable utensils to handle RTE foods and includes 

recommendations for training, hand washing, 

employee health and hygiene, and limiting public 

access in deli areas to prevent product contamination 

(references below). Good employee hygiene practices 

are critical to prevent cross-contamination and the 

spread of Lm and other pathogens. Lm can be 

present on, and spread by, equipment, materials, 

foods, and people. Here are a few employee practices 

retailers can use to minimize cross-contamination. 

• Ensure that employees wear gloves or use 

suitable utensils when handling RTE products, 

as recommended by the 2013 FDA Food Code 

(3-301.11(B)). Provide disposable gloves so 

that employees wear and change gloves, as 

needed, to prevent the contamination of food. 

NOTE: The Interagency Retail Lm Risk 

Assessment found that employees not wearing 

gloves increases the predicted risk of listeriosis 

from the consumption of RTE products sliced 

or prepared in the retail deli department by 

approximately 5%.

• Train employees in sanitation practices and 

safe food handling procedures. Ensure that the 

manager has knowledge of food safety 

practices and procedures, as recommended by the 2013 FDA Food Code (2-102.11), 

and that employees have been properly trained in hygienic practices.

• Provide adequate facilities, including soap and running water, for employees to wash 

their hands. As recommended by the 2013 FDA Food Code (2-301.14), employees 

should wash hands prior to gloving, when switching between handling raw and RTE 

foods, after engaging in other activities that may contaminate the hands (e.g., handling 

money or potentially dirty or contaminated surfaces), or using the restroom.

• Implement a policy to ensure that ill employees do not work with open food items, 

including RTE foods. For example, written procedures should include removing workers 

from the deli when they are ill with respiratory or diarrheal diseases, as recommended by 

the 2013 FDA Food Code (2-201.11).

Things to Consider at Retail

 Are there procedures to 

prevent ill employees from 

working in the food 

preparation area?

 Do employees wash hands 

prior to handling exposed 

RTE product?

 Do employees wear 

disposable gloves when 

handling exposed RTE 

product?

 If employees wear 

disposable gloves, do they 

change them, as necessary,

to prevent crosscontamination (e.g., after 

handling raw product or 

money) when handling RTE 

product?

 Is foot traffic limited in RTE 

food product handling 

areas?

12
• Limit employee traffic in the deli area and develop traffic-flow plans for product, 

employees, and other items to prevent contamination by consumers and employees. 

The plans should minimize exposure of open RTE foods to raw foods, exterior 

packaging, and other possibly contaminated materials, such as boxes, trash, and 

chemicals. Designing facilities and controlling traffic in the deli area to restrict movement 

of people and material reduces the chance of cross-contamination. Non-deli workers 

should not handle exposed RTE products.

• Develop practices to prevent outer clothing from spreading contamination. Ensure that 

employees change their aprons or outer clothing, such as frocks or smocks, when the 

clothing is soiled with food or dirt particles that could transfer to food or food contact 

surfaces. Employees should not hold exposed RTE food products against their aprons 

or other clothing. Employees should not wear this outer clothing into restrooms, in break 

areas, or outside the deli area.

13
Deli Self-Assessment Tool 

Retailers should use this tool to determine whether they have adopted the appropriate

procedures to control Lm, or whether they should adopt new procedures. The preferred answer

(based on the information in the guidance) is indicated with an asterisk. Having a “no” answer 

does not necessarily indicate lack of control. If retailers find that they are not meeting the 

recommendations in this guidance, they should consider changing practices to better control Lm

in the deli area. 

Product/ Product Handling: RTE Deli Area YES NO N/A

1. Is any visibly adulterated product present in the area (e.g., 

filthy, putrid, decomposed, slimy, rancid, off-condition)? □ □* □

2. Are RTE meat or poultry products refrigerated promptly 

after use? □* □ □

3. Is RTE product prepared, held, or stored near or adjacent 

to raw product in the deli case and elsewhere in the deli 

area?

□ □* □

4. Is the RTE product date-marked when opened? □* □ □

5. Is there any RTE product in the deli case that is outside of 

the date-marked period? □ □* □

6. Are the deli cases and other refrigerated units maintained 

at or below 41°F (5°C)? □* □ □

7. Is opened RTE product covered, wrapped, or otherwise 

protected to prevent cross-contamination when not in use 

in the deli case and elsewhere in the deli area?

□* □ □

8. Is RTE product stored in the deli case properly identified 

and labeled? □* □ □

9. Do you use deli products formulated with antimicrobial 

agents? □* □ □

10. Are RTE product contact surfaces cleaned and sanitized

prior to using the surface for another product to avoid 

cross-contamination of products?

□* □ □

11. If you prepare deli salads, are there controls in place to 

ensure that grinders, dicers, or other equipment are 

maintained in sanitary condition?

□* □ □

Cleaning/Sanitizing: RTE Deli Area YES NO N/A

12. Are insanitary conditions (e.g., flies, rodent droppings, 

mold, or dirty surfaces) present in areas where meat and 

poultry products are prepared, packed, or held? 

□ □* □

13. Do you use sanitizers at the proper concentration? □* □ □

14. Do you clean and sanitize the RTE equipment (including 

slicers) at least every 4 hours? □* □ □

15. Do you disassemble RTE equipment (including slicers) 

during cleaning and sanitizing? □* □ □

16. Do you scrub surfaces during cleaning to prevent biofilms? □* □ □

17. Do you soak or rinse cleaning cloths in sanitizer between 

uses? □* □ □

14
18. Are sanitizer types (e.g., quaternary ammonium, chlorinebased, or iodophores) rotated periodically? □* □ □

19. Do you clean the RTE area with a high pressure hose

(e.g., with enough pressure to cause splashing)? □ □* □

20. Are there separate sinks for hand washing and other 

uses? □* □ □

21. Do you have material (e.g., pallets, milk cartons, cardboard 

boxes, or push carts) in the deli area that makes cleaning 

difficult? 

□ □* □

Facility: RTE Deli Area YES NO N/A

22. Are there facility conditions (e.g., condensation dripping on 

exposed product, construction dust on product, or broken 

equipment) that could cause the product to become 

adulterated?

□ □* □

23. Is there condensation on overhead structures or over the 

RTE product? □ □* □

24. Is there standing water on surfaces, including the floor? □ □* □

25. Are product contact surfaces in good condition (e.g., nonporous surfaces, free from cracks, pits, and rough welds)? □* □ □

26. Are slicers and mixers in good condition (e.g., free of 

cracks, broken, missing or unattached parts; seals and 

gaskets not worn, degraded, or missing)?

□* □ □

27. Are the walls, floors, and ceilings sanitary and in good 

repair? □* □ □

Employee Practices: RTE Deli Area YES NO N/A

28. Are visibly ill employees working in food preparation areas

where product could become contaminated (e.g., by 

coughing or sneezing)?

□ □* □

29. Do employees work without washing hands prior to 

handling exposed RTE product? □ □* □

30. Do employees wear disposable gloves when handling 

exposed RTE product that will not be cooked? □* □ □

31. If employees wear gloves, do they changed them as 

necessary to avoid cross-contamination of RTE product? □* □ □

32. Do employees change outer clothing (e.g., frocks, aprons, 

or smocks) as often as necessary to avoid contamination 

of RTE product?

□* □ □

33. Is foot traffic limited to necessary employees in areas 

where RTE product is handled? □* □ □

*Preferred answer

References and Resources

Burnett SL, Mertz EL, Bennie B, Ford T, and Starobin A. Growth or survival of Listeria 

monocytogenes in ready-to-eat meat products and combination deli salads during refrigerated 

15
storage. Journal of Food Science. Volume 70, Issue 6, pages m301–m304, August 2005. 

(Role of temperature in Lm control)

Centers for Disease Control and Prevention website, found at http://www.cdc.gov/listeria/

(Lm and listeriosis overview)

Conference for Food Protection Listeria monocytogenes Intervention Committee. Voluntary 

Guidelines of Sanitation Practices Standard Operating Procedures and Good Retail Practices to

Minimize Contamination and Growth of Listeria monocytogenes Within Food Establishments. 

(Lm niche and sanitation practices) Found at: 

http://www.foodprotect.org/media/guide/2006CFPLmInterventionvoluntaryguidelines.pdf

Endrikat S, Gallagher D, Pouillot R, Hicks Quesenberry H, LaBarre D, Schroeder CM, and 

Kause J. A comparative risk assessment for Listeria monocytogenes in prepackaged versus 

retail-sliced deli meat. Journal of Food Protection. Volume 73, Issue 4, pages 612-619, April 

2010 (FSIS comparative Lm risk assessment)

FDA Food Code, 2013, found at: 

http://www.fda.gov/Food/GuidanceRegulation/RetailFoodProtection/FoodCode/ucm374275.htm

(Model regulations, ordinances, and policies for food safety)

FDA, Guidance for Industry: Control of Listeria monocytogenes in Refrigerated or Frozen 

Ready-To-Eat Foods; Draft Guidance, February, 2008. Found at:

http://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/Food

ProcessingHACCP/ucm073110.htm

FDA/FSIS, Quantitative assessment of relative risk to public health from foodborne Listeria 

monocytogenes among selected categories of ready-to-eat foods, 2003. Food and Drug 

Administration, United States Department of Agriculture, Centers for Disease Control and 

Prevention. Found at: 

http://www.fda.gov/Food/FoodScienceResearch/RiskSafetyAssessment/ucm183966.htm

(Lm risk assessment)

Folsom, JP and JF Frank. Chlorine resistance of Listeria monocytogenes biofilms and 

relationship to subtype, cell density, and planktonic cell chlorine resistance. Journal of Food 

Protection. Volume 69, number 6, pages 1292-1296, June 2006.

Food Marketing Institute (2006). Guidance for the Control of Listeria monocytogenes Risks in 

Retail Food Stores.

(Guidance for Lm control)

Food Marketing Institute (2012). FMI Listeria Action Plan for Retail Delis. Found at: 

http://www.fmi.org/docs/food-safety-best-practice-guides/listeria-action-plan-for-retaildelis.pdf?sfvrsn=9

(Guidance for Lm control)

Food Safety Authority of Ireland. The Control and Management of Listeria monocytogenes

Contamination of Food. 2005. Found at:

https://www.fsai.ie/WorkArea/DownloadAsset.aspx?id=1234

16
FSIS/FDA, Guidelines for Retail and Foodservice Establishments Affected by Natural or Other 

Disasters, found at:

http://www.fsis.usda.gov/wps/wcm/connect/1f4d9cef-3410-4d03-9dd6-

08fe089e1317/Fsis_Fda_Retail_Reopening.pdf?MOD=AJPERES

(Guidance for retail food safety)

FSIS Compliance Guideline: Controlling Listeria monocytogenes in Post-lethality Exposed 

Ready-to-Eat Meat and Poultry Products, 2014, found at:

http://www.fsis.usda.gov/wps/wcm/connect/d3373299-50e6-47d6-a577-

e74a1e549fde/Controlling-Lm-RTE-Guideline.pdf?MOD=AJPERES

(Guidance for FSIS regulated establishments)

Gibson KE, Koo OK, O'Bryan CA, Neal JA, Ricke SC, and Crandall PG. Observation and 

relative quantification of cross-contamination within a mock retail delicatessen environment. 

Food Control, Volume 31, Issue 1, pages 116-124, January 2013 (Bacterial cross-contamination

in the deli)

Gombas DE, Chen Y, Clavero RS, Scott VN. Survey of Listeria monocytogenes in ready-to-eat 

foods. Journal of Food Protection. Volume 66, Issue 4, pages 559-669, April 2003 (Retail 

surveys of Lm contamination in RTE products)

Hoelzer, K, Pouillot, R, Dennis, S, Gallagher, D, and Kause, J. “Update on Listeria 

monocytogenes: reducing cross-contamination in food retail operations.” In: Advances in 

microbial food safety, Volume 2. Sofos, J. (Ed). Woodhead Publishing, Cambridge, UK, 

December 2014. 

Lin CM, Takeuchi K, Zhang L, Dohm CB, Meyer JD, Hall PA, and Doyle MP. Crosscontamination between processing equipment and deli meats by Listeria monocytogenes. 

Journal of Food Protection. Volume 69, Issue 1, pages 71-79, January 2006 (Lm crosscontamination from slicers)

Lloyd T, Alvarado CZ, McKee SR, and Berrang ME. Control of Listeria monocytogenes in ham 

deli loaves using organic acids. Journal of Food Safety Volume 30, Issue 4, pages: 793–803, 

November 2010 (growth inhibitors)

Maitland J, Boyer R, Gallagher D, Duncan S, Bauer N, Kause J, and Eifert J. Tracking crosscontamination transfer dynamics at a mock retail deli market using GloGermTM. Journal of Food 

Protection. Volume 76, Issue 2, pages 272-282, January 2013. (Bacterial cross-contamination

in the deli)

Pan Y, Breidt Jr F, and Kathariou S. Resistance of Listeria monocytogenes biofilms to 

sanitizing agents in a simulated food processing environment. Applied Environmental 

Microbiology. Volume 72, Issue 12, pages 7711-7717, December 2006. (sanitation practices

for Lm control)

Pennsylvania State University (Penn State), College of Agricultural Sciences, Agricultural 

Research and Cooperative Extension. Control of Listeria monocytogenes in Retail 

Establishments, 2006. 

http://pubs.cas.psu.edu/freepubs/pdfs/uk137.pdf

(Guidance for Lm control)

17
Pennsylvania State University (Penn State), College of Agricultural Sciences, Agricultural 

Research and Cooperative Extension. Control of Listeria monocytogenes in Small Meat and 

Poultry Establishments, 2003.

http://extension.psu.edu/food/safety/other-topics/controlling-listeria/Cotrolling-Listeria-2.pdf/view

(Sampling for Lm, rotating sanitizers).

Pouillot, R, Gallagher, D, Tang, J, Hoelzer, K, and Kause, J. Listeria monocytogenes in retail 

delicatessens: an interagency risk assessment – model and baseline results. Journal of Food 

Protection, Volume 78, Issue 1, pages 134-145, January 2015.

Pradhan AK, Ivanek R, Gröhn YT, Bukowski R, Wiedmann M. Comparison of public health 

impact of Listeria monocytogenes product-to-product and environment-to-product contamination 

of deli meats at retail. Journal of Food Protection, Volume 74, Issue 11, pages 1860-1868, 

November 2011 (Bacterial cross-contamination in the deli)

Pradhan AK, Ivanek R, Gröhn YT, Bukowski R, Sofos JN, and Wiedmann M. Quantitative risk 

assessment of listeriosis-associated deaths due to Listeria monocytogenes contamination of 

deli meats originating from manufacture and retail. Journal of Food Protection, Volume 73, 

Issue 4, pages 620-630, April 2010 (Cornell University comparative Lm risk assessment)

Ryser T and Marth EH (eds). 1999. Listeria, Listeriosis, and Food Safety. Second Edition (Lm

and listeriosis overview)

Scallan E, Hoekstra RM, Angulo FJ, Tauxe RV, Widdowson MA, Roy SL, Jones JL, and Griffin 

PM. Foodborne illness acquired in the United States—major pathogens. Emerging Infectious 

Diseases, Volume 17, Number 1, pages 7-15, January 2011. (Estimates of foodborne illness in 

the U.S.)

Simmons, C, Stasiewicz, MJ, Wright, E, Warchocki, S, Roof, S, Kause, JR, Bauer, N, Ibrahim, 

S, Wiedmann, M, and Oliver, HF. Listeria monocytogenes and Listeria spp. contamination 

patterns in retail delicatessen establishments in three U.S. states. Journal of Food Protection, 

Volume 77, Issue 11, pages 1929-1239, November 2014.

Tompkin, RB. Control of Listeria monocytogenes in the food-processing environment. Journal 

of Food Protection, Volume 65, Issue 4, pages 709-725, April 2002. (Lm niche and sanitation 

practices)

Tompkin RB, Scott VN, Bernard DT, Sveum WH, and Gombas KS. 1999. Guidelines to 

prevent post-processing contamination from Listeria monocytogenes. Dairy, Food and 

Environmental Sanitation 19 (8): 551-562.

USDA/FDA, Interagency Risk Assessment: Listeria monocytogenes in Retail Delicatessens, 

2013. United States Department of Agriculture, Food Safety and Inspection Service and U.S. 

Food and Drug Administration, Center for Food Safety and Applied Nutrition. 

http://www.fsis.usda.gov/wps/wcm/connect/c0c6dfbc-ad83-47c1-bcb8-8db6583f762b/Lm-RetailTechnical-Report.pdf?MOD=AJPERES

(Lm risk assessment)

Vorst K L, Todd EC, and Ryser ET. Transfer of Listeria monocytogenes during mechanical 

slicing of turkey breast, bologna, and salami. Journal of Food Protection, Volume 69, Issue 3, 

pages 619–626, March 2006 (Lm cross-contamination from slicers)

18
Walker SJ, Archer P, and Banks JG. Growth of Listeria monocytogenes at refrigeration 

temperatures. Journal of Applied Bacteriology. Volume 68, Issue 2, pages157–162, February 

1990. (Temperature and general background information)

19